CMS has issued the long-awaited 2017 Proposed Rule that outlines the requirements for quality and meaningful use reporting for 2017.
The new program is called: Quality Payment Program and really has two parts. The Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APM).
We had some hints that APMs would be big in the new program, but the big news in the Proposed Rule was that not just any APM will do.
The APM must be an Advanced Payment Model. There is a complex formula for determining if an APM falls definitively in the Advance realm, but the biggest differentiator is that the APM must carry some downside financial risk. That’s why your average Track 1, Accountable Care Organization under the Medicare Shared Savings Program (MSSP) will not qualify. They will still need to participate in MIPS. Because they are participating in an MSSP, they will receive additional points in the category “Clinical Practice Improvement Activities.”
Medicare is aggressively pushing practices to Advanced APM by incentivizing them 5%. Though being an Advanced APM exempts the eligible clinicians from MIPS, they are required to show that they use Certified Electronic Health Record Technology (CEHRT) and they will continue to have to rigorously measure quality.
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