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Leverage MIPS Year 1 experience to make Year 2 less demanding

Insight Article - June 14, 2018


Data Analytics & Reporting

Joncé Smith
Last year, many medical groups struggled to understand the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and its implications for clinicians and their practices’ operational effectiveness. With Year 2’s data collection period in progress, healthcare providers should tackle 2018 reporting for the Merit-based Incentive Payment System (MIPS) by considering changes from Year 1, as well as crafting new strategies to maximize reimbursement.

MIPS changes in Year 2

Eligible clinicians remain the same as last year, but exempt clinicians are now those who bill $90,000 or less in Part B charges or treat 200 or fewer Part B beneficiaries. The Centers for Medicare & Medicaid Services (CMS) Quality Payment Program’s site allows for practices to verify participation status, which also considers special status based on practicing in a federally designated Health Professional Shortage Area (HPSA), whether a practice is small and other factors.

There are numerous program changes for MIPS this year. For example, providers can now gain or lose 5% in Medicare reimbursement versus Year 1’s 4% risk. The reporting participation threshold has increased, as the pick-your-pace option has gone away in Year 2. The points needed to enable participation status and avoid penalty rose from as few as three in 2017 to 15 in 2018. 

While the same four reporting categories of quality, advancing care information (ACI), improvement activities (IA) and cost remain in Year 2, category weights have been adjusted. For the first time, cost performance is weighted at 10% of the final MIPS score, which then adjusts the quality score from the previous 60% to 50%. ACI and IA are weighted the same as they were in Year 1.  

Performance periods for cost and quality have changed as well. The quality and cost categories require a full 365 days of reporting data in 2018. ACI and IA still require 90 days of 2018 data.

Making the most of MIPS in Year 2 

CMS applied MIPS program changes based on more than 1,200 stakeholder and clinician comments to ease reporting burden while keeping small practices in mind. Beyond adjusting to Year 2 changes, there are seven additional ways MIPS participants can stay ahead of the curve.

1. Take advantage of 2017 data 

By assessing past Quality Resource Usage Report (QRUR) data, MIPS providers can better anticipate 2018’s now-weighted category. In addition, official CMS feedback for the 2017 reporting year is slated for this summer. Providers should utilize this feedback as a foundation, especially for the quality category.

2. Assign a MACRA leader

Groups need to assign someone as their leader to work with subject matter experts to ensure accurate reporting, and more importantly, to select the right measures for reporting. This leader should be a physician, but could also be a clinical informaticist. If the group has more than 40 physicians, then two representatives should be selected. 

3. Consider change from 2018 legislation

The Bipartisan Budget Act of 2018 extended MACRA’s initial transition years into 2021. Although CMS projected the MIPS cost category to increase to 30% weight by 2019, the Act extends that until 2022. Additionally, cost improvement scoring will not be considered for MIPS score calculations in 2018. 

4. Thoroughly document for IA

Within the IA category, not all measures need to be from the same 90-day period, but eligible clinicians should strategically document each starting point and measure progress. Pick easily attainable measures that are aligned with your practice’s activities to ensure an easy transition. 

5. Submit the best quality measures

Submit the required full six measures for the quality category, at least one of which should be an outcome measure. If you submit more, CMS can pick which one you will receive credit toward your overall performance score, so choose the best six metrics with data completeness. Each quality measure has the potential for up to 10 points, equaling a total of 60 points.

6. Take advantage of bonus opportunities

Within your six quality measures, you can earn bonus points if more than one is an outcome or patient satisfaction measure. Another bonus option is a quality improvement score. If you report on one or more of the same quality measures in 2018 as Year 1 and show improved performance with data completeness, you can earn up to 10% bonus points at the category level. Keep in mind there is no penalty if 2018 quality performance decreases compared to 2017, as long as the submission requirement is met. 

7. Capture additional bonuses

There are also five-point bonuses toward final 2018 MIPS scores for small practices and eligible clinicians treating complex patients. The complex patient bonus is based on a combination of the Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated.

With feedback from 2017 participation as the foundation, keep these MIPS Year 2 tips in mind as you continue data collection. By employing thorough documentation, better EHR utilization and category maximization, strategic MIPS participation will become a more habitual process.

About the Author

Joncé Smith
Joncé Smith
Vice President of Revenue Cycle Management Stoltenberg Consulting Terry, Miss.

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