Thinking about MIPS & Quality Measures?

34% of Clinicians are accountable for MIPS – You’re not alone.

Thinking about MIPS?  You’re not alone.  The Merit-based Incentive Payment System (MIPS) phenomenon is significant in terms of the number of providers who will be contemplating a strategy.  Putting MIPS into perspective, consider that approximately 34% of clinicians in the U.S. will be held accountable for MIPS reporting, and 66% will be exempt.  This pans out to be roughly 419,000 clinicians participating in MIPS, and 807,000 not participating.  In comparison to the number of clinicians participating in Advanced Alternative Payment Models (APMs), nine providers will be participating in MIPS for every one provider in an Advanced APM (an APM such as a track 2 or 3 MSSP ACO, PCMH CPC+, or a bundled payment program).

By this time, health systems and providers have received a letter from the Centers for Medicare and Medicaid Services (CMS) declaring whether or not they will be eligible to report MIPS in the spring of 2018.  MIPS includes providers with over 100 Medicare patients and greater than $30,000 of Medicare Part B services billed last year (unless 2017 was their first year of billing Medicare, or they joined an Advanced Alternative Payment Model program). In year one of the program, +/- 4% of 2019 Medicare charges are at stake.

As often happens in health care – and human nature – speculation among the 419,000 MIPS clinicians about how to manage the reporting process with the least amount of effort is taking place. This is especially applicable in year one of MIPS, because the 4% penalty can be avoided by simply reporting any of these: one quality measure, one improvement activity, or four to five Advancing Care Information (MU) measures.

On the other side of the ledger, a positive adjustment can be accomplished in one of two ways: report the required MIPS measure data for a 90-day period, or report the required MIPS data for all of calendar year 2017. For providers with a significant portion of their revenue resulting from charges to Medicare, it would be worthwhile to obtain a positive payment adjustment by achievement of the highest score.  Thus, the value of reporting for all six MIPS quality measures, which make up 60% of the score, is an important consideration.

Required to report on 6 measures in the quality category

There are four reporting categories for MIPS:

  • Quality (6 measures, 60% of score)
  • Advancing Care Information (replaces MU, 25% of score)
  • Improvement Activities (combination of high weight activities worth 20 points each and medium weight activities worth 10 points each, 60 points needed, 15% of score)
  • Resource (this represents costs calculated by CMS, 0% of score in year one, pending determination by CMS in future years).

In terms of the number of MIPS quality measures, it’s important to note that most of the 419,000 MIPS-eligible clinicians will be required to report on 6 measures in the quality category.  The exceptions to this are groups of 25 or more providers who are using the web interface for reporting (they must report on 15 quality measures), and specialty providers selecting from specific measure sets that may have fewer than 6 applicable measures.

Six things to consider if you are aiming for high scores

If obtaining a high score in the MIPS quality category is on your radar, these are some important things to consider:

  1. Scores matter, the time-frame does not.  Whether you report for 90 days or one full year, it is the score that determines a payment adjustment.  The advantages of reporting for an entire year are that you have more measures to choose from, more reliable data submissions, and the ability to get bonus points.  Thus, select a timeframe that maximizes your ability to achieve the highest score.
  2. Select measures that don’t require “100%” to get the maximum 10 points.  These are called “topped out” measures because it’s easy for many providers to achieve 100% compliance on them.  Therefore; anything under 100% is going to fall short of the benchmark.
  3. Select measures that are not so unique that it’s unlikely the minimum number of providers will report them in order to generate a reliable benchmark score.  A reliable score means there is sufficient case volume (>=20 cases for most measures; >=200 cases for readmissions) and at least 50 percent of possible data is submitted.  If a measure cannot be reliably scored against a benchmark, then the clinician receives only 3 points.  This is also an example of why reporting for a full year versus 90 days would be strategic.  The data submitted for a full year of reporting is more likely to result in sufficient case volume.
  4. Be sure to select and report one outcome measure or one high-priority measure as one of the six measures.  This is required to be eligible for the maximum payment adjustment.
  5. Select the reporting method that provides you with the greatest numbers of measures from which to choose, and benchmarks that are more likely for you to achieve.  This is important because there are separate measures and benchmarks for the different reporting mechanisms of EHR, QCDR/registries, claims, CMS Web Interface, administrative claim measures, and CAHPS for MIPS.
  6. Go for the bonus points.  In the Quality category, there are two bonus points for each additional outcome and patient experience measure, and one bonus point for each additional high-priority measure.  The combined total of maximum bonus points for reporting these extra measures is 6 points.  Also, if you use Certified Electronic Health Record Technology (CEHRT) to report electronically, you will receive an additional one bonus point per measure.

As a CMS-approved qualified registry, we hear many commentaries from health systems and providers about the challenges and opportunities of reporting for clinical quality measures.  We are a MIPS partner that simplifies the reporting process and maximizes your scores.  If MIPS reporting is among your projects, contact us to learn more about how we ensure reporting success.