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Medicare, MIPS, Payment Cuts, Quality Measures and a Bipartisan Bill to Fix the Mess

by | Jun 23, 2026 | Healthcare Payment Policy, Medicare Audits, US Wound Registry | 0 comments

Medicare, MIPS, Payment Cuts, Quality Measures and a Bipartisan Bill to Fix the Mess

Medicare payment rates have fallen about 33% since 2001 as inflation continues to rise. Physician payment is the only aspect of US healthcare payment policy that is not tied to inflation. Physicians are closing their doors because they can’t afford to stay in practice,` or making the difficult decision to work for large corporations which may not fully align with their practice values – just to ensure that they can pay the mortgage and payback their huge student loans. (While I don’t have any data to prove it, many practitioners currently caught up in expensive “skin sub” audits have told me that they needed the profits from CTPs to help keep their practice solvent in the face of the ~3% across the board sequestration cuts and rising inflation.)

A major problem for practitioners is the Merit Based Incentive Payment System (MIPS), which is part of Medicare’s Quality Payment Program (QPP). I have written a lot of articles about MIPS and the QPP in relation to the practice of wound care. Here’s an overview of the entire program through the lens of wound care. It’s true that an entirely “fee for service” model inside Medicare is a recipe for overuse and improper use, so CMS’ desire to link treatment to outcome is understandable and necessary. It’s just that MIPS hasn’t done that – particularly for wound care. MIPS could work, if US Wound Registry wound care relevant quality measures were available in every electronic health record (EHR), but wound care practitioners are sick of fighting their EHR vendors to incorporate them like Intellicure has. 

The AMA’s bipartisan bill, the Medicare Physician Data-driven Performance Payment System Act of 2026, H.R. 8622, would provide relief to MIPS-participating physicians. The bill that Reps. Mariannette Miller-Meeks, MD (R-Iowa), and Herb Conaway, MD (D-N.J.), introduced would:

  • Freeze the current MIPS performance threshold at 75 out of 100 for three years.
  • Mandate a Government Accountability Office study in consultation with national medical specialty societies to recommend an alternative threshold methodology to Congress and the Department of Health and Human Services (HHS). 
  • Eliminate MIPS’ win-lose tournament style payment adjustments so that physicians won’t face steep penalties. Instead, the measure would link physicians’ MIPS performance to a portion of their annual payment update.
  • Mandate that the Centers for Medicare & Medicaid Services (CMS) provide at least 75% worth of MIPS feedback reports and Medicare claims data to physicians during a given performance year.

Data show that under MIPS, many solo, small and rural practices are being cut at the highest levels to pay the 9% bonuses that MIPS offers. And studies have found that MIPS compliance costs physicians $12,800 per physician annually and requires more than 53 hours on quality assurance tasks each year. The USWR has tried to help wound care practitioners succeed with MIPS without such a high price tag, but that is only possible if the necessary quality measures are baked into the EHR so that there’s no need for laborious secondary data entry. We did that at Intellicure, and I am excited to report that more EHRs are now interested in making USWR quality measures available to wound care practitioners and podiatrists.  I will keep you posted on how that is going.

 Caroline

Additional Resources:

The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.

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