The Medicare Access and Chip Reauthorization Act of 2015 (MACRA) repealed the flawed sustainable growth rate formula and set in motion predictable Medicare Part B payment updates and shifts practices toward value-based reimbursement through the Quality Payment Program (QPP). Under the QPP, practices may be required to participate in the Merit-based Incentive Payment System (MIPS), a new, all-encompassing federal quality reporting program that potentially adjusts Medicare payments based on performance on quality, cost, EHR, and improvement activity metrics. Alternatively, practices may participate in an advanced alternative payment model (APM), which may exempt them from MIPS and qualify them for a 5% lump sum bonus.
2018 is the second performance year of MIPS. Eligible clinicians will be subject to upward, neutral or downward payment adjustments in 2020 based on their performance this year in four performance categories: quality, cost, advancing care information (ACI) and improvement activities. Each MIPS performance category is weighted to contribute to your final MIPS score, which is calculated out of 100 points. Scoring 15 points or higher will avoid a 5% penalty, while higher scores may qualify for a modest bonus.
Steps to ensure your practice is MIPS compliant in 2018
Determine MIPS Eligibility
In 2018, the following types of clinicians generally must participate in MIPS to avoid a penalty in 2020: Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists.
Clinicians may be deemed ineligible if one of the following applies:
- Newly enrolled in Medicare (i.e., never billed Medicare in a previous year)
- Fall below the MIPS low-volume threshold (i.e., bill $90,000 or less in Medicare allowed charges or treat 200 or fewer Medicare beneficiaries)
- Significantly participating in an Advanced APM
- Partially participating in an Advanced APM and opt out of MIPS
While MGMA strongly encourages practices to avoid a MIPS penalty, group practices should weight the costs and benefits of robust participation in MIPS. Practice leaders should consider both the short-term (e.g., cost of purchasing a new registry, etc.) and long-term (e.g., increasing MIPS penalties and reporting requirements over time, etc.) implications when setting a MIPS goal.
Set Your 2018 MIPS Goal
Clinicians may report and be evaluated individually, collectively under one Tax Identification Number (TIN), or as part of a "virtual group," comprised of multiple TINs.
Establish A Reporting Strategy
Looking to avoid a penalty?
Clinicians and group practices must earn at least 15 out of 100 points in 2018 to avoid a Medicare payment cut of up to 5% in 2020. This is an increase from the 2017 threshold of three points but can be achieved by satisfying the requirements of one MIPS category or subparts of multiple MIPS categories. For instance, ECs and group practices that participate fully in the improvement activities category will receive 15 points and avoid a penalty.
Looking to qualify for a bonus?
In 2018, MIPS scores are based on performance in four categories, each with its own reporting and scoring metrics and each accounting for a set proportion of the total MIPS score of 100 points. MIPs is scored on a “sliding scale,” which means you may satisfy as many or as few requirements from each of the categories, but satisfying more MIPS criteria and performing well on individual metrics puts you in the best position to maximize your score.
At year-end, practices should work with their vendors to ensure MIPS data is properly reported. Practices have important decisions to make at this time, including which data to report, whether to report data individually or as a group, and which measures to report. In general, the data submission deadline is Mar. 31 after the performance year. In other words, 2017 data is due to the Centers for Medicare & Medicaid Services by Mar. 31 2018.
Review and Submit Data