Year 2 of the Merit-based Incentive Payment System (MIPS) is in full swing, with plenty of significant updates to the ways you can participate in the Quality Payment Program (QPP). This year’s changes include new data reporting requirements. You’ll want to get those straight to avoid a MIPS 5% pay cut in 2020!
While the Centers for Medicare & Medicaid Services (CMS) intends these MIPS changes as a help, you may find the increasingly difficult standards and program components to be a challenge, warns healthcare compliance expert Jeanne Chamberlin in her live webinar with ProfEdOnDemand.
To help clear up any questions you may have about MIPS Year 2, Chamberlin’s presentation outlines the modified reporting requirements and deadlines, as well as MIPS scoring methodology and how to best adapt to this year’s critical changes.
Who’s Eligible: (Mostly) The Same
MIPS, one of the tracks used by eligible clinicians (ECs) for participation in the QPP, requires the reporting of data across four categories: Quality, Cost, Advancing Care Information (ACI), and Improvement Activities (IA).
Who’s an EC? Currently, according to healthcare legal experts at Press Ganey, ECs include the following practitioner types:
- Advanced Practice Nurses
- Physician Assistants
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
However, CMS does have a low-volume threshold that prevents certain clinicians from the above categories from participating. Last year, the performance threshold was <$30,000 in charges or <100 Medicare Part B patients. This year, that has increased to <$90,000 in charges or <200 Medicare Part B patients. One impact of this increase, say analysts at Advisory Board, is a reduction in the number of eligible clinicians to approximately 622,000.
4 Categories See Significant Changes
The four categories that provide your final MIPS score each reflect a different perspective on how you deliver care in your medical practice. The rules for data submission are different for each category, so you’ll want to pay close attention to ensure you’re submitting the right amount and right kind of data for each one.
Variables: Additionally, requirements may differ for small practices, those affected by natural disasters, and those that are not patient-facing, so it’s important you check what’s required for your specific practice.
For most ECs, the changes this year to the four categories are as follows, according to an analyst at Medisolv:
- Quality: Although CMS initially promised to keep the Quality category’s weight at 60%, the final rule reduces the weight to 50% to compensate for the change to how the Cost category is now weighted. The reporting period for this category is 365 days.
- Cost: This category is now weighted at 10% instead of 0%. For 2018, the Cost score is based on the Medicare Spending per Beneficiary (MSPB) and total per capita cost measures. The reporting period for Cost is also 365 days.
- ACI: This category is weighted at 25%. For ACI, you are eligible for up to 10 bonus points if you report data using only 2015 certified EHR technology (CEHRT). The reporting period for ACI is short—90 days.
- IA: This category is weighted at 15%. As with the other measures, there are modifications and exceptions, so pay attention to what would apply to your practice. The reporting period for IA is also just 90 days.
Tip: You will want to prioritize the Quality and Cost categories this year. Why? As you’ve probably noted already, CMS quadrupled the reporting period for Quality from 90 days to 365, not to mention that Quality already accounts for half your score. And with CMS projecting the Cost category to increase to a 30% weight in 2019, these two categories are the ones that are set to have the greatest impact on your reimbursement.
Continuing the Transition
The requirements for 2018 MIPS reporting can be overwhelmingly complex given all the measures, percentages, exceptions, and deadlines you have to consider. And the guidelines will likely change again come 2019. So don’t put off laying a sound foundation for your practice’s compliance, says Chamberlin.