Friday, June 9, 2017

Brief Blog: The Crazy Complicated World of MIPS-MACRA Measures

Update - 2018 MACRA rulemaking was published on June 21, 2017, here.  Trade article here.  26 page summary of 1074 page rule, here.


Just yesterday I was talking to a European consultant colleague about helping a European company understand how its innovative product might be affected by U.S. MIPS/MACRA measures.   (Answering that question is a substantial deep dive research project, including explaining in clear terms to foreigners what Medicare is and what MIPS/MACRA is, let alone drilling down into a specific subject area and then building out a corporate strategy and then executing it.)

In my inbox today, CMS is holding an annual call for MIPS/MACRA measures, which is open til June 30.   See that and more below after the break.

From CMS Email:

CMS is Accepting Future Measures and Activities for 
Three MIPS Performance Categories until June 30

The Centers for Medicare & Medicaid Services’ (CMS) Annual Call for Measures and Activities for the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program (QPP) is open until June 30, 2017.

CMS encourages clinicians, measure stewards, organizations, and other stakeholders to identify and submit measures and activities to be considered for the Quality, Advancing Care Information, and Improvement Activities performance categories of MIPS in future years.

Submission Details
  • Quality: Measures proposed for inclusion should be submitted through JIRA. Submissions should include the JIRA Measures under Consideration (MUC) template and other associated documents CMS deems necessary for the submission process.
  • Advancing Care Information: Measures proposed for inclusion should be sent using the Advancing Care Information Submission Form   Advancing Care Information Submission Form  to
  • Improvement Activities: Activities proposed for inclusion should be sent using the Improvement Activities Submission Form  Improvement Activities Submission Form  to
Measures and activities should be relevant, reliable, and valid at the individual clinician level. To be considered, proposals must include measure specifications, related research, and background.

A final list of measures and activities for MIPS clinicians will be published in the Federal Register no later than November 1 of the year prior to the first day of the performance period. Please note that some Advancing Care Information measures finalized in the 2018 final rule may not take effect until 2020, depending on the functionalities and workflow changes needed for implementation.

For More Information

Remember to review the Annual Call for Measures and Activities fact sheet    [17 pp]   to learn more and understand the process for submitting measures and activities for the MIPS performance categories. Please direct any questions on measure and activity submissions to the QPP Service Center at


Additional Notes (BQ)
  • For a MIPS MACRA homepage, here.
  • The "call-for-information" by CMS above would primarily involve pulling measures for new CMS use, from libraries of measures already endorsed through complicated and multi-year and multi-stakeholder pathways.
    • E.g. skim around the NQF website, here.  For a giant searchable library of available metrics, here.  For their recent March 2017 76-page report to Congress on El Mundo de Metrics, here.
    • Explaining how a quality topic becomes a quality measure is a lot more complicated than explaining how a bill becomes a law.  
    • Then explaining how an endorsed quality measure in a library of measures becomes an active CMS quality measure in a particular year is another complex process.
    • CMS has estimated that MACRA compliance will cost the health industry up to $1.3B, here.  It's downscaled the total participation that was originally forecast (here) by exempting more providers with small Medicare billings (here).
  • For many articles and blogs about problems caused by MIPS/MACRA, just google the three words MIPS MACRA PROBLEMS, then click NEWS, or click here.   Typical title - "Is the [Metrics] Cure Worse than the Disease?"
  • Similarly, even the federal watchdog panel MEDPAC had just about nothing good to say about MIPS in June 2017 - here.