Updated March 27, 2018The Centers for Medicare & Medicaid Services (CMS) announced important new information for Merit-based Incentive Payment System (MIPS) participants:
1. The CMS data submission system for 2017 MIPS data is now available. Data must be entered by March 31 (or March 16 if you are a CMS Web Interface user).
- To login and submit data, you’ll need your Enterprise Identity Management (EIDM) credentials.
- If you’ve been planning to attest for the Improvement Activities and/or Advancing Care Information categories, this is where you’ll do it.
- For more details about the data submission system, view CMS’ fact sheet.
2. The 2018 MIPS Resources are now available, including the measures and activities for each of the four MIPS performance categories.
- 2018 Improvement Activities
- 2018 Quality Measures
- 2018 Cost Measures
- 2018 MIPS Advancing Care Information (ACI) Measures
Other important 2018 MIPS info for allergists
1. Fewer allergists will be required to participate in MIPS in 2018 due to expansion of low volume exclusions.
Beginning in 2018, CMS has significantly broadened the MIPS low-volume exclusion. MIPS will not apply to individual clinicians or groups with $90,000 or less in annual Medicare revenues OR 200 or fewer Medicare patients. As a result, CMS estimates that only 37% of physicians will be subject to MIPS. A recent Advocacy Insider article summarized the final MIPS rule for 2018. Unfortunately, CMS hasn’t yet provided a lookup tool to check whether you’re excluded.
2. Small practices (< 16 clinicians) get favorable treatment – and can successfully report without an EHR
- Small practices are exempt from the ACI category as long as they file a hardship exception application by the end of 2018. That means allergists without an EHR can still report successfully!
- Small practices get an automatic bonus of 5 points.
- Small practices don’t need to worry about data completeness for quality measures and will receive an automatic 3 points per measure reported. So you just need to report some data for each measure in order to get credit.
3. Minimum participation requirements increase in 2018.
If you are required to participate in 2018, you’ll need to do more to avoid a 5% penalty in 2020. A total of 15 points is required to avoid the penalty in 2018, up from 3 points in 2017. But if you’re a small practice, there are several paths to get there. Some options: 1) report four quality measures (3 points each plus the 5 point small practice bonus), or 2) report one high-weighted improvement activity or two medium-weighted improvement activities (15 points plus the 5 point small practice bonus).
4. There are benefits to reporting as a group.
- Only one clinician needs to attest to completing an improvement activity.
- Not every clinician needs to report data for every quality measure – as long as data completeness requirements are met.
Our conclusion? Every allergy practice should be able to avoid a 5% penalty in 2020 – even if you don’t have an EHR. So take a minute, figure out which quality measures and/or improvement activities to report, and get started!
If you’re looking to maximize your MIPS score, we’ll provide tips in a future Advocacy Insider article. Keep watching for updates!