MIPS Performance Scoring: Understanding How CMS Proposes to Calculate Performance Is Key to Preparing for MIPS Participation

On May 9, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule addressing the implementation of physician payment reforms included in the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”). The proposed rule outlines the CMS framework for the Merit-Based Incentive Payment System (“MIPS”) and physician participation in Advanced Alternative Payment Models (“Advanced APMs”), two programs that intend to shift Medicare physician payments toward payments for value over volume. Most physicians and clinicians paid under the Medicare Physician Fee Schedule are expected to be subject to MIPS payment adjustments beginning in 2019. Accordingly, it is important for stakeholders to understand how performance under MIPS will be measured by CMS. This Client Alert provides further details about the MIPS composite performance scoring methodology included in the proposed rule. All stakeholders are encouraged to provide CMS with feedback on the proposed rule to help shape how these payment reforms are implemented. Comments are due no later than 5 p.m. (EDT) on June 27, 2016.