AMT Submits Comments to CMS on its Proposed Rule to Implement the Merit-Based Incentive Payment System (MIPS) Created by the MACRA Law 7/5/16
AMT recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) to implement the Merit-Based Incentive Payment System (MIPS) created by the MACRA law. MACRA contained the “permanent doc fix” that replaced the failed SGR payment formula with a new value-based payment system for physicians participating in Medicare – i.e., MIPS.
The MIPS program will combine into a single payment system elements from three existing incentive/penalty programs: the Physician Quality Reporting System (PQRS), the Physician Value-based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program, a.k.a. “meaningful use.” Although the EHR meaningful use requirements are largely retained in the Advancing Care Information performance category, beginning next year CPOE usage reporting will become one of a number of alternatives that physicians can use to satisfy the requirement for that performance category, making the reporting optional rather than mandatory. Physicians who participate in the Medicaid EHR meaningful use incentive program will still have to meet the full menu of Stage 3 objectives (including CPOE), even if they also participate in the Medicare MIPS payment system. AMT's comments on the proposed MIPS rule suggested that practitioners who attest to all of the Stage 3 measures under the Medicaid EHR program should be deemed to have satisfied the less-detailed objectives to earn a "base score" under the Advancing care Information performance category of MIPS.
(Link to AMT Comments)