Home > EHR, meaningful use, Medicare > SGR and the Merit-Based Incentive Payment System: The Umbrella Carrot-and-Stick Program

SGR and the Merit-Based Incentive Payment System: The Umbrella Carrot-and-Stick Program

There has been a lot of talk, and rightfully so, about the “Merit-Based Incentive Payment System (MIPS)” concept included in the SGR Repeal and Medicare Provider Payment Modernization Act (the permanent SGR fix bill) currently in play on the Hill. As with the “Value Based Performance (VBP) Payment System” proposal (the earlier iteration of MIPS released for comment last October, presumably renamed to avoid confusion with the Value Based Modifier), MIPS would consolidate the three current Medicare incentive programs—Physician Quality Reporting System (PQRS), the EHR Incentive Program (“meaningful use”), and the Value Based Modifier (VBM)—into an umbrella carrot-and-stick program that eligible professionals would participate in if they do not receive a significant portion of their revenue through participation in alternative payment models (APMs). In other words, think of MIPS as a “pay for performance” alternative to APMs.

Similar to the previous VBP proposal, MIPS would award incentive payments or payment reductions to eligible professionals based on a “composite performance score” of 0-100 comprised of activities in four areas: quality, resource use, meaningful use, and clinical practice improvement activities. As with VBP, these score-based bonuses and payment reductions would effectively replace the penalties in each of the current three incentive programs with potentially bigger penalties—BUT, there would also be an opportunity for no penalties or even incentive bonuses depending on the professional’s score relative to everyone else. Unlike VBP, the legislative language for MIPS is far more explicit about how the incentives and penalties should be assigned to professionals relative to their score.

Importantly, the MIPS language also includes helpful provisions that implore regulators to consider the applicability of the various items that comprise the composite performance score to so-called “non-patient-facing” professionals and others. This language could conceivably result in alternative pathways to compliance with PQRS, MU, and/or VBM; removal of individual programs from the score for certain professionals; or even 1:1 replacement requirements for these professionals that fulfill the same goals. Regardless of the fate of the bill, this should send (yet another) message to the regulatory agencies involved that more consideration and flexibility is required in these programs for those who practice specialized medicine.

Categories: EHR, meaningful use, Medicare

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