MIPS vs APM – it’s your choice. The “Quality Payment Program” is the umbrella term for two tracks under MACRA—the Merit-Based Incentive Payment System (MIPS) track and Advanced Alternative Payment Model (APM) track.
Every psychiatry Medicare practitioner will be asked to choose between the two. Both MIPS and APMs will reimburse Medicare providers based on value of services rather than volume.
Keep in mind, once you choose an APM, you cannot move to the MIPS track.
1) Who is eligible for Advanced APM status?
To be considered “Advanced,” the APM must meet specific criteria:
- Requires participants to use certified EHR
- Bases payment on quality measures comparable to those in the MIPS quality performance category.
- Meets one of two following requirements:
- Bears more than nominal financial risk for monetary losses, or
- Is a Medical Home Model under the Centers for Medicare and Medicaid Innovation (CMMI).
The Medicare Shared Savings Program, Health Care Quality Demonstration Program (HCQP), and others qualify as Advanced APMs.
Qualifying APM Participants, Please Note:
As with MIPS, certain payment and patient count thresholds apply.
This criteria requires information that may not be available – even in 2017. That factor makes your decision-making a little difficult.
- Eligible clinicians participating in Advanced APMs must meet specific criteria to be a Qualifying APM Participant or Partial Qualifying APM Participant.
Factors to Consider Regarding Your Current APM
- Are you participating in an APM right now, and plan to continue in 2017?
- Do you plan to start participating in an APM in 2017?
- It is possible that your current payment model may not meet the CMS definition of an Advanced APM?
- Is it possible that you may not have achieved the required thresholds to become a Qualifying or Partial Qualifying APM entity?
2) Are you participating in PQRS, MU and VBM?
It’s too early to decide right now whether MIPS or Advanced APM is the best option for you. However, your current involvement with healthcare reform programs will be important to your overall success.
If you already successfully participate in Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM), you’ve got an advantage over practices that aren’t yet engaged in these programs.
Experience with these alternative models will pay off, whether you decide to choose the APM or the MIPS option in 2019. This is because the current programs will be folded into MIPS in 2019.
3) Make it a team decision
- What will work best for your team as a whole?
Get your team together –physicians, administrators, technicians and talk about the details of each path, MIPS or APMs.
- What would be best for each psychiatry physician, for your clinic, and for your patients? Examine which option would be best for the upcoming year.
4) Consider PCMH for highest scores
The path of Certified Patient Care Model Home (PCMH) is attractive.
- A Medicare PCMH will automatically qualify for the highest possible score for the clinical practice improvement component of the MIPS program (15% of their total score).
- PCMHs can qualify as an APM without having to take the direct financial risk.
While the details of MACRA/MIPS are still being worked out, psychiatry clinicians are encouraged to seriously consider the PCMH model as an excellent strategic choice. With this experience under your belt, your practice will be well ahead of those still waiting to make a decision.
Watch for MIPS updates
At this printing, MIPS is scheduled to take effect January 1, 2017. The department of Health and Human Services has until November 1, 2016 to publish the quality measures. However, what you’ve just read is the most recent and accurate information we’ve gathered to date.