On July 29, CMS released its proposed updates to the MIPS program. Physician groups have already provided feedback and commented on the proposed changes which, if passed, would go into effect for plan year 2020. Here’s what you need to know:

Evaluation and Management Codes Reworked

Physician groups are happy that controversial changes to evaluation and management services have been reworked with the help of the American Medical Association (AMA). Under the original proposal, CMS would have paid physicians the same amount for an office visit regardless of case complexity.

Now, the proposed evaluation and management changes have been reworked, lead by the AMA to include the medical community’s input. CMS will retain five levels of coding for established patients, reducing the number of levels to four for office/outpatient visits for new patients, and revise code definitions. Finally, CMS will allow physicians to choose the visit level based on medical decision making or time criteria. Code set revisions will be effective January 1, 2021.

Max Payment Adjustment Criticized

But changes to payment adjustment rates drew criticism from one prominent group. The Amercian Medical Group Association (AMGA) criticized the change in rate for essentially de-incentivizing MIPS participation. Instead of an up to 9% potential payment adjustment on Medicare Part B in 2022, CMS estimates the overall adjustment will be 1.4%. The organization is concerned its members will not see promised returns for investing heavily into the MIPS program:

“…Our members expected to have the opportunity to earn a significant payment adjustment if they performed well,” said Jerry Penso, M.D., AMGA president and CEO. “By proposing an overly cautious approach, CMS is not rewarding those organizations that made the necessary investments in and championed value-based care as envisioned by congressional leaders.”

Relieving the Reporting Burden

Finally, the current administration proposes to streamline MIPS participation requirements with a new framework titled “MIPS Value Pathways.” This framework would allow physicians to report on a smaller set of specialty-specific measures that would still be outcome based, but more closely aligned to APMs. Furthermore, the new path would allow CMS to provide more data feedback overall, and includes new Medicare coverage for opioid treatment programs to combat the national epidemic.

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