Policy & Regulation News

CMS Requests Merit-Based Incentive Payment System Discussion

By Jacqueline DiChiara

- The Centers for Medicare & Medicaid Services (CMS) will publish a proposed rule tomorrow (CMS-3321-NC2) requesting information about the implementation of the Merit-Based Incentive Payment System (MIPS) and allowing for a comment period extension on future reimbursement goals to November 17, 2015.

Merit-Based Incentive Payment System MACRA

According to HealthITAnalytics.com, it is feasible some healthcare providers may find the allegedly untimely nature of such commentary a tad unseasonable, since the system will not reach tangible fruition until several more years have passed. Perhaps CMS is merely concentrating its reimbursement energies on the art of correcting mistakes while time is on its side.

This 9-page public inspection document, currently in pending publication until October 20, prolongs the October 1, 2015 comment period for the document, “Request for Information Regarding Implementation of the Merit-based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models,” from November 2, 2015 by 15 days to November 17.

This document, CMS confirms, helps inform the public and CMS stakeholders about various priorities based on such documentation. CMS – founded to administer control of the Medicare Program and the federal portion of the Medicaid Program – says commenters may direct their written or electronic commentary accordingly.  National organizations have confirmed the need for additional time regarding the volume and depth of the original question period, says CMS, which has published nearly 3,500 documents within the past approximate two decades.

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  • “Since we requested the public to comment on various aspects of MIPS and APMs, we believe that it is important to allow ample time for the public to prepare comments regarding the October 1 RFI. Therefore, we have decided to extend the comment period for an additional 15 days,” confirms CMS’s proposed rule. “This document announces the extension of the public comment period to November 17, 2015. While we continue to welcome comments on all questions asked in the October 1 RFI, we suggest that the public and stakeholders may choose to focus their attention on issues that are a higher priority for CMS.”

    A highlighted summary of some of CMS’s posed questions to healthcare providers and stakeholders in relation to matters of revenue cycle management is as follows:

    • What types of data and information can eligible professionals (Eps) submit to CMS to determine if they meet the non-Medicare share of the Combination All-Payer and Medicare Payment Threshold? How can they be securely shared with the federal government?
    • What criteria might the Secretary consider for determining comparability of state Medicaid medical home models to medical home models expanded under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)?
    • Which states’ Medicaid medical home models meet criteria compared to those comparable to medical homes expanded under MACRA?
    • What criteria should the Physician-focused Payment Model Technical Advisory Committee implement to evaluate stakeholder submitted PFPM proposals?
    • What is appropriate “financial risk” under section MACRA to be considered an eligible APM (EAPM) entity?
    • What is the appropriate level of financial risk “in excess of a nominal amount” under MACRA to be considered an EAPM entity?

    CMS additionally explains the following regarding MACRA/MIPS:

    • Section 101 [MACRA] repeals the Medicare sustainable growth rate (SGR) methodology for updates to the physician fee schedule (PFS) and replaces it with a new [MIPS] for [MIPS Eps] under the PFS.
    • Section 101 of the MACRA (Pub. L. 114-10, enacted April 16, 2015) sunsets payment adjustments under the current Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VM), and the Electronic Health Records (EHR) Incentive Program. It also consolidates aspects of the PQRS, VM, and EHR Incentive Program into the new MIPS.
    • Additionally, section 101 of the MACRA promotes the development of Alternative Payment Models (APMs) by providing incentive payments for certain eligible professionals (EPs) who participate in APMs, by exempting EPs from the MIPS if they are qualifying APM participants, and by encouraging the creation of physician-focused payment models (PFPMs).