MIPS—Today’s To-Do List: Avoid the Payment Penalty

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First, the bad news: If you don’t participate in the Merit-Based Incentive Payment System (MIPS) in 2017, your Medicare payments will be reduced by 4% in 2019. For many ophthalmologists, that would mean a payment penalty of about $18,600.

So, what’s the good news? During this initial year of MIPS, CMS has made it easy to avoid the penalty. Indeed, by reporting a quality measure just one time on one patient, you can meet the minimum requirements in just a few minutes, and you can do so today.

Reduce your risk. Reporting the bare minimum will leave you with no margin of error. Given the amount of money that is at stake, it would be prudent to hedge your bets by doing some additional reporting. You can, for example, try to score points in more than one performance category.

Get up to speed. After reading this overview, visit EyeNet’s MIPS Manual and the MIPS hub page to learn more about the MIPS payment program.

You Can Participate in up to 3 Performance Categories

For 2017, your MIPS final score (0-100 points) is based on how you do in 3 performance categories.

The quality performance category replaces the Physician Quality Report­ing System (PQRS). It contributes up to 60 points to your MIPS final score.

The advanc­ing care infor­mation (ACI) performance category replaces the meaningful use program for electronic health records (EHRs). It contributes up to 25 points.

The improve­ment activities performance category is entirely new. It contributes up to 15 points.

In 2017, you only need a MIPS final score of 3 points to avoid the 2019 payment penalty. Because MIPS has a significant learning curve, for the first performance year CMS set a low threshold for avoiding the payment penalty. You can meet or exceed that 3-point threshold by participating in at least 1 of 3 performance categories, as described below.

Option 1: Use the IRIS Registry to Report Quality, With or Without an EHR System

The IRIS Registry offers 2 options for MIPS quality reporting. One requires an EHR system, but the other doesn’t. With either option, you can choose individual reporting or group reporting.

Using IRIS Registry/EHR integra­tion. Once you have integrated your EHR system with the IRIS Registry, an automated process extracts your quality data from your EHRs and uploads the information to a clinical data registry, which submits your MIPS quality data to CMS on your behalf. You must have registered for this option by June 1.

IRIS Registry web portal. This approach involves manually entering your quality data into a web portal. When you log in to the IRIS Registry web portal, you will see a list of quality measures that you can report. You must have registered for the web portal option by Oct. 31.

For a step-by-step guide, visit the IRIS Registry User Guide.

Option 2: Report at Least 1 Quality Measure by Claims

This option is only available to you if you are participating in MIPS as an individual. Along with your claims sub­mission, report at least 1 MIPS quality measure on at least 1 qualifying MIPS patient. You do this by submitting the appropriate quality data code (QDC), as was done when reporting PQRS measures via claims. QDCs can be a Category II CPT code or a temporary G code.

Reduce the risk. If your claim is de­nied, the MIPS reporting for that claim will also fail. With that in mind, you should report more than one quality measure on more than one patient for more than one day.

Pick a quality measure that applies to one of your patient encounters. The Academy identified 31 MIPS quality measures that are most likely to be appropriate for ophthalmologists. Of these, the 16 measures listed below can be reported via claims.

• 1: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (> 9%)
• 12: Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation
• 14: Age–Related Macular Degenera­tion (AMD): Dilated Macular Exam­ination
• 19: Diabetic Retinopathy: Commu­nication With the Physician Managing On-Going Diabetes Care
• 110: Preventive Care and Screening: Influenza Immunization
• 111: Pneumococcal [Pneumonia] Vaccination Status for Older Adults
• 117: Diabetes: Eye Exam
• 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-up Plan
• 130: Documentation of Current Med­ications in the Medical Record
• 140: AMD: Counseling on Antioxi­dant Supplement
• 141: POAG: Reduction of Intraocular Pressure (IOP) by 15% or Documenta­tion of a Plan of Care
• 226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
• 236: Controlling High Blood Pressure
• 317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-up Documented
• 397: Melanoma Reporting
• 419: Overuse of Neuroimaging for Patients With Primary Headache and a Normal Neurological Examination 

Fill out CMS form 1500 for a patient encounter that takes place in 2017. Make sure you fill out these boxes:

• Box 21A: If there is an ICD-10 code associated with the quality measure, list it here.
• Box 24A: Date(s) of service.
• Box 24B: Place of service.
• Box 24D: CPT Category I, Level I code plus MIPS Category II code or HCPCS code, and any applicable modifier.
• Box 24E: Link to the ICD-10 code in box 21A.
• Box 24F: Include a charge of 1 cent.
• Box 24G: Include “1” in the unit field.

Which codes should you use? The Academy has created detailed web pag­es for MIPS quality measures, including lists of relevant QDCs, Category I CPT codes, and ICD-10 codes. To access the pages for the above measures, visit 2017 Quality Measures for Merit-Based Incentive Payment System and click “Claims.”

Why put a charge of 1 cent in the charges field? While CMS may accept a code without an associated charge, your system might suspend the code without a charge. Hence, charge 1 cent and adjust it off when the claim is paid.

Has the measure been received by CMS? Watch for the remittance advice when CMS makes payment, and see if it includes code N620. (Note: This code is for informational purposes only.)

Note: You can only report quali­ty measures via claims if you report individually, not if you report as part of a group. If you report the quality performance category as an individual, you must also report the improvement activities and ACI performance catego­ries as an individual.

Read the online guide. For addition­al information on reporting quality by claims, visit the Claims-Reporting Guide to MIPS.

Option 3: Report Improvement Activities via the IRIS Registry

In order to report an improvement activity, you—or, if you are participat­ing in MIPS as part of a group, at least one clinician in your group—must have already performed that activity for at least 90 consecutive days.

Find a suitable improvement activity. MIPS features more than 90 improvement activi­ties, but many of them aren’t applicable to ophthalmology practices.

The IRIS Registry web portal sup­ports reporting of the 22 improvement activities that are most suitable for ophthalmologists. To see what those measures entail, including docu­mentation suggestions, visit 2017 Improvement Activities for Merit-Based Incentive Payment System.

Have you been performing MIPS improvement activities without realiz­ing it? There are several improvement activities that practices may have been performing and documenting as a matter of course. These include the following:

• IA_AHE_1: Engagement of new Med­icaid patients and follow-up.
• IA_EPA_1: Provide 24/7 access to eligible clinicians or groups who have real-time access to patient’s medical record.
• IA_CC_2: Implementation of im­provements that contribute to more timely communication of test results.
• IA_CC_8: Implementation of docu­mentation improvements for practice/process improvements.

Report an improvement activity at AAO 2017. Go to the Academy Resource Center (Hall G, Booth 3140) and visit the IRIS Registry kiosk, where Academy staff can walk you through the process of reporting an improve­ment activity via the IRIS Registry web portal. You must bring your IRIS Registry login information with you. Note: If you have forgotten your login credentials, you should contact the IRIS Registry vendor, FigMD, at aao.support@bot.figmd.com. Please include your practice name. Contact them before you leave for New Orleans because their customer service staff aren’t available weekends, including the first 2 days of AAO 2017 (Saturday, Nov. 11 and Sunday, Nov. 12).

More information online. To learn how to report improvement activities via the IRIS Registry web portal, visit the IRIS Registry User Guide.

Other Options

You also can avoid the MIPS penalty by meeting the minimum requirements for ACI performance, which is less bur­densome than its predecessor, the EHR meaningful use program.

You can report ACI measures manu­ally via the IRIS Registry web portal.

You also can report ACI measures and improvement activities via the CMS attestation portal and, possibly, via your EHR vendor.

The Zero Penalty Campaign

In an effort to safeguard your reimbursement, the Academy has been using its zero penalty campaign to highlight how ophthalmologists can avoid the MIPS penalty.