January 1 marked the launch of a new physician payment system, the Quality Payment Program (QPP) authorized by the Medicare Access and CHIP Reauthorization Act

(MACRA).

With the launch of QPP, physicians will no longer participate in the Physician Quality Reporting System (PQRS), the Value Based Modifier, or meaningful use program. Instead, the Merit-Based Incentive Payment System (MIPS), one of the QPP tracks, incorporates revised versions of these programs as well as a new Improvement Activities component.

Physicians who participate in an advanced alternative payment model (APM) will be exempt from MIPS. More information on QPP and its two tracks can be found here.

When the Centers for Medicare and Medicaid Services (CMS) released its final rule implementing MACRA last fall, it included major changes from its original proposal designed to ease the burden on physicians.

For those physicians who opt to participate in MIPS, CMS is allowing physicians to pick their pace and use 2017 as a test year. As long as physicians report one piece of quality data,

they will not be subject to a penalty in 2019. Physicians can still choose to report for the full year or some portion thereof and potentially earn a bonus.

In response to public comment, CMS further simplified the reporting options under MIPS and down weighted the cost category (formerly resource use) in 2017 since a risk adjust- ment methodology has not yet been finalized.

The reporting period for the advancing care information category, formerly known as meaningful use, was reduced to 90 days and its reporting requirements were simplified further. The low-volume threshold for participation in MIPS has been raised to less than $30,000 in Medicare Fee-for- Service (FFS) revenue OR less than or equal to 100 Medicare patients, which will help provide a better safety net for small practices.

We anticipate that CMS will release another notice of proposed rulemaking this spring making further changes to the program for 2018 when we anticipate all physicians will be required to fully participate in MIPS or an advanced APM.