Editor’s Note: Subsequent to the publication of this article, CMS has renamed the “Meaningful Use” programs to “Promoting Interoperability”.
With October upon us here is what we know about the future of the CMS Incentive Programs. Acting Administrator of CMS Andy Slavitt has detailed in a recent blog post that the Medicare Quality Payment Programs will indeed start on time. This means that starting 
January 1, 2017 the Merit Based Incentive Payment System (MIPS) and Advanced APMs will go live. His blog post details some modifications in reporting in the first year to allow providers who are just coming online some flexibility in reporting. He has stated that for clinicians to avoid the negative penalties, they are only required to submit some data for the 2017 reporting year. However, practices and clinicians who feel that they are ready to attest for a partial year, or the full year will still be able to receive increased reimbursements from the program. We aren’t sure exactly what the new MIPS program will look like, but the proposed rule has given us some pretty good ideas for what to be prepared for. Slavitt mentioned that we should expect to see the final rule by November 1, 2016. Although we might hope that the final rule text is less that the 962 pages the proposed rule gave us in April, we will probably be expectedly disappointed.
What does this mean for meaningful use?
This is sort of an interesting question. MACRA sets out to replace the Medicare EHR Incentive Program, PQRS, and the Value Based Modifier program. However, it only partially does this. Hospitals participating in the Meaningful Use Program will continue to do under the current rules. Medicaid participants in the EHR Incentive program will also continue with the current track they are on. It’s important to note that providers who bill more than $10,000 in Medicare and who are participating in the Medicaid EHR Incentive program will have to report on both to avoid the penalty for Medicare.
So meaningful use is going away for some providers, but not for everyone. That being said, the new Advancing Care Information performance category under MIPS strongly imitates the Meaningful Use program, so providers will likely continue to report on the same information.
But I am not ready to attest for Meaningful Use this year.
CMS has provided some guidance as to physicians who have struggled to attest to their first year of Meaningful Use. Providers will be able to apply for a significant hardship exception for 2016 to avoid the 2018 -4% payment adjustment if they have never successfully attested. However, this doesn’t mean they’re off the hook. In order for the provider to apply for significant hardship exemption, they will have to attest that they intend on participating in MIPS for 2017 and they will have to submit a successful meaningful use attestation for a 90-day period prior to October 1, 2017. It’s unclear what data will be expected for the MIPS attestation, but we expect to find out more when the final rule is released.
Look for more information on MIPS and Meaningful Use on our Blog.
