Merit-based Incentive Payment System (MIPS)
Merit-based Incentive Payment System (MIPS) - Is it too late?
By now, all medical practices should be aware of the Merit-based Incentive Payment System (MIPS). If you are not, I recommend you review the information on the Centers for Medicare and Medicaid Services (CMS) Quality Payment Program (QPP) website (https://qpp.cms.gov/). Failure of clinicians to participate in MIPS in the last quarter of 2017 will cause a payment penalty in 2019. It is quite easy to avoid this payment penalty in 2019, even starting at this late date.
For 2017 and 2018, MIPS-eligible clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and any clinician group that includes one of the listed professionals. There are several exemptions from participating in MIPS which will not be discussed in this article. If you are unsure about a clinician’s requirement to participate in MIPS, check participation status at https://qpp.cms.gov/participation-lookup.
Eligible clinicians will receive a MIPS composite score (0 – 100) based on the 2017 performance year data submitted for the following performance categories:
- Quality (weighted 60%)
- Advancing Care Information (weighted 25%)
- Improvement Activities (weighted 15%)
- Cost (weighted 0% for 2017)
Based on the MIPS score, a participant will earn either a positive payment adjustment or a negative payment adjustment on Medicare Part B payments in 2019. Below is a quick rundown of the payment adjustments:
| MIPS Composite Score | Payment Adjustment | Notes |
|---|---|---|
| 0 | -4% | Score of 0 would result if eligible clinician submits no MIPS data. |
| 3 | 0% | No payment adjustment. 3 is the minimum score for submitting any MIPS data (also called MIPS "test"). |
| 3.1 - 100 | 0 - 4% | Bonus paid out of negative payment adjustments - We expect max bonus to be less than 1%. |
| 70 -100 | max +10% | Additional “exceptional performance” bonus paid out of $500 million CMS budget. |
To be eligible for a MIPS bonus, participants must fully report quality, advancing care information and improvement activities for a minimum of ninety (90) days. The last day to begin a 90-day participation in MIPS was October 2, 2017. Eligible clinicians who have not implemented a qualifying EHR or improvement activity by October 2 will not fulfill the minimum reporting period requirements – resulting in a score of 0 for both - and a maximum MIPS composite score of 60. Depending on the MIPS quality performance scores for the 90-day period reported, a participant can expect to receive a MIPS composite score of 3 to 60. That means if a clinician has not already implemented and captured quality and advancing care information performance and implemented improvement activities, the MIPS score will be low and a bonus is less likely.
While participants may not get a bonus, a 4% payment penalty can still be avoided in 2019. For the 2017 transition year, MIPS eligible doctors and other clinicians have an option to “test”. Choosing the “test” option means that clinicians submit the minimally-required data of one quality measure, for one patient for one day, and would achieve a MIPS composite score of 3. In this scenario, clinicians do not have to submit 90 days of quality data.
Of course, clinicians can report MIPS quality data for a 90-day period and achieve a higher MIPS composite score – probably somewhere greater than 3 and less than 60. Based on what we have heard from CMS, clinicians with a MIPS composite score in this range should expect to get less than a 1% payment bonus on Medicare Part B payments in 2019.
For those practices that simply want to avoid the MIPS penalty, the easiest path is the “test” option. While this does not result in a potential bonus on your Medicare Part B payments in 2019, it does eliminate the payment penalty. We advise practices that use the “test” option to begin now preparing for the 2018 MIPS performance year.
If you have questions or would like assistance with MIPS, please contact our office at 770-951-8427.