Hopefully by now you’ve heard about the Centers for Medicare and Medicaid Services’ (CMS) new Quality Payment Program (QPP), and specifically MIPS, the Merit-based Incentive Payment System, which is one of two QPP options providers must participate in to avoid a 4 percent negative payment adjustment in 2019.
The MIPS program combines several former CMS programs, including PQRS, EHR Incentive Program, and Value-Based Payment Modifier, and for its first year, CMS is offering providers three “Pick Your Pace” options to help ramp up to the full program. Participating in any of the three options means avoiding the 4 percent negative payment adjustment in 2017, and two of the options offer the possibility of a positive payment adjustment of up to 4 percent. A fourth option allows providers to participate in an Advanced ACO instead of MIPS. However, CMS anticipates only a small number of providers will be ready and eligible for the Advanced ACO option in 2017.
The three Pick Your Pace options are:
- 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.
Even if you choose to participate at a minimum level for 2017, take advantage of this one-year “grace period” to prepare for the more rigorous requirements of 2018 and beyond. Here are a few suggestions.
Confirm Your Eligibility
Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists are eligible to participate in MIPS if they bill more than $30,000 to Medicare and provide care to more than 100 Medicare patients per year. That means providers who bill $30,000 or less to Medicare or provide care to 100 or fewer Medicare patients per year are exempt.
Interestingly, this same low-volume threshold applies to individuals or groups. So members of the same practice who all operate under the same TIN can decide for themselves whether to remain ineligible as individuals (if they meet the low-threshold criteria) or participate as a group if they meet the eligibility criteria in aggregate.
Complete Minimum Requirements
Be sure you actually complete the minimum requirements to avoid the automatic 4 percent negative payment adjustment. Submitting one quality measure for one patient encounter is enough to meet minimum requirements based on the Quality Category. Do only that, and you will have avoided the penalty. If you report no quality measures, however, you can still meet minimum requirements in either the Improvement Activities Category (by completing and attesting to one medium-weight improvement activity) or the Advancing Care Information Category (by completing and attesting to all of the base measures in one of the technology options). The Cost Category is not being scored for 2017 but will be part of MIPS for 2018.
Do More If You Can
Because of the way the MIPS program is scored, even a moderate level of participation in 2017 could earn you a positive payment adjustment. So completing the minimum requirements in all three categories, or completing the full requirements of one or more of the categories for even just 90 days could result in additional reimbursement from Medicare in 2019. Of course participating in all three categories for a full year provides the best chance to earn a bonus.
Evaluate Your Technology
The entire MACRA Quality Payment Program is designed to move providers away from fee-for-service and toward pay-for-performance models, which inherently rely on technology and data to measure quality and value. According to John Morrissey in his Health Data Management article called, “IT crucial as physician groups begin the trek toward MACRA,” providers who have kept up with and invested in the necessary technology to participate in Medicare’s PQRS and EHR Incentive Programs will “have an advantage in meeting MACRA head on. For groups lagging in using a certified electronic health record, developing analytics to guide them and pushing critical data out to their practitioners, experts say it’s time to catch up.”
For instance, while MIPS participants can still use the 2014 version of certified technology to meet the Advancing Care Information Category requirements for 2017, in 2018, everyone will need to upgrade to 2015 CEHRT.
Also, even just reporting quality measures may require the use of a certified registry or qualified clinical data registry. Providers should use 2017 to evaluate and prepare for entering and extracting quality data into a practice management system or other data warehouse so they can take advantage of the reporting options that make the most sense for their practice.
According to Morrissey, Rob Tennant, health information technology policy director for the Medical Group Management Association, suggests practices should use 2017 to look beyond just “technology for the sake of reporting MIPS” and really try to invest in ways that add value to their practice by asking, “How can [we] leverage the technology to improve the clinical performance of the practice?”
Don’t waste this Pick Your Pace year. Instead, use it get your practice ready for the industry’s steady move toward value-based payment models.
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