The Medicare clinician-payment rule was published on November 4, 2016, not on this November 12 coverage date. Its provisions take effect January 1, 2017. The final rule separates the 2017 performance period from the 2019 MIPS payment year. Reading those dates as one immediate payment change would misstate the transition. [2016-25240][2016-10032]

MIPS means Merit-based Incentive Payment System. It is one avenue of the Quality Payment Program; Advanced Alternative Payment Models provide another. CMS’s May 9 proposal had outlined consolidation of components of three existing programs and proposed measurement, reporting and scoring across four categories. It also proposed an alternative scoring standard for certain model participants. [2016-25240][2016-10032]

The final version does not activate every proposed detail unchanged. CMS assigned the cost category zero weight for the transition year and offered eligible clinicians different participation paces. It excludes low-volume clinicians with at most $30,000 in Medicare Part B allowed charges or at most 100 Medicare patients. Those are alternative exclusion tests. [2016-25240][2016-10032]

The useful sequence is proposal, final design, transition performance and later adjustment. January effectiveness alone does not describe an individual practice’s reporting position or payment result. Both retained documents are CMS products from the same rulemaking, not independent corroboration. They establish the framework and its historical development, while promised improvements in quality and efficiency remain aims rather than demonstrated results. [2016-25240][2016-10032]

Source documents

  1. Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Modelshttps://www.govinfo.gov/content/pkg/FR-2016-11-04/html/2016-25240.htm
  2. Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Modelshttps://www.govinfo.gov/content/pkg/FR-2016-05-09/html/2016-10032.htm