CMS is planning a new “Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration” that would allow clinicians who participate in certain Medicare Advantage (MA) plans that involve taking on risk to be treated as Advanced Alternative Payment Model (Advanced APM) participants under the Medicare physician fee schedule. By way of background, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established two tracks for Medicare physician fee schedule/Quality Payment Program updates:
- The Merit-based Incentive Payment System (MIPS), which adjusts Medicare payments based on performance on quality, cost, improvement activities, and advancing care information measures, or
- Advanced APMs, under which eligible clinicians may earn incentive payments for sufficient participation in certain payment arrangements that coordinate care, improve quality, and reduce costs.
CMS notes that some MA organizations (MAOs) are developing innovative, risk-bearing arrangements that resemble Advanced APMs, but participating clinicians still are subject to the Merit-Based Incentive Payment System (MIPS) track. The MAQI demonstration would test whether exempting such participating clinicians from MIPS reporting requirements and payment adjustments increases participation in these arrangements and changes the manner in which clinicians deliver care.
CMS expects that the first performance period for the MAQI demonstration will be 2018 and that the demonstration would last up to five years. CMS is accepting comments on reporting requirements associated with the planned demonstration; comments are due September 4, 2018.