Merit-Based Incentive Payment System: Meaningful Changes in the Final Rule Brings Cautious Optimism

Area of Science:

• Health Policy and Management
• Healthcare Quality Improvement
• Medicare and Medicaid Services

Background:

• The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the Sustainable Growth Rate (SGR) formula.
• MACRA introduced the Merit-Based Incentive Payment System (MIPS) to consolidate quality reporting programs.
• MIPS integrated Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-Based Payment (VBP) with a new Improvement Activities (IA) category.

Purpose of the Study:

• To analyze the evolution of the Merit-Based Incentive Payment System (MIPS) from its proposed to final rule.
• To assess the impact of stakeholder feedback, including from the American Society of Interventional Pain Physicians (ASIPP), on MIPS implementation.
• To evaluate the changes made to MIPS components, scoring, and reporting requirements in the final rule.

Main Methods:

• Analysis of the proposed and final rules for the Merit-Based Incentive Payment System (MIPS) under MACRA.
• Review of stakeholder comments and their incorporation into the final MIPS regulations.
• Examination of changes in MIPS category weighting, performance periods, and reporting thresholds.

Main Results:

• The final MIPS rule incorporated significant stakeholder feedback, including a 90-day reporting period and acceptance of non-MIPS measures.
• CMS introduced mechanisms for penalty avoidance, such as reporting for a single patient or a 90-day period.
• The final rule reduced the number of quality measures, eased the burden of the Advancing Care Information (ACI) and Improvement Activities (IA) categories, and improved coordination between performance categories.

Conclusions:

• The final MIPS rule demonstrates increased flexibility and reduced reporting burden compared to the proposed rule.
• While improvements have been made, concerns persist regarding scoring for quality improvement, resource use methodology, and the prominence of ACI.
• MIPS has been modified to be more meaningful, with bonuses for exceptional performance and adjusted reporting requirements for providers.