New details on how MIPS will impact allergists
Last week, we took an initial look at Medicare’s latest proposed details of the Quality Payment Program. Today, we are diving deep into details of the Merit-Based Incentive Payment System (MIPS). We have some good news and some bad news (not necessarily in that order).
Remember, the Advocacy Council is preparing comments to submit to CMS before June 26, and the rules will not be finalized until later this year.
Less onerous compliance
Although many MIPS requirements are similar to PQRS, MU or VBM, CMS is proposing changes intended to make compliance less onerous. Some of the important changes include:
- Reporting of six quality measures instead of nine.
- Reporting a specialty measure set instead of individual measures.
- Bonus points for registry reporting.
- Reporting can include non-Medicare patients beginning in 2019.
- Elimination of all or nothing requirement for meaningful use of EHRs.
- Elimination of computerized provider order entry and clinical decision support requirements.
Rules eased for small practices/low volume
Allergists with fewer than $10,000 in Medicare allowed claims and fewer than 100 Medicare patients are exempt from MIPS. CMS estimates approximately 22% of allergists enrolled in Medicare will be excluded from having to participate. In addition, for those in groups of 15 or less, the rules for achieving compliance with the clinical practice improvement category have been eased. Further, for the cost/resource use component, there must be at least 20 Medicare cases or patients per measure for the measure to be counted. If a physician does not have enough patients attributed to him, as is likely with specialists such as allergists, CMS will reweight the category to zero and adjust the other three MIPS performance scores.
Economic impact on the allergy specialty
CMS estimates that 70% of the MIPS penalties in 2019 will be borne by practices of fewer than 10 physicians, and, of the 3,031 allergists who are expected to participate, 57.1% will receive a negative adjustment. The initial negative adjustment is limited to 4% and thus is less than the current PQRS/MU/VM program adjustments which, in 2018, could be as high as 9%. The estimated negative impact is higher than that of other specialties due, at least in part, to allergists’ historically low participation in PQRS, meaningful use of EHR, and the VBM programs. If that is you, get ready now to start reporting quality measures and implementing new MIPS care information requirements.
MIPS composite score
Under MIPS, clinicians (both physicians and certain non-physician practitioners) will receive a MIPS composite score based on four categories that will determine whether they receive a negative or positive adjustment. Each of the four MIPS components counts for a different percentage of the score. Physicians can opt to be measured individually or as a group.
Composite Score Weight
Current Program It Replaces
Advancing Care Information
Meaningful Use of EHR
Clinical Practice Improvement
Allergy quality measures still lacking
There are still few, if any, CMS approved quality measures that relate specifically to allergy specialty care. Although there are approved asthma care measures, many view these as more directed at primary care. Under MIPS, two asthma measures are proposed – one existing measure and one new measure. Both have age restrictions and would not cover the elderly Medicare population. There is also concern that one of these measures might actually work against specialists because they see the most severe asthma cases.
View the ACAAI webinar titled "Changing Payment Models: What Allergists Need to Know Now” to learn more about the proposed rule and its impact on allergists.