This year, the Merit-based Incentive Program (MIPS) is in full swing. Under the program, clinicians must report on four areas of improvement activities. Clinicians who succeed in following the program guidelines are eligible for reimbursement increases from CMS. Clinicians who fail to achieve the minimum required reporting could be penalized.
MIPS is a very complicated program, and many physicians are still confused about how and when to participate. Plus, there are many exceptions to eligibility. In 2017, nearly two-thirds of Medicare doctors were exempt.
This year, MIPS continues to push forward, and CMS is dedicated to the success of the program. With each passing year, it’s likely that more and more physicians will be eligible for and required to participate in MIPS.
If your practice has a qualifying Medicare patient population, it’s important to understand these realities:
Advancing Care Initiatives (ACI) is now Promoting Interoperability (PI)
Last year, one of the reporting categories was called “Advancing Care Information.” This year, it’s called “Promoting Interoperability Requirements.” This change is in name only – nothing else changes about this category, though future rules could change that.
Why the name change? Essentially, CMS wants to maintain alignment across all programs. CMS is committed to improving interoperability and patient access to personal health data. The name change makes this very clear.
The 2018 MIPS requirements for PI are the same as the 2017 requirements for ACI. They account for 25 percent of the final score and fall under two categories:
- Promoting interoperability objectives and measures.
- Promoting interoperability transition objectives and measures.
Practices with a CEHRT certified for the 2014 edition must use the second category. Otherwise, practices can choose one or the other, as well as a mix of both. Clinicians and groups experiencing a hardship – such as a lack of control over available CEHRT – can apply for an exemption from PI requirements. Likewise, groups participating in APM may have other options available to them.
In general, practices are required to submit data for four or five base score measures for 90 days or more. Clinicians may be able to earn bonus percentage points for submitting data to more than one clinical data registry, submitting more than one CEHRT improvement activity or only using the 2015 edition CEHRT for a single PI category.
Year 3 proposals could change MIPS
Last year, CMS warned the medical community that 2018 would be the first year of full program implementation. However, CMS has since extended the transition period for another three years. The hope is that this period will give providers enough time to fully participate and thus reduce administrative burdens. In the meantime, clinicians that already have their ducks in a row stand to gain significant financial incentives.
Here are the most important takeaways from the recent proposal:
CMS may extend the program to new types of clinicians, including psychologists, social workers, physical therapists and occupational therapists.
The proposal also seeks to add another element to the MIPS low-volume threshold. Essentially, the new rule would exempt providers with 200 or fewer Medicare beneficiaries, $90,000 or less in Medicare Part B charges and 200 or fewer covered professional services.
Help for small practices
The new rule proposes to move the small practice bonus from a stand-alone category to the quality performance score. Doing so could further reduce administrative burden by giving small practices a slight advantage as they transition to the value-based care model. Furthermore, CMS will award small practices with three points for quality measures that do not meet data completeness requirements.
Changing the name of the Promoting Interoperability category isn’t the only language change providers can expect to see. In order to make terms more clear, CMS has proposed the following three-term additions:
- Collection type: “A set of quality measures with comparable specifications and data completeness criteria including, as applicable: electronic clinical quality measures (eCQMs); MIPS clinical quality measures (CQMs); Qualified Clinical Data Registry (QCDR) measures; Medicare Part B claims measures; CMS Web Interface measures; the CAHPS for MIPS survey measure; and administrative claims measures.”
- Submitter type: “The MIPS eligible clinician, group, or third party intermediary acting on behalf of a MIPS eligible clinician or group, as applicable, that submits data on measures and activities.”
- Submission type: “The mechanism by which the submitter type submits data to CMS, including, as applicable: direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web Interface. There is no submission type for cost data because the data is only submitted for payment purposes.”
Reduced administrative burden
In 2017, the American Medical Association sent a letter to CMS asking the agency to simplify Quality Payment Program regulations. One of the reasons for this request was the extreme burden physicians felt as they tried to get their practices compliant with the complex rules.
“Many proposed changes seek to reduce administrative burdens on doctors.”
This year, CMS is attempting to do so by adding eight episode-based measures to the cost performance category. Likewise, the case minimum for procedural episodes would be reduced to 10, and the minimum for acute inpatient medical condition episodes would be reduced to 20.
According to CMS, Procedural episodes will be attributed to MIPS-eligible clinicians who render a trigger service as identified by HCPCS/CPT procedure codes. Acute inpatient medical condition episodes will be attributed to MIPS-eligible clinicians who bill E&M claim lines during a trigger inpatient hospitalization under a TIN that renders at least 30 percent of the inpatient E&M claim lines in that hospitalization.
CMS is accepting comments on the proposed changes until Sept. 10, 2018.
MIPS compliance is made easy with agile analytics
To achieve maximum incentives, clinicians need technology that can respond to program changes at the drop of a hat. A dependable solution gives providers complete control over their data, so they don’t have to worry about whether their ACO is reporting on the correct information.
Advanced analytics give providers detailed insights into their entire patient population, allowing them to meet measures with accuracy. Plus, analytics can improve operations by displaying payer mixes, E&M statistics and basic financial measures. Any clinician transitioning to a value-based care program needs this level of granularity.
To learn more, contact the experts at Tangible Solutions today.