MIPS Participation: Finishing 2017 and Getting Started in 2018

The first performance year of the Medicare Quality Payment Program is now behind us. In the early days of the second performance year, here are a few reminders for eligible providers, especially those who chose the Merit-Based Incentive Payment System (MIPS) option, as they wrap up 2017 reporting and prepare for ongoing participation in 2018.

Wrapping up 2017

As you wrap up MIPS for 2017, keep the following in mind:

1. Eligible providers have until March 31, 2018, to submit 2017 MIPS data (except for CMS Web Interface users who will have a different time frame to report quality data from January 22, 2018, to March 16, 2018.)
2. The Centers for Medicare and Medicaid Services (CMS) recently announced a new data submission system on qpp.cms.gov that features real-time initial scoring and start and stop reporting (allowing you to come and go as you work on your submission until you submit the final data).
3. Providers who participated in the Advancing Care Information category must attest to the “Prevention of Information Blocking.” CMS offered clarification of this requirement back in October.

Getting Started in 2018

For 2018, several changes were made to the MIPS program. The following highlights some of the key provisions to keep in mind as you plan for participating in MIPS in 2018:

1. New eligibility guidelines may mean that providers who participated in 2017 are not required (or able) to participate in 2018. Individual MIPS eligible clinicians or groups with $90,000 or less in Part B allowed charges or 200 or fewer Part B beneficiaries are excluded from the program. For year one, the threshold was $30,000 in Part B allowed charges or 100 Part B beneficiaries. Providers can check their eligibility status both as individuals and groups using CMS’s MIPS Participation Status calculator. (NOTE: As of January 15, 2018, the MIPS calculator had not been updated to 2018 eligibility specifications.)
2. The MIPS Participation Status calculator will also alert providers to any special status that may affect their participation. For instance, several changes also were made to the 2018 MIPS performance year for small practices. Also, keep in mind the exceptions for hospital-based and non-patient-facing providers, especially as it relates to the Advancing Care Information category. You can learn more about those provisions in our blog post “2018 Quality Payment Program Changes.”
3. Payment adjustments for 2018/2020 will be +/- 5 percent up from +/- 4 percent in 2017/2019. The various performance categories will be weighted as follows for 2018/2020: Cost — 10 percent; Quality — 50 percent; Improvement Activities — 15 percent; and Advancing Care Information (ACI) — 25 percent.
4. For the 2018 performance year, MIPS participants must earn 15 points to avoid a 5 percent negative payment adjustment. During the 2017 transitional year, MIPS participants could avoid the 4 percent negative payment adjustment by earning just 3 points.
5. The performance period for the Advancing Care Information, Improvement Activities, and Cost performance categories will remain 90 days in 2018, but providers must participate for 12 months in the Quality category.
6. Quality measures that don’t meet the data completeness criteria (60 percent in 2018) will earn only 1 point in 2018. In 2017, Quality measures that didn’t meet data completeness criteria (50 percent in 2017) earned 3 points.
7. For providers planning to submit data via an outside registry, lists of approved qualified registries and qualified clinical data registries have been published by CMS for 2018. You can find those at the bottom of the 2018 Resources page.

For more information about MIPS in 2018, review the following:

• CMS Fact Sheet “Quality Payment Program Year 2”
• Quality Payment Program website
• Quality Payment Program resource library

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