In a recent blog post, CMS Acting Administrator Andy Slavitt announced CMS’s plans to give physicians more options for complying with significant upcoming changes to Medicare physician fee schedule (MPFS) rules – which will help physicians avoid triggering a negative payment adjustment in the first year of the program.

As previously reported, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed the longstanding sustainable growth rate methodology for updating the MPFS. Instead, MACRA established a period of stable MPFS annual updates, after which MPFS updates will be made pursuant to either a new Merit-based Incentive Payment System (MIPS) or based on participation in qualified Alternative Payment Models (APMs). CMS published a proposed rule in May 2016 to implement the MIPS and APM reforms, which together CMS calls the “Quality Payment Program.” The first reporting period for the Quality Payment Program begins on January 1, 2017, and it will impact physician payment in 2019.

While CMS states that it intends to issue the final Quality Payment Program rule by November 1, 2016, Acting Administrator Slavitt “wanted to share our plans for the timing of reporting for the first year of the program.” In light of the “wide diversity of physician practices,” CMS will “allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017.” The blog post outlines the following four options for 2017 that would ensure that eligible physicians (and certain other clinicians) do not receive a negative payment adjustment in 2019:

  1. Test the Quality Payment Program – As long as a physician submits “some data” to the Quality Payment Program, including data from after January 1, 2017, the physician will avoid a negative payment adjustment. Such testing is intended to prepare the physician for broader participation in 2018 and 2019.
  2. Participate for part of the calendar year – Physicians may choose to submit Quality Payment Program information for a reduced number of days in 2017 and still qualify for a small positive payment adjustment.
  3. Participate for the full calendar year – Practices may submit Quality Payment Program information for a full calendar year beginning on January 1, 2017 and qualify for a modest positive payment adjustment.
  4. Participate in an Advanced APM in 2017 – If a practice receives enough Medicare payments or a certain number of Medicare patients through an Advanced APM in 2017, it would qualify for a 5% incentive payment in 2019.

CMS will provide more details about these options in the final rule this fall.