Proposed Changes to the 2017 and 2018 MIPS Program

 In Articles, MACRA, Medicare Quality Programs, MIPS, Provider Notes

2017 is the first reporting year for the new Merit-Based Incentive Payment System (MIPS), which replaces three Medicare Quality programs – Meaningful Use, PQRS and Value-Based Modifiers. CMS is seeking feedback on a new set of proposed rules; some of which could have an impact on this year’s reporting.

Here’s our summary of the key changes being proposed and details on how you can submit comments by the August 21 deadline.

Proposed Changes for the 2017 Reporting Year:

  • Within the Advancing Care Information Category (ACI – similar to Meaningful Use), CMS plans to reinstate the exclusions to two measures in the Base Score. If you prescribe fewer than 100 medications, you will not need to meet the E-prescribing measure; if you refer or transfer out fewer than 100 patients in the 90 day reporting period, you will not need to meet the Health Information Exchange measure.
  • If you provide more than 75% of your covered Medicare services in Ambulatory Surgery Centers (POS 24), you will be treated like a Hospital-Based provider. You can elect to skip the ACI category, and your Quality category score will count as 85% of your final MIPS score (instead of 60% from Quality and 25% from ACI).
  • If you are planning to apply for a hardship exemption for the ACI category, that application will be due December 31, 2017, instead of July 2018. If your application is denied, you’ll still have time to submit data for the 2017 reporting period before the March 31, 2018, deadline.

Proposed Changes to Previous Rules Impacting 2018 Reporting Year:

  • The requirement to use a 2015-certified EHR and some of the original Stage 3 Meaningful Use measures has been delayed until the 2019 reporting year. Mid-level providers can continue to elect an exclusion from the ACI category.
  • CMS proposes to keep the weights assigned to each of the four categories the same as 2017: 60% Quality, 25% ACI, and 15% Improvement Activities with the Resource Use or Cost category staying at 0%. However, this change means there will be a big jump to 30% weight for the Cost category in 2019 (as required by statute).
  • In the Quality category, clinicians will need to report each measure for 50% of eligible patients instead of the scheduled increase to 60%. CMS states that they will raise this data validation threshold to 60% in 2019 and a higher level in future years.
  • Note that the Quality category will be based on 12 months of data in 2018 as was expected, while the ACI and Improvement Activity categories stay at 90 days.

Other Proposed Changes to MIPS for 2018 Reporting Year:

  • CMS proposes to increase the Low Volume Exclusion threshold from < $30,000 or < 100 patients to < $90,000 or < 200 patients during a 12-month period. CMS estimates that almost 50% of clinicians otherwise eligible for MIPS will be excluded if the proposal is finalized.
  • In 2017, the threshold for the MIPS Final Score was set at 3 points out of 100. Providers earning higher than 3 points will receive a small payment increase in 2019, while those that don’t earn 3 points will receive the 4% reduction. For 2018, CMS proposes to set the threshold at 15 points; however, they request comments on whether they should instead select either 6 or 33 points for the threshold. Starting in 2019, the threshold will be either the median or mean MIPS score from a prior year.
  • CMS proposes several new ways to earn bonus points:
    • Providers who work in practices with less than 16 providers will automatically get 5 additional points added to their MIPS score.
    • Providers who have a complex Medicare patient population (HCC risk score > 1.0) will receive between 1 and 3 bonus points added to their MIPS score.
    • Providers who use a 2015 Certified EHR will receive 10 bonus points in the ACI category.
    • Providers who improve their Quality category score can earn additional “improvement” points in the Quality category.
  • Currently, all data for a category must be submitted through a single submission method – For example, all six quality measures would be submitted through a Registry or the EHR. CMS proposes to allow submission to be split between different methods (3 measures submitted through a Registry and 3 through the EHR, for example).
  • CMS proposes a process for reducing the value and eventually eliminating quality measures that are “topped out” (have national averages > 95%). 49% of all quality measures were listed as “topped out” in 2017. Six of these measures will be able to earn only a maximum of 6 points instead of 10 points in 2018 (Measures 21, 23, 52, 224, 262, 359) and will likely be removed in 2019. Other measures that are “topped out” for a second year in 2018 will be worth only 6 points for two years and will then be removed.
  • Group practices with fewer than 10 providers can come together to form a Virtual Group. Their MIPS scores will be calculated based on the scores earned by all clinicians in the Virtual Group. This will be most useful for IPAs or Clinically Integrated Networks that are not yet ready to take the leap to a risk-bearing ACO structure.
  • Providers who see more than 75% of their covered Medicare services in hospitals (POS 21 or 23) will have the option to use the Hospital’s Value-Based Program score as their Final MIPS Score, rather than reporting MIPS data as an individual clinician or as a group practice.
  • As is the case each year, CMS proposes several additions to the Quality Measures and about 15 new Improvement Activities. Other Quality Measures have significant revisions proposed.

For more details and instructions on how to submit comments to CMS, see the Proposed Rule Fact Sheet.

MSOC Health provides consulting services to help you understand the new Medicare payment methodology and implement processes and systems to ensure your success in 2017 and beyond. Contact Jeanne Chamberlin at j.chamberlin@msochealth.com or 919-245-4274.

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