Medicare’s current quality reporting program, PQRS, ends on December 31, 2016, as the Centers for Medicare and Medicaid (CMS) transition to the new Merit-Based Incentive Payment System (MIPS). Even though PQRS sunsets this year, the PQRS penalties are based on data reported two years before. Psychologists will see a 2 percent penalty applied to their payments in 2017 if they failed to successfully report measures in 2015. Now is the time for psychologists to report this year's PQRS measures to avoid a 2 percent penalty in 2018.
The APA Practice Organization’s registry, APAPO PQRSPRO, is available for those psychologists wishing to begin reporting quality measures in the new MIPS in 2017 and 2018.
CMS envisions a future where clinicians use certified health information technology to manage patients. CMS also foresees clinicians working with a Qualified Clinical Data Registry to obtain and report quality measures to both CMS and commercial payers, as well as to track patients for quality improvement.
The CMS proposed rule includes incentives for Alternate Payment Models (APMs) where physicians and other clinicians deliver comprehensive health care. APMs represent another payment model option and providers who meet the APM requirements are exempt from MIPS. Clinicians in their first year as Medicare providers are also exempt from MIPS.
CMS is proposing a low-volume threshold to exempt clinicians with $10,000 or less in Medicare claims and 100 or fewer Medicare patients. If this threshold is adopted, many psychologists will be exempt from MIPS. While exempted clinicians are protected from losses under MIPS, they will also be ineligible to receive positive payment adjustments because they cannot show value. This means that MIPS would have no impact on exempt psychologists' payment. If the allowed amount for 45 minutes of psychotherapy is $85, then a psychologist’s payment is $85.
The Practice Organization is working with CMS as it rolls out a new payment process and will continue to update members during this transition. Members with questions about PQRS and MIPS can contact government relations staff in the Practice Organization.