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In 2019, Medicare is supposed to begin increasing or decreasing the amounts paid to doctors under a new merit-based incentive payment system (MIPS), which system will rely in large part on a doctor's 2017 performance under Medicare?s Quality Payment Program. This notion that 2019 Medicare payments will depend on 2017 performances has made many doctors particularly anxious because 2017 is fast approaching.

Happily, Andy Slavitt, Acting Administrator of the Centers for Medicare & Medicaid Services (CMS), recently published a post on the CMS Blog that provides some anxiety relief.  According to the recent CMS Blog post, the Quality Payment Program will allow eligible physicians and other clinicians to "pick their pace" of participation for the first performance period, beginning January 1, 2017. Eligible physicians and other clinicians can:

1.    Submit some data to the Quality Payment Program after January 1, 2017, and avoid the negative 2019 payment adjustment;
2.    Submit data to the Quality Payment Program for part of the 2017 calendar year, and qualify for a small positive 2019 payment adjustment;
3.    Submit data to the Quality Payment Program for the full 2017 calendar year, and qualify for a modest positive 2019 payment adjustment; or
4.    Participate in an Advanced Alternative Payment Model in 2017, and qualify for a 5% incentive payment in 2019.

Doctors may not know more until the final rule, which is set to be released by November 1, 2016. However, those doctors who are currently planning for implementation of the Quality Payment Program, and looking to avoid a negative payment adjustment in 2019, should make sure to submit some data to the Quality Payment Program in 2017.

Barry Rosen
(410) 576-4224 • brosen@gfrlaw.com