Announcement from the Federal Office of Rural Health Policy

May 2, 2016


Special Edition - April 29, 2016

Historic Change to How Clinicians Are Paid - Comments Requested by June 27
At the heart of the proposed rule that CMS issued on April 27th is the Quality Payment Program which, beginning in 2019, would offer new systems for paying doctors and other clinicians who serve Medicare beneficiaries.   One, the Merit-Based Incentive Payment System (MIPS), would evaluate the quality of care delivered based on four performance categories: cost, quality, exchange of information (use of electronic health records) and clinical practice improvement. The second system, advanced Alternative Payment Models (APMs), offers higher financial incentive to clinicians who improve quality by coordinating care across providers and settings.  Initiatives for coordinated care include CMS's Accountable Care Organization (ACO) Model and Comprehensive Primary Care.
The rule would consolidate three existing payment programs under MIPS:  the Physician Quality Reporting System, the Physician Value-based Payment Modifier and the Electronic Health Record Incentive Program. It is the first step toward implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which aims to lower costs while raising quality of health care delivery.  It's expected that most Medicare clinicians will initially participate in the MIPS program but over time will move toward the alternative payment model.
What do rural providers need to know?  First, that CMS needs your review and feedback to understand the challenges that are unique to rural areas and how these changes would affect your practice.  Once the proposed rule is officially published on May 9th, CMS will accept comments until Monday, June 27th.  Some key issues for your consideration:
For the first two years of MIPS, Eligible Professionals (EPs) would include physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists.  Other professionals may be added in later.
EPs below the low-volume threshold would be excluded from MIPS.  The proposal defines the threshold as having Medicare billing charges less than or equal to $10,000 and providing care for 100 or fewer Part B-enrolled Medicare beneficiaries.
The MIPS adjustment would apply to EPs who have assigned their billing rights to a Critical Access Hospital (i.e. Method II CAH billing). 
Currently, Rural Health Clinics and Federally Qualified Health Centers are excluded from reporting to MIPS since they are paid differently under Medicare. CMS is asking for comment on whether these safety net providers should but have the option to voluntarily report on applicable measures and activities with no penalty in order to remain in alignment with broader efforts under Delivery System Reform. 
Only certain APMs are considered as qualifying for receipt of incentive payments and exclusion from MIPS payment adjustments. 
CMS is providing opportunities to better understand the rule and provide early feedback through three sessions that are open to the public. Register now for an Overview of MACRA on Tuesday, May 3rd , an Overview of MIPS on Wednesday, May 4th, and an Overview of the Quality Payment Program on Tuesday, May 10th. Space for these webinars is limited and registration is required.  After your registration is completed, you will receive a follow-up e-mail with step-by-step instructions on how to log-in to the webinar.  CMS encourages review of the proposed rule (CMS-5517-P) prior to these listening sessions and reminds that the feedback you give will not be considered formal commenting.