• MIPS Manual 2017—Quality: How to Avoid the Payment Penalty

    Written By: Rebecca Hancock, Flora Lum, MD, Chris McDonagh, Cherie McNett, Jessica Peterson, MD, MPH, and Sue Vicchrilli, COT, OCS

    This content was excerpted from EyeNet’s MIPS Manual 2017.


    The new regulations present you with a significant learning curve, and the –4% payment penalty poses a serious financial risk. To reduce that risk during the program’s inaugural year, CMS included several provisions that will help you to avoid the penalty. Most importantly, CMS set a performance threshold of just 3 points for avoiding the 2019 payment penalty.

    For the 2017 performance year, you can score 3 points by reporting just 1 quality measure 1 time on 1 patient. This is because, during MIPS’ first performance year, CMS has assigned a floor of 3 points to each quality measure, and you can earn those points even if you don’t meet quality reporting’s case minimum requirements and data completeness criteria (though you must meet those 2 reporting thresholds if you want to earn more than 3 points for a quality measure).

    Warning—given what is at stake, you would be ill-advised to report 1 quality measure just once. Although it is possible to avoid the penalty with very limited reporting—an opportunity that CMS refers to as the “test pace” of MIPS participation—you should increase your chances of penalty avoidance by doing much more than that. And if you are reporting quality by claims, keep in mind that if your claim is denied, the MIPS reporting for that claim will also fail. Report more than 1 quality measure for more than just 1 day. For added reassurance, you should also try to score points in more than 1 performance category.

    Use 2017 to get up to speed for future performance years. By 2018, the reporting requirements will start to become more challenging, and the learning curve much steeper. CMS has said that it will increase the performance threshold in each of the next 2 performance years. Under the proposed rule for 2018, the performance threshold would be 15 points next year. By the 2019 performance year, CMS plans to set the performance threshold high enough that half of MIPS participants will fall below it (and get a negative payment adjustment in 2021) and half will be above it (and get a positive payment adjustment).

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    Next: Quality: MIPS Versus PQRS (Good News, Bad News)

    Note: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.

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