Compliance

Get a grip on MIPS

The program is scheduled to go into effect on Jan. 1.

BY LISA SHAW, COE, NCP, EPM/HER

In April 2015, the Medicare Access and CHIP Reauthorization, or MACRA, was signed into law. This law establishes Merit-Based Incentive Program, or MIPS. Here, I outline and discuss the recently released final rule.

Categories of reporting

The MIPS rule defines four distinct categories of reporting. These categories will replace the PQRS, VBM, and MU programs and also add a new category. CMS will assign a single overall composite score from 0 to 100 based on performance in each of the categories. For 2017 reporting (2019 payment year), adjustments will not be based on a practice score, but on which reporting method you choose (outlined later). In 2018 and beyond, depending on where your score falls, you will be subject to a negative, neutral, or positive payment adjustment.

The four proposed categories are:

1. Quality (60% of score in 2017). This will replace PQRS. The proposed rule requires reporting on only six measures, including one outcome measure, as opposed to PQRS, which requires nine.

2. Resource use (0% of score in 2017). This category will not be used in scoring for the initial year of MIPS in 2017. There is no reporting requirement for providers for this category; CMS will derive that data from claims.

3. Improvement Activities (15% of score in 2017). This new category will provide over 90 activities to choose from. Each of the activities is weighted with differing scores for high-weighted and medium-weighted activities. Practices with fewer than 15 providers will earn double points for each activity.

4. Advancing Care Information (25% of score in 2017). This will replace the MU program. Providers submitting data for required measures will receive a base score of 50% and can earn additional percentage points for performance in these measures.

Payments

As with previous Medicare quality initiatives, the performance year and payment year are two years apart. For instance, reporting year 2017 will impact payment year 2019.

The program starts at a ±4% payment adjustment in 2019, and will increase to a ±9% adjustment in 2022, with an additional increase for exceptional performers.

Timelines

MIPS is scheduled to take effect Jan. 1, 2017, which will give providers little time to fully understand and implement. However, CMS allows flexibility. Providers can choose one of the following options.

1. To avoid a penalty for 2019, providers can choose one of these actions:

2. To be eligible to receive a small bonus, providers can choose one of the following and report for 90 days:

3. To be eligible for a larger bonus, providers can choose to report for a 90-day period or a full year but must meet all the measures and benchmarking thresholds in all categories.

4. APM. Providers who participate are not required to submit MIPS data. OP

1. • Report one quality measure for one patient in which the practice does not have to meet the benchmark.

   • Report on one improvement activity.

   • Report on the base measures for Advancing Care Information.

   • Report on two or more quality measures in which the practice does not have to meet the benchmark.

   • Report on two or more Improvement Activities.

   • Report on the required measures for Advancing Care Information plus an additional performance measure.

Ms Shaw is the IT manager for Laurel Eye Clinic in western and central PA. She manages participation in PQRS, MU, and MIPS, while managing computer security and maintenance as well as the systems that collect and store patient information.