The “Who, What, When, Where, Why, and How” of MIPS can be confusing.
MIPS combines several incentive reporting programs into one. The “Who, What, When, Where, Why, and How” of MIPS can be confusing.
The good news: it’s not too late to gather information and prepare for MIPS! In fact, you have time to collect enough performance data to sufficiently report for a positive payment adjustment.
Here is a summary of important information and reliable MIPS resources, as well as a checklist for what you need to do to get ready.
Who: MIPS Eligibility
You are eligible for MIPS if you bill Medicare more than $30,000 in Part B allowed charges a year and provide care for more than 100 Medicare patients a year.
If you are already in an Advanced Alternative Payment Model (APM) such as an MSSP ACO, you will most likely complete reporting through the APM. However; there are exceptions to this based on payment and patient thresholds.
By this time, providers should have received a letter from the Centers for Medicare and Medicaid Services (CMS) explaining their MIPS eligibility status. This site has more helpful information about MIPS eligibility: https://naacos.memberclicks.net/mips-eligibility-notification
If you are not meeting the requirements of MIPS through your participation in an APM, you may report as an individual or as part of a group. An individual is one NPI associated with one TIN. A group is two or more NPI’s associated with one TIN.
Groups of 25+ providers had the option of registering by June 30, 2017, to report by a submission method called a Web Interface and/or CAHPS for MIPS.
There are different submission methods and reporting periods (for example, groups of 25+ who registered will report for the entire 2017 calendar year) depending on if you report as an individual or as a group. This site provides more helpful information: https://qpp.cms.gov/mips/individual-or-group-participation
What: MIPS Scoring
MIPS reimburses providers based on a scoring system that compares the quality and cost of care to other providers. MIPS combines and replaces the three programs of PQRS, EHR Meaningful Use, and the Value-Based Modifier, and adds a new category called Clinical Practice Improvement Activities.
The four categories of MIPS are:
- Advancing Care Information (used to be Meaningful Use)
- Improvement Activities
For more information such as in the image above, check out: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Group-Participation-in-MIPS-2017.pdf
In this first year of MIPS, providers have three options for what to report:
- You can achieve a “neutral” score (no downward or upward payment adjustment) by reporting one Quality measure OR one Improvement Activity OR 4 or 5 designated Advancing Care Information measures.
- You can report for a 90-day period of 2017 for:
• 6 Quality measures (fewer if you are a specialist and only specific measure apply to your patient population)
• Improvement Activities (2 high-weighted activities, or 1 high-weighted activity and 2 medium-weighted activities, or 4 medium-weighted activities)
• Advancing Care Information measures (Security Risk Analysis, e-Prescribing, Provide Patient Access, Health Information Exchange)
• The Cost category will be automatically calculated for you in 2018
- You can report for a full year for the same measures listed above in #2.
It’s important to remember that the time period for which you are reporting (90 days or 1 full year) does not determine the payment adjustment. The payment adjustment is determined by your scores, so strategically select the time frame that maximizes your ability to accurately report for the best scores.
Want to learn more about how MIPS is scored? Check out: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/QPP-MIPS-Quality-and-Cost-Slides.pdf
Study to the test! Want to know how the test will be graded? (As in, where do I find the benchmarks that will determine how my scores will be calculated?) This site has a spreadsheet that includes the benchmarks (click on the bullet point labeled “2017 Quality Benchmarks”): https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html
When: Performance Period Timeline
The MIPS timeline includes important milestones to keep in mind. These milestones are the performance periods, reporting deadlines, and payment adjustment stages.
The first MIPS performance period is January 1, 2017 through the end of the year. You can select a 90-day period for which to report, or report for the entire year (if you’re going for a positive adjustment).
You can begin submitting for MIPS on January 1, 2018. The reporting deadline for MIPS is March 31, 2018.
The first payment adjustments based on performance go into effect on January 1, 2019.
The MIPS adjustment timeline incrementally increases the amount of positive or negative adjustments that will be applied to your reimbursements. For example, the 2017 performance year, with reporting due by March, 2018, determines the payment adjustment for 2019:
|Performance Period||Reporting Deadline||Adjustment Year||Positive or Negative Adjustment|
|CY 2017||March 31, 2018||2019||+/- 4%|
|CY 2018||March, 2019||2020||+/- 5%|
|CY 2019||March, 2020||2021||+/- 7%|
|CY 2020||March, 2021||2022||+/- 9%|
Where: Options and Methods of Submission
Where to report MIPS depends on if you are submitting as an individual or as a group. To further complicate your choices, the method of submission determines the quality measures from which you can choose and the benchmarks for each of these measures. For example, there are different measures and benchmarks for reporting by claims than for reporting by a MIPS registry.
The table below shows the options for the method(s) of submission for reporting as an individual or as a group.
|Report as an Individual
(some options vary depending on performance category)
| Report as a Group
(some options vary depending on performance category)
|Qualified Clinical Data Registry (QCDR)||Qualified Clinical Data Registry (QCDR)|
|Qualified Registry||Qualified Registry|
|Electronic Health Record (EHR)||Electronic Health Record (EHR)|
|CAHPS for MIPS Survey (only available to groups with 2 or more eligible clinicians)|
|CMS Web Interface (only available to groups with 25 or more eligible clinicians)|
This site lists all the submission method options for MIPS reporting: https://qpp.cms.gov/mips/individual-or-group-participation
Why: Reimbursement and Bonuses
An eligible MIPS provider could have their reimbursement revised upward as much as 4 percent ($400 per $10,000 of Part B revenue) in 2019. A provider who doesn’t report anything for MIPS this year (by March 31, 2018) would see an automatic 4 percent downward adjustment in 2019. These adjustments scale up +/- 9 percent by 2022.
There is more money at stake in the form of bonuses; CMS has set aside $500 million for each year between 2019 and 2024 for those who perform exceptionally well. The bonus amounts range from 0.5-10 percent depending on the provider’s score. In total, there is a potential downward adjustment of 4 percent of reimbursement in 2019, and a maximum of 14 percent upward for providers with exceptional performance.
How: MIPS Survival Guide Checklist
- Decide if you’re going to report the minimum measures to avoid the penalty, or if you’d like to go for a positive payment adjustment.
- Determine if you will be reporting MIPS as an individual, a group, or meeting the requirements through an APM. By this time, you should have received a letter from CMS explaining your MIPS status.
- Select a reporting submission method. Submission methods include: Claims, Electronic Health Record (EHR), Qualified Clinical Data Registry (QCDR), Qualified Registry, CMS Web Interface, and CAHPS for MIPS.
- Select a reporting timeframe (90 days or the full calendar year) based on the requirements of the submission method you are using.
- Select the measures for each of the categories of Quality, Improvement Activities, and Advancing Care Information that will provide you with the highest score. It is important to make sure you are selecting measures that are allowed based on the submission method you will be using.
- Review the benchmarks associated with each of the measures you selected.
- Determine if you will be reporting for bonus points, such as using end-to-end EHR reporting or submitting data for a high priority measure. This is a helpful resource with information about bonus points: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/QPP-MIPS-Quality-and-Cost-Slides.pdf
- Prepare for the future! 2017 is a “test” year for MIPS, but the stakes get higher moving forward. Create an action plan for how to track your progress on MIPS measures throughout the year.
Clinigence is a certified MIPS reporting vendor for the submission types of:
- QCDR (approval pending)
- Qualified Registry
- CMS Web Interface
- EHR end-to-end bonus points reporting
Have more questions or need more information on how to report for MIPS? Reach out to us and learn how you can succeed at MIPS reporting.