January 1 will not be as hard as you may think. In spite of all the pages of regulations, MIPS is not all that different, really. At least based on the Proposed Rule. Of course the new Final Rule with its thousands of pages may paint a different picture, by the time we absorb it all. But in general CMS does not originate new content in a Final Rule, that was not present in a Proposed Rule.
Underneath all the MIPS language, we remain with Meaningful Use and PQRS, which we have been doing for years. Add in Clinical Practice Improvement Activities, a dramatically simple compliance process, and January 1 does not seem all that daunting.
In fact, the "Meaningful Use" component gets easier, at least for the sophisticated players already in Stage 2 and eyeballing Stage 3. The new rules require a smaller set of compliance metrics than what we were all planning for. The "PQRS" component gets reduced as well, from 9 measures to 6 (for providers outside an ACO).
The biggest change from Meaningful Use and PQRS to MIPS falls in how the overall score is calculated, and how overall reimbursement is determined. Doing those two things may actually require that providers build (or buy) new software that operationalizes the thousands of pages of rules.
So as you read the new Final Rule that goes into effect in January, prepare for a series of long sessions. But Don't Panic! And if you need some of that MIPS rule-taming software, check out our MIPS Monitor. It will make you a hero, and save many weeks' worth of your personal effort.