What Emergency Physicians Need to Know about Reporting MIPS in 2018

Even though we’re almost two months into 2018, it’s not too late for emergency physicians to participate in the 2018 Merit-Based Payment System (MIPS) to avoid a negative 5 percent adjustment on Medicare Part B payments in 2020.

MIPS is one prong of the MACRA Quality Payment Program which was first implemented in 2017. Physicians and other eligible providers or groups with more than $90,000 in Medicare Part B allowed charges or who submit claims for more than 200 Medicare Part B beneficiaries are required to participate in the program in 2018 or automatically receive a negative payment adjustment.

Submission Methods

While several data submission methods are available, many emergency physicians will struggle to find enough relevant measures, will not have access or the technology, or will otherwise not be able to use some submission methods, particularly CMS Web Interface and EHR options. As a result, most EM providers will participate via claims, qualified registry, or qualified clinical data registry (QCDR).

In the case of claims, only Quality data can be submitted, and only for physicians participating as individuals, not groups. Since EM physicians also are required to complete measures in the Improvement Activities performance category, each individual physician would need to complete and attest to those activities using another submission data method, such as the CMS Quality Payment Program website, a qualified clinical data registry, or a qualified registry.

By using a qualified registry or a QCDR, individual physicians or groups may be able to submit data in both required categories with one submission method, but those options also require providers to work with an approved outside vendor, often at a cost to the provider.

Benefits of Qualified Clinical Data Registries

CIPROMS works with clients to help with Quality data submission in both the claims and QCDR options. In addition to entering and submitting Quality data codes to Medicare through electronic claims, CIPROMS also works with emergency physicians to enter and format Quality data for submission to a registry or QCDR, such as the American College of Emergency Medicine’s (ACEP’s) QCDR known as the Clinical Emergency Data Registry, or CEDR.

In general, QCDRs provide several benefits for providers, including a wider variety of measures outside of the MIPS measure set to choose from. As well, QCDRs collect data from across the entire payer spectrum, not just Medicare, making the data more relevant and meaningful to practices. Emergency clinicians participating in CEDR also receive feedback regarding their individual- and/or ED-level performance on a range of process and outcome quality measures, benchmarked against their peers at national and regional levels.

The cost for using CEDR to report MIPS is calculated in one of two ways:

CEDR transaction fee based on visit volume = $0.25 per visit, or
Annual User fee = $100 per provider (ED Physician and Advanced Practice Provider).

The $100 Annual User Fees are waived for ACEP members and for groups, hospitals, etc. where 100 percent of eligible ED providers are members of ACEP. For groups that do not have 100 percent ACEP membership, only their ACEP members qualify for the waived fee, and all others would pay the $100 annual user fee.

Special Status

Based on authority from the 21st Century Cures Act, the Advancing Care Information performance category will be reweighted to 0 percent and the Quality performance category will be reweighted to 75 percent for providers in the following categories:

Eligible providers with significant hardship exceptions;
MIPS eligible clinicians in small practices (15 or fewer clinicians) who apply for a hardship exception;
MIPS eligible clinicians whose EHR was decertified and who apply for a hardship exception;
Hospital-based MIPS eligible clinicians; and
Ambulatory Surgical Center (ASC)-based MIPS eligible clinicians.

An eligible clinician is defined as hospital-based if they furnish 75 percent or more of their covered professional services in either the inpatient hospital (Place of Service 21), outpatient hospital (POS 22), off-campus-outpatient hospital (POS 19), or emergency department (POS 23) setting. As such, physicians who work primarily in the emergency department setting will not be required to submit data for the Advancing Care Information performance category.

Changes to MIPS for 2018

For 2018, the Centers for Medicare and Medicaid Services (CMS) made several changes to the MIPS program. The following list highlights some additional key provisions to keep in mind as you plan for participating in MIPS in 2018:

New eligibility guidelines may mean that providers who participated in 2017 are not required (or able) to participate in 2018. As mentioned above, 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 February 15, 2018, the MIPS calculator still had not been updated to reflect 2018 eligibility guidelines.)
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.
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.
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.
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.
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 participating in MIPS in 2018, review the Medicare Quality Payment Program website or visit ACEP’s CEDR website. For a list of changes to the MIPS program, check out the Quality Payment Program Year 2 Fact Sheet. To find out more about how CIPROMS helps clients with MIPS data submission or other aspects of our full-service medical billing, contact us today.