This content was excerpted from EyeNet’s MIPS Manual 2017.
On Jan. 1, 2017, Medicare launched the Quality Payment Program (QPP), which is its new system for adjusting Medicare payments based on clinician performance.
The Quality Payment Program provides 2 pathways: MIPS and advanced APMs. You can participate either in the Merit-Based Incentive Payment System (MIPS) or in an advanced alternative payment model (APM). MIPS includes a hybrid option—the MIPS APM—for clinicians who are in an accountable care organization (see “The Alternative to MIPS: APMs in Brief”).
This EyeNet supplement focuses on MIPS. Advanced APM options will initially be limited for ophthalmology, so most Academy members will be MIPS participants.
Many aspects of MIPS may seem familiar. If you have participated in CMS’ previous quality reporting programs—such as the Physician Quality Reporting System (PQRS)—then many aspects of MIPS reporting will seem familiar to you.
Some initial wiggle room. For MIPS’ inaugural year, CMS has eased the reporting requirements and made it easy to avoid the payment penalty. Use this transition year to (1) determine your best strategy for MIPS and (2) establish and fine-tune your MIPS procedures so you’ll be ready for 2018, when CMS is expected to start ramping up the reporting requirements.
Scoring, Bonuses, and Penalties
Your 2017 MIPS final score (0-100 points) will be based on 3 performance scores:
Improvement activities score contributes up to 15 points. This performance category is entirely new. You may also see this category referred to as clinical practice improvement activities (CPIAs), which was the term CMS used in an early draft of the MIPS regulations. For a quick summary, see “Improvement Activities Overview.”
Advancing care information (ACI) score contributes up to 25 points. The ACI performance category replaces the meaningful use (MU) program for electronic health records (EHRs). For a quick summary, see “Advancing Care Information (ACI) Overview.”
Quality score contributes up to 60 points. The quality performance category replaces the Physician Quality Reporting System (PQRS). For a quick summary, see “Quality Overview.”
In 2019, CMS plans to start factoring a fourth performance category—cost—into your MIPS final score (see Table 1). You don’t report any data for cost; CMS will determine your cost score based on Medicare claims data.
Your 2017 MIPS final score (0-100 points) will impact your 2019 payments. If your 2017 final score is:
- 0 points, your 2019 Medicare payments will suffer a payment penalty of 4%;
- 3 points, you’ll get no penalty and no bonus;
- more than 3 points but less than 70 points, you will get a small bonus; or
- 70-100 points, you will get a modest bonus.
During the inaugural year of MIPS, avoiding the penalty is easy. For the 2017 performance year, the 2 easiest ways to meet the 3-point threshold and avoid the payment penalty are:
- submit data on 1 quality measure 1 time on 1 patient, or
- report on 1 improvement activity.
Do more than the bare minimum. If you plan to avoid the penalty by reporting only 1 quality measure just 1 time or by reporting just 1 improvement activity, you will have no margin for error. The Academy urges you to report more than the bare minimum.
What if you don’t have an EHR system? If you don’t have an EHR system, your ACI score will be 0%. Unless one of the ACI exemptions applies (see “Some Physicians May Be Exempt From ACI”), your maximum final score will be 75 points.
Table 1: MIPS Final Score: 2017-2019
Your 2017 MIPS final score is based on how CMS rates you in 3 performance categories. In 2017 and 2018, quality contributes the lion’s share of points to your final score, but that is slated to change, as shown below.
||0 or 12.5-25 points
||0 or 12.5-25* points
||0 or 12.5-25 points
|+ Improvement activities
|= MIPS final score
|* Scoring for 2018 won’t be finalized until CMS publishes its final rule for 2018 (expected in October 2017).
For 2017, CMS has set the performance period at 90 consecutive days. If you plan to tackle more than 1 performance category (e.g., quality and improvement activities), it is OK for each category to have a different 90-day performance period.
In 2017, you can score quality points with a performance period shorter than 90 days. This year, CMS gives you 3 points toward your quality score—enough to avoid the payment penalty—for submitting data on a quality measure, even if you don’t satisfy the standard submission thresholds, such as the 90-day performance period.
Consider reporting for more than 90 days. You are likely to get a higher score for quality with a longer performance period—ideally a full calendar year (see “The Performance Period for Quality”).
Smaller Practices Get a Break
The MIPS program defines smaller practices as those with fewer than 16 MIPS eligible clinicians. This year, small practices score double for improvement activities.
Next year, CMS has proposed that small practices would get their own bonus points, would have their own ACI hardship exemption, and would continue to have a 3-point floor for quality measures.
What Is Pick Your Pace?
CMS has promoted 2017 as a transitional year when you can pick your pace for MIPS participation. In its educational materials, CMS describes 3 options for participating in MIPS during the program’s first year:
- Test pace of participation. This option involves avoiding the payment penalty by doing the minimum needed for 1 performance category, with quality being the easiest option. For instance, if you submit 1 quality measure just 1 time on 1 patient, you will score 3 points, which is enough to avoid the payment penalty. Although CMS terms this the “test pace” of participation, reporting just 1 quality measure only 1 time won’t test your readiness for MIPS. It is more analogous to the “Get Out of Jail Free” card in the classic board game Monopoly—with a minimal amount of effort you can avoid a significant penalty. To give yourself some room for error, the Academy urges you to do much more than the bare minimum.
- Partial year participation. Participate for at least 90 days and you will be able to score more than 3 points for each quality measure that you report, and you also will be able to score points for the improvement activities and ACI performance categories.
- Full year participation. Participating for a full year will help prepare you for the 2018 performance year, when the performance period for quality is expected to increase to 12 months, and it may boost your quality score (see “The Performance Period for Quality”).
Next: Know the Basics: Who Does (and Doesn’t) Take Part in MIPS
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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