MIPS Toolkit

MIPS Overview

MIPS, which began on January 1, 2017, consolidates the previous Medicare programs (PQRS, Value Based Modifier (VBM) and Meaningful Use) into one composite performance score, ranging from 0 – 100. The composite score is based on four weighted categories:

  • Quality (previously PQRS)
  • Cost (previously VBM)
  • Advancing Care Information (ACI) (previously Meaningful Use)
  • Improvement Activities (IA) (new category)

Are you looking to avoid a MIPS penalty with minimal reporting?

Follow our step-by-step instructions for 2017.

Who must participate in MIPS?

MIPS applies to all physicians, nurse practitioners and physician assistants, unless they meet one of the following exclusion criteria:

  • They are in their first year of Medicare participation.
  • They are qualified participants in eligible advanced APMs.
  • They fall under a low-volume threshold for treating Medicare patients: they bill $30,000 or less in Part B allowed charges OR see 100 or fewer Part B patients per year. (Medicare Advantage patients do not count.)

Check the Centers for Medicare & Medicaid Services (CMS) online tool to see whether you must participate in MIPS in 2017. All you need is your National Provider Identifier (NPI) to learn if you’re required to participate.

Do you belong to a Physician Hospital Organization (PHO) or Accountable Care Organization (ACO)?

Find out what that means for MIPS reporting.

MIPS Performance

Eligible Clinicians (ECs) receive a positive adjustment if their score is above the performance threshold and a negative adjustment if their score is below the threshold. But the program must be budget neutral, so negative adjustments are required to offset positive adjustments. Category weights and potential adjustments are shown by year in the chart below.

  MIPS Performance Categories & Weighting 
Performance YearPayment YearQuality MeasuresCostImprovement ActivitiesAdvancing Care InformationPotential Adjustment
2017201960%0%15%25%+/- 4%
2018202045%15%15%25%+/- 5%
2019202130%30%15%25%+/- 7%
2020 and beyond2022 and beyond30%30%15%25%+/- 9%

 

Options for 2017

2017 is a MIPS transition year, and CMS has provided multiple flexible reporting options. There are three MIPS reporting options that will exempt physicians from any risk of penalties in 2019:

  • Report minimal data (one improvement activity for 90 consecutive days or one quality measure or all four base advancing care information measures for 90 consecutive days) and avoid a penalty. Follow our step-by-step instructions.
  • Report additional data (more than one improvement activity, more than one quality measure, or more than the four base advancing care information measures) for at least 90 consecutive days and be eligible for a small bonus payment.
  • Report all required measures for at least 90 consecutive days and be eligible for a bonus payment. 
    • Eligible clinicians who achieve a final performance score of 70 or higher (out of a possible 100) will be eligible for an exceptional performance adjustment funded from a separate incentive pool of $500 million!

If you choose not to report at all, but are required to do so, you will see a 4% reduction in 2019 Medicare reimbursements.

At minimum, every allergy practice should consider reporting ONE improvement activity or ONE quality measure to avoid a penalty in 2019!

Individual vs. Group Reporting

Eligible clinicians can participate in MIPS either as an individual or as part of a group. A group is defined as a set of two or more clinicians with unique NPIs sharing a common Tax Identification Number (TIN). If reporting as a group, all clinicians with NPIs assigned to the TIN must participate as a group and report on the same measures and activities.

Reporting as an individual or a group: Which path should you take?

Keep these tips in mind.

 

Full 2017 MIPS Reporting Requirements

2017 College MIPS Tips

Quality

  • Review your reporting options. You have a better chance of maximizing your quality score if you report via EHR Direct, Qualified Registry or QCDR – not claims.
  • If you participated in PQRS in 2015, review your 2015 Quality and Resource Use Report (QRUR), which shows how you performed on quality and cost measures. Exhibit 3 will give details on your quality measure performance, and can help you select good quality measures to report in 2017 – or show where you need to improve.
  • Read our tips on how to maximize your quality score.
  • You may want to consider the measures in the Allergy/Immunology specialty measure set. You have the option of reporting all measures in a specialty measure set for your chosen reporting method (registry, EHR, etc.)

Improvement Activities

  • You don’t need to use a registry or EHR to report; you can simply attest to the activity on the CMS attestation website (currently under development).
  • If your practice reports as a group, as long as one clinician within the group performs the activity for a continuous 90-day period, the whole group will get credit.
  • There are 92 possible improvement activities to choose from – and you may already be doing one or more of them in your practice.
  • CMS provides guidelines for validating Improvement Activities as well as suggested documentation for each.
  • Some suggested Improvement Activities for allergists are:
    • Activity IA_BE_13: Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms.
      • Do you regularly perform patient satisfaction surveys? If so, you already meet this activity requirement. Practices can administer surveys of their own design for this activity.
    • Activity IA_BE_20: Implementation of condition-specific chronic disease self-management support programs.
      • Do you provide asthma patients with self-management support programs or coaching? If so, you may already meet this activity requirement.
    • Activity IA_BE_4: Engagement of patients through implementation of improvements in patient portal.
      • Does your practice have a patient portal that provides patient education on asthma or allergies? Does it allow bidirectional communication about medication changes? If your answer is “yes”, this activity may work for you.

Advancing Care Information

  • You must report all required base measures, or your entire Advancing Care Information score will be 0.
  • In 2017, the ACI measures you report will depend on the year of your EHR edition. The 2014 EHR edition is currently most popular, as most EHRs haven’t updated to the 2015 edition yet. Be sure to check your EHR edition before reporting.
  • For details about Advancing Care Information requirements, measures and scoring, CMS has a helpful ACI Deep Dive webinar and slides.
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