Merit-based Incentive Payment System: Here it Comes, Ready or Not

Under the Merit-Based Incentive Payment System (MIPS), radiologists will receive a composite performance score (0–100) based on a defined performance period. CMS will then use that score to adjust payments beginning in 2019. This gives us more than three years to prepare, right? Wrong. I estimate that we have 15 to 21 months until our performance period starts, and even less time than that to evaluate and understand the rules that will determine our performance score.

I present one potential MIPS implementation countdown in Table 1. Historically, CMS has used the Medicare Physician Fee Schedule (MPFS) rule-making process to implement its quality programs. If CY2017 proves to be the performance period for 2019, CMS must include those rules in the CY2017 MPFS, published in Federal Register in 2016, as I describe.  If this is the case, we have 15 months from now until our performance period and nine months from now to evaluate the rules. Once CMS finalizes the performance metrics, we will have only two months to implement those rules.

CMS might need more time to craft the rules and make them public. For example, CMS could have the performance period involve only the last six months of 2017 or start later in 2017 and extend the performance period into 2018. The downside for such a delayed timeline would be a shorter performance period or a tighter time frame for determining composite scores. Plus, such an alternative calendar could require a rule-making process, separate from the MPFS.

Whichever calendar CMS chooses, we don’t have much time. So what can we do to prepare? The answer depends on what metrics will be included in MIPS. Are there metrics that we know will be part of MIPS? The answer is yes. CMS could simply use the existing quality programs during the first MIPS performance period, and those rules are in place now. In fact, the Medicare Access and CHIP Reauthorization Act (MACRA) requires that the new system include measures used in the current quality, resource use and meaningful use (MU) programs. MACRA also describes a number of expected elements such as: (1) registry participation, including the use of Qualified Clinical Data Registries (QCDR), and (2) certified EHR technology (MU).

Head start

To that end, participants in the Physician Quality Reporting System (PQRS) are ahead of the game. Those of us participating through a QCDR, such as the ACR National Radiology Data Registry (NRDR) are even further ahead. Practices that have implemented the stage 3 MU program stand to benefit. Remember that we, radiologists, are not mandated to start with stage 1 and stage 2 MU; we can start with stage 3.

Let’s engage in and participate in PQRS and take a look at the QCDR option. Along the way, let’s implement the Stage 3 MU program, even though we are, technically, exempt from the MU adjustment in 2017.

Above all, we need to stay informed. The calendar I propose could change, but the relevant rules will be upon us sooner than we think. Keep the countdown I describe in mind: We don’t want to find ourselves out of time and then wondering what happened when the MIPS decreases our payments in the first quarter of 2019.

Ezequiel Silva III, MD, is the director of interventional radiology for South Texas Radiology Imaging Centers, San Antonio, the vice chair of the ACR Commission on Economics , and the ACR RVS Update Committee advisor.