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San Francisco Marin Medical Society Blog

Payments, Penalties to Change Post-SGR



With the repeal of the sustainable growth rate (SGR) formula comes a new, consolidated quality reporting program for Medicare. Physician practices may be faced with bonus payments and financial penalties under the merit-based incentive payment system (MIPS).

The Medicare Access and CHIP Reauthorization Act (MACRA) has a variety of provisions, including medical liability protections and incentives for physicians who participate in alternative payment models. This post will spotlight a major provision that deals with alignment of quality reporting and value purchasing programs.

These pay-for-performance programs—the Physician Quality Reporting System (PQRS), the value-based payment (VBP) modifier, and the meaningful use electronic health record incentive program—currently require physicians to separately report various metrics for each program. The competing programs would leave many physicians facing a tsunami of regulatory penalties

Under MIPS, physicians will have the chance to earn bonuses if they score above average performance thresholds and avoid penalties if they meet those thresholds. MIPS also will give physicians the chance to score better and receive more credit for more quality improvement efforts—including a new category of clinical practice improvement activities—than under current programs.

Adjustment factors for performance assessment under the MIPS will be according to a “sliding scale”—versus the current “all or nothing” approaches used in PQRS and meaningful use. Credit will be provided to those who partially meet the performance metrics and for improvement as well as achievement.

Solo and small practices can join together in “virtual groups” and combine their MIPS reporting. The composite MIPS score will generally reflect four categories, which when fully implemented, will be weighted in these ways:

  • 30% - PQRS and quality
  • 30% - Value-based payment modifier and resource use
  • 25% - Meaningful use
  • 15% - Clinical practice improvement

CMS could adjust these percentages for physicians with limited measures and activities that are relevant to their practice. Starting in 2016, group practices also will be allowed to use qualified clinical data registries for PQRS and MIPS reporting. 


The three quality reporting programs continue through 2018, and then the MIPS will take effect in 2019. That same year, the secretary of the U.S. Department of Health and Human Services must inform physicians of their upcoming MIPS payment adjustment, whether it is a penalty or a bonus.

MIPS bonuses and penalties must balance out, and bonuses for the very best performers could be adjusted to go even higher—up to three times these amounts. Physicians also may earn “exceptional performance” bonuses of up to 10% from 2019 through 2024.

SFMS is collaborating with CMS Region IX to develop additional resources and in-person workshops to assist physicians with value-based payment (VBP) transition to avoid the mandated penalties. Click here for member-only tools (log-in required) or contact the SFMS.

Source: AMA Wire, July 2, 2015.



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