In addition, the level of financial risk for certain specialties will continue to rise as implementation of the MIPS program progresses over the next few years. For example, payment adjustments for rheumatologists and oncologists could increase or decrease by as much as 29% in performance year 2020.1

Before MIPS went into effect, CMS programs including the Physician Quality Reporting System, Physician Value-Based Payment Modifier, and the Medicare Electronic Health Record Incentive only pertained to physician fee schedule services and did not include the cost of Part B drugs.4 With the inclusion of these costs, the new rule represents a significant change in their approach.

Continue Reading

Medical Bag spoke with Avalere’s director, John Feore, for further details on the rule.

Medical Bag: What are the reasons for the changes described under the new rule? 

Feore: CMS states in the rule that its proposal is actually a clarification of existing policy. CMS points to the MACRA statute as requiring the MIPS payment adjustment to be applied to Part B drugs.

Medical Bag: Which specialties are expected to be affected most significantly? 

Feore: Our analysis shows that rheumatologists and oncologists face the greatest potential impact under this provision. Any specialty that prescribes a high dollar amount of Part B drugs as a percentage of their total Medicare allowed charges may be affected.

Medical Bag: What can physicians do to prepare for these potential changes? 

Feore: Physicians should be preparing to fully participate in MIPS, gain an understanding of their reporting options, and closely examine how they can best perform under the program. In 2019, the third year of the program, many of the flexibilities that have enabled CMS to “ramp up” to full implementation will go away and the program will have to be fully implemented.

Medical Bag: Is there anything else that clinicians should know about the topic?

Feore: The impact for specialists can be both negative and positive. Those specialists who thrive under the program and perform at the highest levels may receive large bonus payments. This is the design of MIPS, which is a budget-neutral program — outside of the separate $500 million exceptional performance bonus pool.

Related Articles



  1. Feore J, Kane R. CMS proposal for new Medicare payment system could lead to large payment variability for specialists [press release]. Washington, DC: Avalere Health. Published October 5, 2017. Accessed November 11, 2017.
  2. MACRA basics: Advanced Alternative Payment Models (AAPMs). American Academy of Family Physicians. Accessed November 11, 2017.
  3. What’s the Quality Payment Program? Quality Payment Program. Accessed November 11, 2017.
  4. Medicare Part B drugs and the Merit-based Incentive Payment System (MIPS) payment adjustment. Centers for Medicare & Medicaid Services. Accessed November 11, 2017.