Medicare's Quality Payment
Program (QPP)



The 2015 Medicare Access and CHIP Reauthorization Act (MACRA) repealed the broken Medicare sustainable growth rate (SGR) formula and established new payment pathways for physicians. To implement MACRA's reimbursement reforms, the Centers for Medicare & Medicaid Services (CMS) developed the Quality Payment Program which includes:

  • the Merit-Based Incentive Payment System (MIPS), as a modifier for fee-for-service payments beginning in 2019.
  • Alternative Payment Models (APMs).

Ensuring Pathologists Participation in QPP

The CAP has engaged with Medicare officials to mitigate the negative effects of new and evolving reporting requirements for pathologists and laboratories. Through a strategy developed by the Council on Government and Professional Affairs and Economic Affairs Committee, the CAP advocates to ensure pathologists can participate in the Quality Payment Program. The CAP also provides resources and updates on Medicare payment reform to its members as the CMS begins implementation of payment reforms in 2017.

View the MACRA Infographic »

View and Complete the MACRA Readiness Checklist »

Understand Your MIPS Reporting Options »

List of 2017 Improvement Activities for Pathologists

MIPS Calculator

Use our MIPS calculator to help estimate future Medicare payment adjustments based on your practice data and project how MIPS will impact your practice's finances. Note this tool is for informational and estimation purposes only.

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2017 Transition

As most physicians will qualify for the MIPS program, the inaugural 2017 program year will be a transition period with four tracks. Eligible clinicians will be required to submit data by March 31, 2018, for payment adjustments for 2019.

2017 MIPS Reporting Options

Do Not Report

  • Those who do not report 2017 data will experience negative payment adjustments (-4%) in 2019

Test the MIPS Program

  • Report minimal data at any point in CY 2017 to demonstrate capability
  • One pathology quality measure for one patient, or one improvement activity
  • No minimum reporting period
  • No negative adjustment in 2019

Partial MIPS Reporting

Full MIPS Reporting

  • Meet all reporting requirements, including those for quality measures, for at least 90 consecutive days
  • No negative adjustment in 2019
  • Maximum opportunity for positive 2019 adjustment (≤4%)
  • Exceptional performers eligible for additional positive adjustment (up to 10%)

Most pathologists who participate in Medicare will be included in the MIPS program, including those who work in independent laboratories. Pathologists can avoid the 2019 penalty by reporting on PQRS measures by any mechanism, including claims as they have done in previous years. For those who have not participated in the past, including those working in independent laboratories, this transition year allows you to test reporting mechanisms and avoid the penalty.

The CAP will update members on how to attest to Clinical Practice Improvement Activities (CPIA) when CMS makes the information available. CMS has indicated that they are developing a web-based mechanism for CPIA attestation.


Check your practice's readiness for MACRA