In a November 29 webcast by the Centers for Medicare and Medicaid Services (CMS) titled “Merit-based Incentive Payment System (MIPS) Overview,” MIPS Program Lead Molly MacHarris of CMS’ Center for Clinical Standards & Quality offered several steps for providers to help them prepare for the first MIPS performance year which starts January 1, 2017.
MIPS is one of two tracks in the new MACRA Quality Payment Program (QPP) that builds on and replaces several CMS quality programs, including the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the Medicare EHR Meaningful Use Program for Part B providers. MIPS includes four performance categories which are weighted differently, including Quality, Improvement Activities, Advancing Care Information, and Cost. For 2017, cost will be determined based on an administrative claims analysis but will be weighted at 0 percent. Data for the other three performance categories must be submitted by participants, and will be weighted as follows: Quality – 60 percent, Improvement Activities – 15 percent, and Advancing Care Information – 25 percent.
Unlike previous quality programs that were scored with an all or nothing approach, in MIPS each performance category offers an accumulating point system based on how much data is submitted and the results of the quality data as compared to benchmarks which are currently being determined by CMS. Mary Wheatley, Principal Healthcare Policy Analyst for The MITRE Corporation, led the second part of Tuesday’s MIPS webinar about how providers will be scored under MIPS. We’ll cover this in more detail in a future article.
In this article, however, we’ll walk through 6 steps for preparing to participate in MIPS.
1. Determine Your Eligibility Status
Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists are eligible to participate in the MIPS track of the Quality Payment Program if they bill more than $30,000 to Medicare and provide care to more than 100 Medicare patients per year. In 2017, eligible providers who do not participate are subject to a 4 percent negative payment adjustment. Providers who participate by submitting any amount of data in any performance category avoid the negative payment adjustment, and those who submit quality data for 90 days or the full year may be eligible for small or modest positive payment adjustments.
Providers who bill less than $30,000 to Medicare or see fewer than 100 Medicare do not meet the low-volume threshold for the MIPS program and are not eligible to participate. They also are excluded from the automatic 4 percent negative payment adjustment. Likewise, newly enrolled Medicare providers who enroll during the reporting period are exempt from the MIPS program, as well as providers who significantly participate in an Advanced Alternative Payment Model.
2. Gauge Your Readiness and Pick Your Pace
As part of the transition into the MACRA QPP, CMS has implemented a Pick Your Pace policy to encourage as many clinicians as possible to participate in the MIPS program. Basically there are three ways to participate in MIPS:
- Test your ability to participate by submitting any amount of data in any performance category. This could mean submitting data for one Quality measure, one Improvement Activity, or the base measures in the Advancing Care Information category.
- Submit partial data over a 90-day period in more than one performance category. The more data that is submitted, particularly in the quality category, the greater likelihood of a positive payment adjustment.
- Submit a full year of data in more than one performance category. Again, the more data that is submitted, particularly in the quality category, the greater likelihood of a positive payment adjustment.
Providers who have already participated in PQRS and Meaningful Use are likely prepared to submit data for at least the 90-day period. Keep in mind that a full-year of quality data will be required in year two of MIPS, so the more experience you can get in year one, the better.
3. Choose to Participate as an Individual or Group
Eligible providers can participate as individuals or as groups of two or more if they share a TIN. The low-volume threshold mentioned above will be applied based on whether a provider is participating as an individual or group. So if an individual provider wants to participate in MIPS but doesn’t see more than 100 Medicare patients or bill more than $30,000 to Medicare per year, that provider can participate as a group with other providers in the same TIN in order to meet the low-volume threshold.
Only groups choosing to participate in the Web-Interface data submission option must register as a group by June 30, 2017. Individuals and groups reporting through other data submission options do not need to register for MIPS.
4. Choose Your Data Submission Option
Data submission options vary slightly by performance category and by whether providers are reporting as individuals or groups.
Basically, all three of the 2017 performance categories can be reported through qualified registry, EHR, or qualified clinical data registry (QCDR). Additionally, for individuals, Quality Measures can be submitted through the claims option, and Advancing Care Information Measures and Improvement Activities can be submitted through attestation for individuals or groups.
Groups with more than 16 will automatically have their readmission rates calculated through administrative claims by CMS as part of the Quality performance category. And groups of 25 or more can submit all three performance categories through the CMS Web Interface option.
Remember, the QCDR, qualified registry, and EHR options require the use of an outside vendor and usually charge a fee for their use. Some professional societies waive the fee or offer reduced costs for members.
5. Choose Which Measures You Will Perform
Once you have decided how you will participate, you can begin to choose which measures you will perform based on those options. The CMS Quality Payment Program website has a tab called “Explore Measures” that allows you to sort and filter measures by Performance Category, specialty, and other factors.
While there are some exceptions, keep in mind that most providers will need to choose the following number of measures by performance category:
- QUALITY: Submit data on six measures, including one outcome measure. If an outcome measure is not applicable, providers must choose at least one high quality measure. If fewer than six measures apply, providers must report all measures that do apply, and they will be subject to a validation process to ensure additional measures were not available (similar to the measure applicability validation under PQRS). If more than six measures are reported, CMS will base the MIPS Quality score on the six highest performing measures. Groups of 16 or more will also have the readmission measure calculated for them by CMS. You can download a zipped folder of all measure specifications from the Education Tools tab of the CMS QPP website. Also, keep in mind that individual QCDRs will be publishing their own specialty-specific measures for MIPS reporting.
- ADVANCING CARE INFORMATION: Depending on the certification year of their EHR, providers must submit 4 or 5 base measures plus 7 or 9 performance measures, and can qualify for bonus credit by submitting additional measures. Hospital-based, non patient-facing, and certain mid-level providers who were not eligible for the EHR Meaningful Use program can opt in to the Advancing Care Information performance category with some modification. However, those same clinicians can choose not to participate in the Advancing Care Information and instead will have that performance category weighted to 0 percent and the Quality performance category will be reweighted to 85 percent.
- IMPROVEMENT ACTIVITIES: Choose up to 4 improvement activities that you can complete for a minimum of 90 days. This includes either 4 medium-weighted activities, or 2 high-weighted activities.
We will review scoring in more detail in a future article, but in general, providers earn points in each performance category and then those points are weighted in order to determine a score out of 100. The higher the score, the greater likelihood for a positive payment adjustment up to 4 percent. Remember, any level of participation in 2017 prevents providers from receiving a negative 4 percent payment adjustment.
6. Review the Program Timeline
The first year performance period for MIPS is 2017 and begins on January 1. In order to complete at least a 90-day partial reporting period, providers need to start performing measures by October 2. Data must be submitted to CMS through any of the available options by March 31, 2018.
If you choose to report the Quality performance category through the claims data submission option, however, you will need to begin submitting measures as soon as possible in 2017 in order to meet the “Data Completeness” criteria of submitting quality data codes on at least 50 percent of denominator-eligible encounters for the chosen measures.
Payment adjustments for the 2017 performance year will be applied in 2019.
To watch the entire MIPS Overview webinar yourself, visit the MIPS webinar page and follow the instructions to register for viewing. For more information, you also can review CMS’s Quality Payment Program Overview Fact Sheet or visit the CMS Quality Payment Program website.
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