Even though we’re almost two months into 2018, it’s not too late for anesthesiologists 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 or automatically receive a negative payment adjustment.
Submission Methods
While several data submission methods are available, most anesthesiologists will struggle to find enough relevant measures in some submission methods, particularly the claims, EHR, and CMS Web Interface options. As a result, most EM providers will participate via qualified registry or qualified clinical data registry (QCDR).
For providers who do attempt to use claims, only Quality data can be submitted. Since anesthesiologists also are required to complete measures in the Improvement Activities performance category, they would need to use another submission data method for attesting to those activities, such as the CMS Quality Payment Program website, a QCDR, 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 the claims, qualified registry, and QCDR options. Particularly, CIPROMS has worked with the Anesthesia Quality Institute’s National Anesthesia Clinical Outcomes Registry (NACOR), which offers both qualified registry and QCDR options.
QCDRs provide several benefits for providers, including a wider variety of measures to choose from, including measures outside of the MIPS measure set. QCDRs also include data from across the entire payer spectrum, not just Medicare, making the data more relevant and meaningful to practices. Anesthesiologists participating in NACOR also have access to NACOR dashboard reports, including interactive analytical reports, peer-to-peer benchmarking, performance gap analysis, and patient outlier identification.
The cost for using NACOR’s Standard Quality Reporting to report MIPS is determined based on membership in the American Society of Anesthesiologists (ASA) and the provider’s credentials:
- ASA Member: $0
- Non-ASA Member Pricing:
- Physician: $1,250
- Care Team Staff: $150
- Independent CRNA: $250
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, most anesthesiologists 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 March 1, 2018, the MIPS calculator still had not been updated to reflect 2018 eligibility specifications.)
- 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 (except in the case of reweighting for special statuses).
- 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 the ASA’s MIPS Reporting page. 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.
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