# MIPS Proposed Rule



## dwaldman (Apr 30, 2016)

I am looking at this MIPS proposed rule that describes potentially in 2017 lowering the number of measures to 6 and removing NQS requirement for PQRS version of the requirement and changes to MU requirement on the thresholds for the measures that reflect measures of modified stage 2 or stage 3.



Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative
Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for
Physician-Focused Payment Models

https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf

Quality: For most MIPS eligible clinicians, we propose to include a minimum of six
measures with at least one cross-cutting measure (for patient-facing MIPS eligible clinicians) and
an outcome measure if available; if an outcome measure is not available, then the eligible
clinician would report one other high priority measure (appropriate use, patient safety,
efficiency, patient experience, and care coordination measures) in lieu of an outcome measure.
MIPS eligible clinicians can meet this criterion by selecting measures either individually or from
a specialty-specific measure set.

Resource Use: Continuation of two measures from the VM: total per costs capita for
all attributed beneficiaries and Medicare Spending per Beneficiaries (MSPB) with minor
technical adjustments. In addition, episode-based measures, as applicable to the MIPS eligible
clinician.

CPIA: We generally encourage but are not requiring a minimum number of CPIAs.

● Advancing Care Information: Assessment based on advancing care information
measures and objectives


By rewarding eligible clinicians based on their performance, MIPS consolidates
key components of the PQRS, the VM and the Medicare EHR Incentive Program for EPs into
one single, streamlined program based on performance in the following:
● Quality.
● Resource use.
● CPIA.
● Advancing care information.
Second, we are focused on improving the way care is delivered by providing clinical
practice support, data and feedback reports to guide improvement and better decision-making.

In response to the comments, and based on our desire to simplify the MIPS reporting
system and make the measurement more meaningful, we are  proposing MIPS quality criteria that
focus on measures that are important to beneficiaries and maintain some of the flexibility from
PQRS, while addressing several of the issues that concerned commenters.
● To encourage meaningful measurement, we are proposing to allow individual MIPS
eligible clinicians and groups the flexibility to determine the most meaningful measures and
reporting mechanisms for their practice.
● To simplify the reporting criteria, we are aligning the submission criteria for several of
the reporting mechanisms.
● To reduce administrative burden and focus on measures that matter, we are lowering
the expected number of the measures for several of the reporting mechanisms, yet are still
requiring that certain types of measures be reported.
● To create alignment with other payers and reduce burden on MIPS eligible clinicians,
we are incorporating measures that align with other national payers.
● To create a more comprehensive picture of the practice performance, we are also
proposing to use all-payer data where possible.
As beneficiary health is always our top priority, we propose criteria to continue
encouraging the reporting of certain measures such as outcome, appropriate use, patient safety,
efficiency, care coordination, or patient experience measures. However, we are proposing to
remove the requirement for measures to span across multiple domains of the NQS. We continue
to believe the NQS domains to be extremely important and we encourage MIPS eligible
clinicians to continue to strive to provide care that focuses on: effective clinical care,
communication, efficiency and cost reduction, person and caregiver-centered experience and
outcomes, community and population health, and patient safety. While we will not require that a
certain number of measures must span multiple domains, we strongly encourage MIPS eligible
clinicians to select measures that cross multiple domains. In addition, we believe the MIPS
program overall, with the focus on resource use, CPIAs, and advancing care information
performance categories will naturally cover many elements in the NQS.

We propose that for the
applicable 12-month performance period, the MIPS eligible clinician or group would report at
least six measures including one cross-cutting measure (if patient-facing) found in Table C and
including at least one outcome measure. If an applicable outcome measure is not available, we
propose that the MIPS eligible clinician or group would be required to report one other high
priority measure (appropriate use, patient safety, efficiency, patient experience, and care
coordination measures) in lieu of an outcome measure. If fewer than six measures apply to apply to the
individual MIPS eligible clinician or group, then we propose the MIPS eligible clinician or group
would be required to report on each measure that is applicable.
MIPS eligible clinicians and groups will have to select their measures from either the list
of all MIPS measures in Table A or a set of specialty-specific measure set in Table E.
Note that
some specialty-specific measure sets include measures grouped by subspecialty; in these cases,
the measure set is defined at the subspecialty level.
We designed the specialty-specific measure sets to address feedback we have received in
the past that the quality measure selection process can be confusing. A common complaint about
PQRS was that EPs were asked to review close to 300 measures to find applicable measures for
their specialty. The specialty measure sets in Table E are the same measures that are with within
Table A, however these are sorted consistent with the American Board of Medical Specialties
(ABMS) specialties. Please note that these specialty-specific measure sets are not all inclusive
of every specialty or subspecialty. We request comments on the measures proposed under eachthe specialty-specific measure sets. Specifically, we seek comments on whether or not the
measures proposed for inclusion in the specialty-specific measure sets are appropriate for the
designated specialty or sub-specialty and whether there are additional proposed measures that
should be included in a particular specialty-specific measure set.


The cross-cutting measures
that were available under PQRS for 2016 reporting that are not being proposed as cross-cutting
measures for 2017 reporting are:
● PQRS #001 (Diabetes: Hemoglobin A1c Poor Control).
● PQRS #046 (Medication Reconciliation Post Discharge).
● PQRS #110 (Preventive Care and Screening: Influenza Immunization).
● PQRS #111 (Pneumonia Vaccination Status for Older Adults).
● PQRS #112 (Breast Cancer Screening).
● PQRS #131 (Pain Assessment and Follow-Up).
● PQRS #134 (Preventive Care and Screening: Screening for Clinical Depression and
Follow-Up Plan).
● PQRS #154 (Falls: Risk Assessment).
● PQRS #155 (Falls: Plan of Care).
● PQRS #182 (Functional Outcome Assessment).
● PQRS #240 (Childhood Immunization Status).
● PQRS #318 (Falls: Screening for Fall Risk).
● PQRS #400 (One-Time Screening for Hepatitis C Virus (HCV) for Patients at Risk).
While we are proposing to remove the above listed measures from the cross-cutting
measure set, these measures are being proposed to be available as individual quality measures
available for MIPS reporting, some of which have proposed substantive changes. The proposed
MIPS cross-cutting measure set can be found in Table C of the appendix of this proposed rule
and will be available on the CMS website.

Page 773---Table A

TABLE A: Proposed Individual Quality Measures Available for MIPS Reporting in 2017 (Existing Measures
Finalized in CMS-1631-FC). The 2016 PQRS Measures Specifications Supporting Documents can be found at the
following link: https://www.cms.gov/medicare/quality-initiatives-patient-assessmentinstruments/
pqrs/measurescodes.html.

Page 823----Table C

TABLE C: Proposed Individual Quality Cross-Cutting Measures for the MIPS to Be Available to Meet the
Reporting Criteria Via Claims, Registry, and EHR Beginning in 2017

Page 836----Table E

TABLE E: 2017 Proposed MIPS Specialty Measure Sets

Page 838  Anesthesiology

Base Score
To earn points toward the base score, a MIPS eligible clinician must report the
numerator and denominator of certain measures specified for the advancing care information
performance category (see measure specifications in section II.E.5.g.7 of this proposed rule),
which are based on the measures adopted by the EHR Incentive Programs for Stage 3 in the 2015
EHR Incentive Programs Final Rule, to account for 50 percent (out of a total 100 percent) of the
advancing care information performance category score.

Page 209
TABLE 6: Base Score Primary Proposal Advancing Care Information Objective and
Measure Reporting*

Page 2012
TABLE 8: Base Score Modified Primary and Alternate Proposals Advancing Care
Information Objective and Measure Reporting for Modified Stage 2 (in 2017)


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