Table 2

The differences between SGR and Medicare Provider Payment Modernization Act of 2015

Annual Medicare Update for Physician Services
  • 21.2% SGR cut takes effect April 1, 2015.

  • Future SGR cuts could exceed 25%

Annual update of: (0% January through June 2015) (0.5% July 2015 through 2019) (0% in 2020 through 2025) (2026 and beyond: 1% for APM participants; 0.5% for all others)
Pay for Performance/Quality Reporting ProgramsPQRS+MU+VBM
Maximum total penalties
  • 2015: 4.5%

  • 2016: 6%

  • 2017: 9%

  • 2018: 10% or more

  • 2019: 11% or more

  • 2020: 11% or more

MIPS maximum penalties and bonuses
  • 2015–2018: PQRS, MU, VBM continue.

  • 2019: 4% (extra bonus possible)

  • 2020: 5% (extra bonus possible)

  • 2021: 7% (extra bonus possible)

  • 2022 and after: 9% (extra bonus 2022–2024)

All physicians could earn a bonus if they meet
MIPS quality standards.
Extra bonus 2019–2024: up to 10% for exceptional performance (up to $500 million/year). MIPS has more accurate assessment, scoring, flexibility, predictability than under PQRS, MU, or VBM. MIPS abandons current VBM ‘tournament’ model (requiring penalties to equal bonuses)
EHR MUNo clear timeline or enforcement tools to achieve interoperabilityMU measures count 25% in MIPS. Interoperability is a goal by 2018; Secretary may adjust penalties and/or decertify EHRs if this is not achieved
APMsNo guaranteed payment update or bonus for physician participation in medical homes, ACOs, or other existing APMs. Limited support for physicians to develop new payment models5% Bonus payment for 2019–2024 for successful participation in eligible models. APMs must bear more than nominal risk, or be a qualifying medical home. Physicians can propose new APMs. $20 Million/year (2016–2020) in technical assistance for small practices to develop new models or participate in MIPS
Quality Measure Development FundingNone$15 million/year (2015–2019) for measure development; $75 million total. Excess available through FY 2022
Physician data accessData provided by CMS through physician feedback program. No requirements on timelinessRequires CMS to provide timely (such as quarterly) feedback reports at individual physician level
Physician claims dataPhysician 2012 claims data released by CMS. QEs authorized to do public reports using the dataEstablishes an annual release of physician data with no explicit safeguards. Expands QE authority to provide non-public reports and data with explicit protections. Provides data to QCDRs
Standard of Care Protection ActNo protectionsIncluded. Quality program standards do not set standard of care in medical liability actions
Opting out of MedicareRenew status every 2 years or face serious consequencesStatus continues indefinitely; no need to renew every 2 years
CCM servicesMedicare started paying for CCM services in 2015, but could end those payments in the futurePermanently requires Medicare to pay for care management of patients with chronic health problems, without requiring an annual wellness visit or initial preventive physical examination
  • Reprinted with permission Manchikanti et al.1

  • ACOs, accountable care organizations; APM, alternative payment model; CCM, chronic care management; CHIP, Children's Health Insurance Program; CMS, Center for Medicare and Medicaid Services; EHR, electronic health record; MACRA, Medicare Access and CHIP Reauthorization Act; MIPS, Merit-based Incentive Payment System; MU, Meaningful Use; PQRS, Physician Quality Reporting System; QCDRs, Qualified Clinical Data Registries; QE, qualified entities; SGR, sustainable growth rate; VBM, value-based model.