First and probably most importantly, the formulaic approach to setting base payment rates is gone, replaced with automatic increases for all doctors from 2015 through 2019. For six years after that…no automatic increases will be provided and doctors’ respective rates will be altered based on their performance under a Merit-Based Payment Incentive System (MIPS).
The MIPS is basically a consolidation of three pay-for-performance programs already underway and the addition of another…Current penalties under these programs are repealed, though, and the new incentive structure would be budget neutral. For every doctor that makes more from the MIPS, there will be one who makes less. A true zero sum game, if you will.
Assessments will be based on four categories of metrics: (1) quality; (2) resource use (or efficiency); (3) meaningful use of electronic health records…and (4) clinical practice improvement activities. The poorest performing doctors, determined by their composite score drawn from relevant aspects of all four categories, will see their payments cut by up to nine (nine!) percent…
Congress here would also set payments for the years 2026 and beyond. Then, the degree to which an individual doctor’s pay is increased will be dictated by their participation in so-called Advance Payment Models (APMs). Right now, that means accountable care organizations (ACOs), medical homes, bundled payment models, and the like.
Other provisions of interest include:
- The specific MIPS measures have not yet been selected. However, my guess is that they will likely be based largely on existing measures from the Physician Quality Reporting System (PQRS) and the physician Value-based Payment Modifier (VPM).
- There is additional funding for measure development, especially in the areas of “outcome measures, patient experience measures, care coordination measures, and measures of appropriate use of services, and consider gaps in quality measurement and applicability of measures across health care settings.”
- The financial impact of MIPS will be even larger than the current VPM system “Negative payment adjustments will be capped at four percent in 2018, five percent in 2019, seven percent in 2020, and nine percent in 2021″…a nearly 10% payment cut for physicians is huge.
- Physicians who participate in APMs (read ACOs, medical homes, etc.) are not eligible for MIPS.
- MIPS results will be posted on the Physician Compare website.