12 Little-Known Facts About MIPS

 In Articles, Medicare Quality Programs, MIPS

Most practices that don’t successfully report 2017 data for Medicare’s new Merit-Based Incentive Payment System (MIPS) will face a 4% reduction in Medicare payments in 2019. On the other hand, you could potentially receive an increase in your payment rate by optimizing your MIPS score. CMS offers extensive education about the program at www.qpp.cms.gov.

We’ll go beyond the basics to answer some FAQs and share some of the little-known facts that might surprise you.

Q: What’s the minimum I have to do to avoid the 4% reduction?

A: You need a MIPS score of 3 (out of 100 points). To get 3 points, you can do any of the following:

  • Report 1 quality measure to CMS on 1 Medicare patient
  • Attest to 1 improvement activity performed consistently during any 90 days in 2017
  • Attest to the 4 measures that make up the Base Score of the Advancing Care Information (ACI) category – these are from the Modified Stage 2 Meaningful Use measures and you must meet the threshold of 1 patient or answer Yes for each measure during any 90 days

Q: Why would I worry about doing anything more than the minimum?

A: There are three important reasons. First, MIPS will get more difficult in future years with a 12-month reporting period and a likely threshold of 50-60 instead of 3 – this is the year to get your processes in place.

Secondly, a score of 70 or higher will give you a significantly higher increase in 2019 payments because you will share in a $500 million additional incentive fund.

Finally, the MIPS score will be published at www.medicare.gov/physiciancompare and will be marketed by Medicare, AARP, Consumer Reports and your competitors as the gold standard in evaluating the value of different physicians and practices.

Q: If I don’t have an Electronic Health Records system, does MIPS apply to me?

A: Yes, however without a 2014 Certified EHR, you will be unable to earn any points in the Advancing Care Information (ACI) category so your maximum possible score will be 75 instead of 100 points. You can still earn points in the Quality and Improvement Activities Categories.

Please note that if you have never participated in the Meaningful Use program, there is a special one-time exception to the 2016 Meaningful Use program that can eliminate the scheduled 3% reduction in 2018 payments.

Q: Do I get a higher score if I report data for 12 months instead of just 90 days?

A: Not necessarily. You can report for any period of time between 90 days and 12 months; your score is based on the data you report. Choose the reporting period that maximizes your score.

Q: Do I have to use the same 90-day reporting period for each category?

A: No. You can select a different reporting period for each of the 3 categories: Quality, Advancing Care Information (ACI-similar to MU) and Improvement Activities.

Q: What should I consider in choosing whether to report as a Group or as Individual Clinicians?

A: Most importantly, unless you plan to use the GPRO website to report quality measures, you’ll make the decision at the time you report – in early 2018. Here are factors to consider:

  • Which approach provides the highest MIPS score and the greatest revenue impact? When reporting as a Group, each provider in the group will have the same score and the same payment adjustment. When reporting as Individual Clinicians, each provider will have a different score and be paid at a different payment rate in 2019.
  • Are some providers excluded due to Low Volume? If so, they are not required to report as Individual Clinicians but would be included as a member of the Group.
  • In a multi-specialty group, do some providers have 6 great quality measures to report on while another specialty struggles to find 6 measures that make sense for them? In this situation, Group reporting may be beneficial as you can select measures that apply only to one specialty within your practice.

Q: What happens if I move to a new practice by the payment year (2019)?

A: Your MIPS score will move with you. If your practice reports as a Group in 2017, each clinician in the group receives the same MIPS score. In your new practice, your 2019 payment rate will be based on the MIPS score you earned in 2017 regardless of which practice you were in.

If you had 2 MIPS scores in 2017 because you worked in 2 different practices that year, your 2019 payment under a new TIN will be based on the higher of the two scores.

Q: I only see patients in the hospital, am I excluded from MIPS?

A: Probably not. There are only three exclusions from MIPS:

  • Low Volume Exclusion: Less than $30,000 in Medicare Allowables OR less than 100 Medicare patients during a 12 month period.
  • New Medicare Provider Exclusion: 2017 is the first year that the provider billed to Medicare under their NPI number.
  • Advanced Alternative Payment Model: Provider is deemed a participating provider in a Medicare Advanced APM (see next question).

However, Hospital-based providers are excluded from the ACI (MU) category. The 25% weight typically assigned to this category is reassigned to the Quality Category making Quality worth 85% of the Final MIPS Score and Improvement Activities worth 15%. Note that the definition of Hospital-based has changed to more than 75% of encounters in POS 21, 22, or 23 (Inpatient, Hospital Outpatient, ED).

Q: I am participating in a Medicare ACO. Do I have to report MIPS?

A: It depends on the specific Medicare Alternative Payment Model (APM) you are participating with. Some programs have been deemed “Advanced APMs” and others are deemed “MIPS APMs.” You’ll want to carefully review the information on www.qpp.cms.gov in order to determine which you are participating with and the specific rules that apply to you.

Q: What should I consider in selecting the Quality Measures to report?

A: Probably one of the most difficult issues in implementing MIPS. Be sure to consider the following:

  • How will you collect the necessary data and report it to CMS? There are over 250 measures and 5 reporting options – claims, certified EHR, registry, qualified clinical data registry (QCDR), and GPRO Website. Some measures are only available for some reporting options.
  • There are different benchmarks for different reporting options. Be sure you are using the correct benchmarks to determine your score. The same measure may have lower benchmarks if you report it via registry as compared to EHR or vice-versa.
  • Measures with less than 20 eligible cases, or those with no benchmarks will receive a score of 3.
  • Some measures are listed as ‘Topped Out’ meaning that the national average is > 95%. It is ok to report these for 2017 however they may not be available in 2018 and beyond.

Q: I am switching to a new EMR in 2017. Under the Meaningful Use program, I would have received a Hardship Exemption for 2019. Does the same exemption apply under MIPS?

A: You are not exempted from MIPS altogether, but you may apply for a Hardship Exemption for the Advancing Care Information (ACI) Category. Applications will be available in early 2018 and if approved, your Quality Category would be reweighted to be 85% of your Final MIPS Score with 15% assigned to the Improvement Activities Category.

Q: How are the Improvement Activities reported to CMS and what type of documentation is required?

A: Improvement Activities can be reported to CMS via an attestation website that will be available in early 2018. You will simply attest that you performed the activity consistently during the 90-day reporting period you have chosen. If you are reporting as a Group, only one provider in the group must perform the activity. CMS has declined to provide further guidance about the requirements of each activity. You will need to retain appropriate documentation to justify and support your attestation in the event of an audit.

MSOC Health can help you succeed with MIPS!

We offer a comprehensive MIPS Consulting Package that includes education, development of a MIPS Plan, monitoring results, and data submission in early 2018. MSOC billing clients receive a 25% discount. Contact your Client Analyst or Jeanne Chamberlin at 919-442-2422 or j.chamberlin@msochealth.com.

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