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While most of the rule focuses on payer requirements, it also requires that Merit-Based Incentive PaymentSystem (MIPS) “Promoting Interoperability Program” eligible providers report on their use of Prior Authorization APIs in a new “Electronic Prior Authorization” measure. commercial plans, worker’s compensation, etc.)
Merit-based Incentive PaymentSystem (“MIPS”) eligible clinicians, operating under the Promoting Interoperability performance category of MIPS, and eligible hospitals and critical access hospitals (“CAHs”), operating under the Medicare Promoting Interoperability Program, are impacted by the Final Rule, as well.
The regulations impact CMS-regulated payers and provide incentives for providers and hospitals that participate in the Medicare Promoting Interoperability Program and the Merit-based Incentive PaymentSystem (MIPS). Most of the Proposed Rule’s provisions will be effective on January 1, 2026.
The Centers for Medicare & Medicaid Services (“CMS”) will publish the 2025 Inpatient Prospective PaymentSystem (“IPPS”) Final Rule (“Final Rule”) in the Federal Register on August 28 with an effective date of October 1, 2024. CMS estimates this extension will result in $137 million in additional payments to IPPS hospitals.
Beginning in 2026, QPs will receive a higher annual Medicare fee schedule adjustment than non-QPs. In addition, eligible clinicians who participate in certain APMs but don’t meet the QP requirements may still receive more favorable scoring under MIPS.
The Final Rule also imposes additional reporting requirements under the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals and for eligible clinicians reporting under the Promoting Interoperability performance category of the Merit-Based Incentive PaymentSystem.
On November 1, 2023, the Centers for Medicare & Medicaid Services (“CMS”) posted a pre-publication copy of the Calendar Year (“CY”) 2024 Home Health Prospective PaymentSystem Rate Update Final Rule (“2024 Final Rule”), which has since been filed in the Federal Register. Hospices need to be much more vigilant about compliance.
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