How to do the bare minimum in 2018 to avoid a MIPS penalty in 2020

, | April 16, 2018

How to do the bare minimum in 2018 to avoid a MIPS penalty in 2020

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For those of you simply trying to avoid a 5% MIPS penalty in 2020, follow these steps in 2018. It’s still possible, even if you don’t have an EHR!

1. Check whether you are required to report under MACRA.

Beginning in 2018, providers (or groups, if your practice reports as a group) that bill Medicare $90,000 or less OR see 200 or fewer Medicare patients annually are EXEMPT from participating in the program. You are also exempt if this is your first year of Medicare participation, or if you are a qualified participant in an eligible advanced alternative payment method (APM).

Check the newly updated Centers for Medicare & Medicaid Services (CMS) online tool to see whether you must participate in MIPS. All you need is your National Provider Identifier (NPI) to learn if you’re required to participate in 2018. CMS will not mail MIPS status letters to group practices in 2018, so it’s important to check the lookup tool to determine your status.

CMS estimates that only 37% of physicians will be subject to MIPs due to the expansion of low-volume exclusions. CMS will evaluate claims data from two separate year-long periods to determine 2018 low-volume eligibility: September 2016 through August 2017, and again from September 2017 through August 2018.

2. Determine if you qualify as a small practice (<16 clinicians).

If you have less than 16 clinicians, you qualify as a small practice. If so, you get special benefits and it will be easier to report! Clinicians include physicians as well as physician assistants and advanced practice nurses.

  • Small practices get an automatic bonus of five points.
  • Small practices don’t need to worry about data completeness for quality measures. You just need to report some data for each quality measure to get credit.
  • Small practices get double credit for improvement activities (IAs).

If you’re not a small practice, don’t despair. You’ll need to do more, but you can still meet the minimum 2018 reporting requirements. Read on.

3. Mix and match to get to 15 points.

A total of 15 MIPS points is required in 2018 to avoid the penalty, up from three points in 2017. You have lots of options to get to 15 points – but they will depend on the size of your practice.

Small Practice (<16 clinicians)

As we mentioned above, small practices automatically receive a bonus of five points. Plus, they receive minimum credit for each quality measure reported, if they report some data for the measure. They also get double credit for IAs. Here are some options for small practices to get to 15 points:

  1. Report some data for four quality measures.
  2. Report one high-weighted IA or two medium-weighted IAs for 90 days.
  3. Report one medium-weighted IA for 90 days plus some data for one quality measure.


Large Practice (16+ clinicians)

Here are some options for larger practices to get the required 15 points:

  1. Report all required IAs for 90 days (options: two high-weighted IAs OR one high-weighted IA + two medium-weighted IAs OR four medium-weighted IAs).
  2. Submit six quality measures (or the A/I specialty measure set) that meet data completeness criteria (60% of applicable patient encounters over a 12-month reporting period).1
  3. Report two medium-weight IAs for 90 days and four quality measures that meet data completeness criteria.1
  4. Meet the Advancing Care Information (ACI) base score (an EHR is required for this) and submit one medium-weighted IA.

For 2018, there are two options to meet the ACI base measures:

2018 Advancing Care Information Transition Objectives and Measures

Security Risk Analysis
Provide Patient Access
Health Information Exchange


Advancing Care Information Objectives and Measures

Security Risk Analysis
Provide Patient Access
Send a summary of care
Request/accept summary of care

4. Choose improvement activities and/or quality measures.

Improvement Activities (IA)

There are 113 possible IAs detailed on the Quality Payment Program website. Choose activities that work for your practice (or that you are already doing; that counts, too!) and implement them for at least 90 days. Reporting improvement activities has certain advantages:

  • You don’t need to use a registry or EHR; you can simply attest to the activity on the CMS attestation website. (We strongly suggest you retain supporting documentation in case of an audit.)
  • If your practice reports as a group, rather than as individuals, only one clinician in the group needs to perform the activity and the whole group will get credit.

You only need to participate in the activity for 90 days.

The College has developed a list of improvement activities for allergists to consider.

Quality Measures

Quality measures can be reported several ways: by EHR, registry, QCDR, CAHPS for MIPS Survey (groups only), and Claims. But how you decide to report will determine which measures you can choose from. (Some measures are only available by claims, others by EHR, etc.) CMS has a full list of quality measures and possible reporting methods for each.

When choosing quality measures, remember the following:

  • Small practices (<16 clinicians) only need to report some data for each measure.
  • Large practices (16+ clinicians) must meet data completeness requirements (60% of applicable patient encounters over 12 months).1
  • If you plan to submit quality measures via claims, you can’t report as a group.

Allergy practices may want to consider reporting quality measures in the allergy/ immunology specialty measure set. But you can report any one of the 275 quality measures available for your chosen reporting method.

5. Attest and/or Report to CMS.

Improvement Activities

You can simply attest to completing IAs at the CMS website; the deadline is March 31 of 2019. You’ll need an Enterprise Identity Management (EIDM) account before you begin.

To create an EIDM account, visit the CMS Enterprise Portal or call 1-866-288-8292. If you forgot your EIDM credentials, go to the CMS Enterprise Portal to reset your user ID  or password. When creating your EIDM account, the first step asks you to select an application. For MIPS, the application you need to select is Physician Quality and Value Programs.

Quality Measures

There are many ways to report quality measures. If you’re reporting via claims, follow the AMA’s example of how to submit a measure via claims.

Other options include reporting via Qualified Registry, Qualified Clinical Data Registry (QCDR) or EHR (contact your EHR vendor for details), although these all typically involve a fee.

6. Get help if you need it.

CMS has a wealth of resources to help you, ranging from videos and online courses to a help desk and in-person assistance. Don’t hesitate to reach out if you need help.

In summary, fewer allergists will be required to participate in MIPs in 2018. Large practices, especially, will need to do more to avoid a penalty. But if you follow these steps, we’re confident all allergy practices can avoid a 5% penalty in 2020.


1 To meet data completeness requirements for quality measures, large practices (16+ providers) must report on 60% of applicable patient encounters over 12 months. If you report via claims, you only need to report 60% of Medicare patients. However, if you report via any other method (EHR, registry, etc.) you will need to report 60% of all applicable patients – regardless of payer.