One pathway is MIPS. Under MIPS, elements of the Physician Quality Reporting System, the Value-Based Payment Modifier, and the Meaningful Use program will be consolidated into a single program with four weighted performance categories on which eligible professionals will be assessed for reimbursement: 1) Quality; 2) Resource Use; 3) Clinical Practice Improvement Activities; and 4) Meaningful Use of Certified EHR Technology. For physicians who select the MIPS track, a methodology will be used to assess the physician’s performance provided for Medicare beneficiaries, and each MIPS eligible physician will receive a composite quality score for each performance period.
The other pathway is one of many alternative payment models (APMs) (e.g., Accountable Care Organizations). MACRA provides incentives for providers to participate in certain APMs. From 2019 through 2024, qualifying APM participants will receive a lump sum incentive payment of 5%. Qualifying APM participants will not be subject to MIPS adjustments; however, many components of MIPS, including electronic health records (EHRs), are also requirements of APMs.
At the moment, there is a lot to learn about both MIPS and APMs because many of the rules about MIPS and APMs are yet to be written. The specific benefits and drawbacks will become clear over time, as CMS continues to determine how it will put these two tracks into operation. The ACR is actively engaged with CMS administrators to make sure that the rules and quality measures defining each track are fair, feasible and logical for rheumatologists.
To strengthen the collective effort, the ACR has contracted with regulatory lobbyists who have expertise and relationships in this area, complementing the ACR’s lobbying efforts in the legislative arena. Over the coming year, the ACR will be launching an informational campaign that will give members access to up-to-date MACRA information and analysis throughout CMS’s decision-making process.
Navigating the MIPS Pathway
Method of Attribution: For those practitioners considering the MIPS pathway, the method of attribution is important—that is, the process by which patients get assigned to a particular doctor for cost and quality measures. Under MIPS, rheumatologists will be judged as a group based on every doctor who is a part of a single Tax Identification Number (TIN). Hence, if a patient with a complex condition sees many different doctors, cost and quality measurements will be aggregated for all doctors in the TIN. Under the APM track, the method of attribution will be by the physician’s National Practitioner Identifier (NPI), in a more precise, individualized manner. The takeaway here: If you work with people of high-quality care and low cost, MIPS will make sense for you. That said, knowing who is in your TIN will be an important consideration for those considering the MIPS pathway.
