CMS provides clinicians flexibility under MACRA but retains 2017 start date for first performance period

Posted by Anne Phelps, Principal, US Health Care Regulatory Leader, Deloitte & Touche LLP and Daniel Esquibel, Deloitte Advisory Senior Manager, Deloitte & Touche LLP on September 9, 2016

In a blog post late Thursday, September 8, 2016, Centers for Medicare & Medicaid Services (CMS) Administrator Andy Slavitt announced two new options for participation in the Merit-based Incentive Payment System (MIPS) that are intended to give clinicians more flexibility to participate in the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Notably, the blog post states that the first performance period will still begin on January 1, 2017.

The first of the new options for MIPS participation will remove the prospect of negative payment adjustments for 2019 for clinicians so long as they report data based on performance in 2017 for the Quality, Advancing Care Information, and Clinical Practice Improvement Activities performance categories under MIPS. (Note: The Resource Use performance category is based on claims data and does not require clinicians to report data.)

The second new option will allow clinicians to submit performance data for a reduced number of days, rather than the full calendar year. The blog post states that this option will allow clinicians to potentially qualify for “small positive payment adjustments” while not reporting on performance for the full calendar year.

Based on the blog post, it appears that only clinicians who do not report any information under MIPS will receive negative payment adjustments. The final rule is expected to include detail of how this might affect the budget neutrality requirement under MIPS, including how the scaling factor for positive payment adjustments under MIPS will be applied.

The blog highlights that clinicians still will be able to participate in MIPS for the full calendar year and to participate in advanced alternative payment models (APMs).

More detail will be provided in the final rule, which the blog post indicates will be released by November 1, 2016.

This announcement, in many ways, reinforces the tight timeline facing clinicians under MACRA and reinforces the foundational role of MIPS preparedness for the health care system’s move toward performance-based payments and risk-based contracting.

For more on physicians’ overall readiness for MACRA based on new Deloitte survey findings, as well as an overview of MACRA and the timeline for implementation, visit

Anne Phelps
Principal | Deloitte Advisory
US Health Care Regulatory Leader
Deloitte & Touche LLP
Latest conversations from Anne Phelps on Twitter

Daniel Esquibel
Senior Manager
Deloitte & Touche LLP

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