Understanding the Merit-Based Incentive Payment System (MIPS)
MIPS combines parts of the Physician Quality Reporting System (PQRS), the Value Modifier (VM or Value-based Payment Modifier), and the Medicare Electronic Health Record (EHR) incentive program into one single program. MIPS most closely approximates the current fee-for service system. A notable exception is that payment adjustments will be tied to a Composite Performance Score based on measures in a number of categories including; quality, resource use, clinical practice improvement activities, and meaningful use of certified EHR technology. Providers may be reimbursed more (for meeting quality outcomes) or less (if they fall below an averaged national metric).
You may be able to report through claims, registries, Qualified Clinical Data Registries (QCDR's), health information technology developers, and certified survey vendors.
MIPS Reporting
- First MIPS reporting period begins on January 1, 2017 and runs through December 31, 2017.
- MIPS Eligible Clinicians: Physicians, PAs, NPs, CNS, CRNA
- For applicable clinicians, 2017 MIPS performance will determine payment increases/penalties for the 2019 Payment Year.
- Maximum MIPS negative payment adjustment will be -4% for 2019, if an eligible clinician chooses to do nothing.
- As proposed, there are three major categories of exempted physicians
Options for MIPS Reporting
Eligible Clinicians have two options for reporting:
- Report as an “Individual,” – combination of TIN/NPI
- Report as a “Group,” – Group’s billing TIN as identifier
A “Group” is defined as two or more Eligible Clinicians (EC) that have assigned billing rights to the same TIN. There will be no “virtual groups,” until the 2018 reporting year.
How do I report my information to CMS for the MIPS?
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MIPS Category
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Available Reporting Mechanisms
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Quality of Care
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- Qualified Clinical Data Registry (QCDR)
- Electronic Health Record
- Claims Data
- GPRO
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Resource Use
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EHR Meaningful Use
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Clinical Improvement Activities
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- Attestation
- QCDR
- “Qualified Registry”
- EHR
- Claims Data
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MIPS Incentive Payments/Adjustments
MIPS is a system where each eligible clinician will receive a composite score or “index,” that will determine whether they receive a positive or negative payment adjustment for a given year starting in 2019 based on data and activities reported in 2017. This composite score is based on an eligible clinicians performance in four different categories: Quality, Cost, Clinical Performance Improvement Activities, and Advancing Care Information, previously known as Meaningful use of Electronic Health Records.
Please download the CMS information regarding the four program elements of MIPS. Below is a chart summarizing the various categories and their scores.
MIPS Overview – What you need to do for each category:
MIPS Potential Payment Adjustments
Go At Your Own Pace
What can AUGS clinicians Do in 2016 to Prepare for MIPS 2017?
Quality—60%
- Successfully participate in the Physician Quality Reporting System (PQRS) for 2016
- Measure options and reporting thresholds might change in 2017, but PQRS will continue to form the foundation of the MIPS quality component.
- Understand which measures are most applicable to your practice.
- Learn how to incorporate data collection into your workflow to improve your chances of success.
- Review your PQRS Feedback Report. Access your report on the CMS website.
- Understand your measure reporting and performance rates under PQRS to help you determine the best strategy for reporting under MIPS.
Note. If you are not currently participating in PQRS, it is not too late to start. With the introduction of MACRA, providers are paid based on treatment outcomes, quality of care, efficiency and patient satisfaction. AQUIRE has been developed as a means for members to track these parameters. In 2017, AUGS will apply for QCDR status and users will be able to submit quality measures more easily to CMS and other private insurers for reimbursement should they choose to do so.
Advancing Care Information (ACI)—25%
- Confirm that your EHR system is certified by the Office of the National Coordinator for Health IT (ONC), and determine whether it is the 2014 or 2015 edition. Check your EHR’s certification.
- Review the list of measures and objectives for the current EHR Incentive Program (also known as Meaningful Use).
Although reporting thresholds will likely change, CMS intends to maintain most of the current objectives and measures in the EHR Meaningful Use program as the basis of calculating ACI scores under MIPS.
Tips:
- Make sure you are able to conduct a security risk analysis. We recommend you review CMS’ guidance on conducting a secure risk analysis.
- Set up the groundwork for patient engagement through your patient portal since some objectives focus on encouraging patients to use these portals to view, download and transmit health information in 2017.
Clinical Practice Improvement Activities (CPIA)—15%
1. Review the list of proposed CPIA activities and begin to identify six activities that you could perform in 2017. CPIA is a new component in MIPS where clinicians will be scored on their level of engagement in activities intended to advance clinical practice, such as care coordination, shared decision making, safety checklists, and expanded access for patients.
Resource Use—0%
1. Review your Quality and Resource Use Report (QRUR) from CMS. Access your QRUR.
- You can better understand your performance on both quality and cost measures compared to other Medicare providers and consider how your practice patterns might be impacting your score. Learn more about how to understand your QRUR.
- CMS intends to use much of the same cost data it currently collects under the Physician Value Based Payment Modifier for calculating the Resource Use component score of MIPS.
- No data submission required.