Beginning in 2017, Medicare consolidates the Physician Quality Reporting System and other existing quality-improvement programs into the Quality Payment Program. Most ophthalmologists will likely use the program’s new fee-for-service option – the Merit-Based Incentive Payment System. The Academy’s IRIS Registry can help you meet MIPS reporting requirements and avoid penalties in 2019.
How MIPS Works
Physicians have three options for MIPS: 1) Earn a bonus for high performance; 2) Avoid a penalty for successful performance; 3) Earn a future penalty for unsuccessful performance or not reporting at all.
- With the IRIS Registry, you can work toward both a bonus or penalty avoidance.
- Under MIPS, the Centers for Medicare and Medicaid Services evaluates physician performance in four weighted categories.
CMS will not count performance on the cost category for 2017 reporting. Category weights for 2017:
Using the IRIS Registry to Report MIPS
The IRIS Registry supports reporting for each of the three weighted categories. Important note: The IRIS Registry will automatically submit 2017 MIPS data at the group level unless you ask us report at the individual eligible clinician level. If your practice reports at the group level for one category, it must do so for all MIPS categories.
|MIPS Category||With Eligible EHR System||Without Eligible EHR|
||Registry automatically reports to CMS on your behalf.
||Enter data in the IRIS Registry web portal
|Advancing care information
||Attest in the IRIS Registry web portal
||Attest in the web portal if you have an EHR system; measures for this category require the use of EHRs
||Attest in the IRIS Registry web portal to receive credit
||N/A - Even once CMS assigns a weight to this category, physicians will not have to report this data.
Use the IRIS Registry to meet the reporting requirements for the quality category using the EHR-integration option OR the IRIS Registry web portal (cannot combine both for quality).
- CMS offers bonus points for 1) reporting on more than one outcomes or high priority measures and 2) for electronically submitting quality measures.
- With an EHR system: The IRIS Registry will submit the measures on which you would earn the highest points, automatically maximizing your score.
- Benchmarking: All EHR-integrated IRIS Registry participants that report the electronic clinical quality measures (CQMs) will be compared to the CMS published EHR benchmarks for MIPS scoring purposes. CMS will know to use the EHR-benchmarks because IRIS Registry will submit the CQM performance data for those practices using a file for electronic clinical quality measures, as CMS determines the appropriate benchmark to use based on the submission file type. This is different than measures reported using the IRIS Registry web portal. Practices manually entering quality measure data using the IRIS Registry web portal will be compared to the registry benchmarks.
- ACOs: Practices part of an ACO can report quality separately from the ACO to be considered if for any reason the ACO fails. Providers joining ACO-participating practices after August 31, 2017 should also report quality measures separately.
Advancing Care Information
CMS does not require EHR use for 2017 MIPS participation, but you must use an EHR system to meet the reporting criteria for the advancing care information category.
- Earn 5 bonus points under this category for using the IRIS Registry (participation in a specialized registry).
- New in 2017: You don’t need to separately attest with CMS; you can submit advancing care information directly through the IRIS Registry web portal.
- Participation in the IRIS Registry is not sufficient to meet the criteria for this category; providers must use their certified EHR system to meet the required measures for that category.
CMS offers a number of activities that may apply to ophthalmologists. Points for activities vary based on practice size. All physicians must complete at least one activity for this category to avoid a penalty.
- The IRIS Registry supports reporting for 18 activities.
- With an EHR system: Participation in the IRIS Registry qualifies you for four of these 18 activities. You can report for additional activities if desired.
- Without an EHR system: Attest to some of these 18 activities through the IRIS Registry web portal.
In addition to attesting, all practices should maintain documentation supporting completion of each activity, in the event of a future audit.
Qualified Clinical Data Registry
CMS approved the IRIS Registry in 2015 and 2016 as a Qualified Clinical Data Registry. We will receive notification from CMS regarding IRIS Registry’s QCDR approval and non-MIPS measure approval for 2017 MIPS reporting in late spring 2017.