MACRA/Quality Payment Program

The Medicare Access and Chip Reauthorization Act of 2015 (MACRA) repealed the flawed sustainable growth rate formula and set in motion predictable Medicare Part B payment updates and shifts practices toward value-based reimbursement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, 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.

NEW

  • Access MGMA’s member-exclusive analysis of the final 2018 Medicare physician fee schedule and the 2018 MIPS/APM rules
  • Read the 2018 Quality Payment Program final rule
  • Access the CMS fact sheet for the final rule
  • MGMA submitted comments in response to proposed 2018 Quality Payment Program rule
  • It's not too late to avoid a MIPS penalty - learn how

 

Sign up for MGMA's MACRA Member Community for access to questions and discussion on MIPS and APMs 

Want to learn more about APMs? Check out MGMA's APMs Resource Center

Subscribe to MGMA's Washington Connection for the latest news on the future of the QPP and other pressing industry topics

Check out MGMA's library of member-exclusive MIPS resources including a getting started checklist, FAQs, and more

MIPS in 2017: The basics

2017 is the initial performance year of MIPS. Eligible clinicians will be subject to upward, neutral or downward payment adjustments in 2019 based on their performance this year in three performance categories: quality, 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 3 points or higher will avoid a 4% penalty, while higher scores may qualify for a modest bonus.

Continue reading for steps to ensure your practice is MIPS compliant in 2017.

Expanding Item - View More Step 1: Determine MIPS eligibility

In 2017, the following types of clinicians generally must participate in MIPS to avoid a penalty in 2019: 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 $30,000 or less in Medicare allowed charges or treat 100 or fewer Medicare beneficiaries)
  • Significantly participating in an Advanced APM
  • Partially participating in an Advanced APM and opt out of MIPS

Expanding Item - View More Step 2: Set your 2017 MIPS goal


While MGMA strongly encourages practices to avoid a MIPS penalty, group practives 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. The relatively risk-free environment in 2017, however, does present the opportunity to learn how to effectively participate in the program.

Expanding Item - View More Step 3: Establish a reporting strategy

Clinicians may report and be evaluated individually or collectively under one Tax Idenitification Number (TIN).

Looking to avoid a penalty?

Completing any of the following would earn at least 3 overall MIPS points and avoid a penalty:

  • Report one quality measure (on at least one patient)
  • Attest "yes" to completing one improvement activity
  • Report or attest to the four ACI base measures

MGMA strongly recommends clinicians report or attest to more than one measure or activity as insurance against a penalty should they experience any data submission issues or inaccuracies.

Looking to qualify for a bonus?

In 2017, MIPS scores are based on performance in three 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. For maximum credit, all three MIPS categories require at least 90 consecutive days of data. 

For more information about MIPS, including resources on group-reporting, vendor lists and category-specific information, including measure specifications and benchmarks, click here.

Expanding Item - View More Step 4: Review and submit data

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 period of 90 consecutive days (or longer) of data to report, whether to report data individually or as a group, and which measures to report. MGMA will update this webpage as more information on the data submission and attestation processes are made available from the government.

MGMA Resources

MGMA Advocacy

  • MGMA joins several provider organizations urging CMS to include group practices in APMs with Medicare Advantage plans in the APM track of MACRA
  • MGMA submits comments calling on CMS to pilot test new QPP episode-based cost measures through a voluntary program to mitigate any unintended consequences.
  • MGMA calls for immediate release of crucial 2017 MIPS eligibility information
  • MGMA comments on MIPS/APMs final rule
  • MGMA to CMS: Simplify proposed quality reporting program and expand APM pathway
  • MGMA submits comments on a request for information from CMS regarding implementation of MIPS and APM programs under MACRA
  • MGMA joins 37 other provider organizations in a letter urging CMS to include physician-led organizations and specialty societies in the clinical quality measures development process for the new Merit-based Incentive Payment System.

 

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