Advocating for You: Assisting physician anesthesiologists navigate the quality jouney and receive value-based payment
Why This Matters
The Quality Payment Program provides two general pathways for physicians to receive negative, neutral, or positive adjustments to their Medicare Part B covered professional services payments. These pathways are the Merit-based Incentive Payment System (MIPS) (including Traditional MIPS, MIPS Value Pathways (MVPs) and the Alternative Payment Program (APP)), and Advanced Alternative Payment Models (APMs). It is important to understand your reporting options and how they apply to your practice.
What You Should Know
Eligibility: Individuals and groups that do not meet the low volume threshold are not required to report MIPS or participate in an APM. Physicians, their groups, and other clinicians that fall under the low-volume threshold are exempt from MIPS participation if they:
Bill $90,000 or less in Medicare Part B allowed charges for covered professional services payable under the Physician Fee Schedule; or
Provider covered professional services for 200 or fewer Part B-enrolled individuals; or
Provide 200 or fewer covered professional services to Part B-enrolled individuals.
Traditional Merit-based Incentive Payment System (MIPS): Eligible Clinicians (ECs) and groups participating in the Merit-based Incentive Payment System (MIPS) will earn up to 100 points based upon their performances in four performance categories (Quality, Cost, Promoting Interoperability, and Improvement Activities). Non-participation in MIPS when an individual or group is required to participate will result in those ECs and groups receiving a -9% payment adjustment on their Medicare Part B payments.
MIPS Value Pathways (MVPs):The MVP policy was established in the 2023 reporting year to ease the burden placed on individuals and groups participating in MIPS. According to CMS, the MVP framework “aims to align and connect measures and activities across the quality, cost, and improvement activities performance categories of MIPS for different specialties or conditions.”
Alternative Payment Program (APP):The APP is an optional MIPS reporting and scoring pathway for MIPS eligible clinicians identified on the Participation List or Affiliated Practitioner List of any APM Entity participating in any MIPS APM. Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP) would be required to report through the APP for purposes of assessing their quality performance for that program, but MIPS eligible clinicians participating in these ACOs also would have the option of reporting outside the APP, or within it at an individual or group level, for purposes of being scored under MIPS, like all other MIPS APM participants.
Alternative Payment Models:Advanced Alternative Payment Models (APMs) reward eligible clinicians and practices for taking on some risk related to their patients’ outcomes. An APM often applies to three primary categories, specific clinical condition, a care episode, or patient population.
Current MIPS Performance Year Information:
In Performance Years 2023 and 2024, the performance threshold to receive a positive payment adjustment is 75 points. Individuals and groups scoring below 75 points will receive a negative payment adjustment in 2025 and 2026 (two years after the performance year). Those practices scoring exactly 75 points will receive a neutral adjustment. Those scoring above 75 points will receive a positive payment adjustment. The exceptional performance bonus is no longer available. Performance category weights are Quality 30%, Cost 30%, Promoting Interoperability 25%, and Improvement Activities 15%.
What is ASA Doing for You
ASA advocates in front of CMS on quality measures, quality measure development and maintenance.
We submit comments on behalf of ASA members and AQI NACOR registry participants in response to the Quality Payment Program federal rules and regulations.
We support individual and group MIPS reporting via the Anesthesia Quality Institute National Anesthesia Clinical Outcomes Registry (AQI NACOR).