CMS' proposal could change MIPS

On July 10, CMS proposed changes to physician payment policies and The Medicare Merit-based Incentive Payment System MIPS program. 

The new fee schedule includes a 2.8% reduction in physician payment. The decrease includes requirements that adjustments be budget neutral, the expiration of a 2.93% bump in 2024 and an adjustment related to the work relative value unit portion, according to a July 10 news release from CMS.

CMS proposed that the MIPS system performance threshold be maintained at 75 points for 2025. The threshold for 2024 was also 75 points, despite an initial proposal by CMS to raise the threshold to 82. Some advocates, including the AMA, have criticized the points threshold and the MIPS program overall, arguing that it disproportionately penalizes small independent and rural practices. 

In a July 8 blog post about AMA's own proposed changes to the MIPS program, they wrote: "The AMA has long been concerned about the undue administrative burden placed on physicians subjected to MIPS reporting requirements, the program’s lack of improvement in patient outcomes and quality of care, and the limited scope of quality measures for specialists." 

CMS is also soliciting feedback on the design of a "potential ambulatory specialty care mode" that would leverage the MIPS value pathways to "increase the engagement of specialists in value-based care and expand incentives for primary and specialty care coordination." 

The current concept for the system redesign would base payment adjustment on a set of "clinically relevant [value pathways] measures," in relation to other specialists or type of care setting. CMS also said in the ruling that if it were to "propose a future model test, it would do so through notice and comment rulemaking.

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