SGR out, MIPS in—but how? CMS requesting input on implementation

As CMS figures out how to implement the new merit-based incentive payment system (MIPS) that replaces the sustainable growth rate (SGR) methodology, it is requesting information from the industry about alternative payment methods and incentive payments. CMS particularly seeks information on such topics as identifiers for MIPS eligible professionals (EPs), the quality performance category, data quality assurances, and the use of electronic health records (EHRs). The request will be published in the Federal Register on October 1, 2015, and comments must be received within 30 days to be assured consideration.


For the first two years of the program, the MIPS will apply to the following as EPs: physicians, physician assistants (PAs), nurse practitioners (NPs), clinical nurse specialists (CNSs), certified registered nurse anesthetists (CRNAs), and professional groups. Starting in the third year, the HHS secretary has the discretion to specify additional EPs. CMS currently uses Tax Identification Numbers (TINs) and National Provider Identifiers (NPIs) or a combination of the two to identify EPs in other programs. The agency requests input on which identifiers to use for MIPS, including potentially creating a distinct MIPS identifier. It also requests comments on parameters for virtual MIPS EP groups.

Quality measures

MIPS EPs may choose from a list of quality measures for assessments. CMS plans to use other quality programs to shape the performance category, but requests input about using physician quality reporting system (PQRS) reporting mechanisms for MIPS. The questions also address the application of the quality performance category to MIPS EPs in specialties. In a similar vein, CMS also wants to address how it should test for data accuracy and integrity, as data quality is vital to properly calculating the MIPS composite score.


A quarter of the MIPS composite performance score will be based on meaningful use of certified EHR technology. CMS is currently considering the methodology for assessing meaningful use, weighing methods such as basing the performance score solely on full achievement of meaningful use versus using a tiered methodology. The request for information notes that comments are only sought on meaningful use under MIPS, not the Medicare and Medicaid EHR Incentive Program.