CMS rolled out the new Merit-based Incentive Payment System (MIPS) in 2017. MIPS took the previous programs known as Meaningful Use, Physician Quality Reporting System (PQRS) and the Value Based Payment Modifier and combined them under one program. Due to the fact that the final rule for 2017 was released so late in 2016, CMS offered providers a lot of flexibility in how they reported during their first year. As long as providers submitted some data in 2017 they avoided the -4% payment adjustment in 2019.
Many providers did the bare minimum for MIPS in 2017 due to the flexibility offered by CMS. Now that the transition year has ended, CMS is removing some of the previously offered flexibility for 2018. Providers who adapt to these programs early have the greatest chance of getting the highest incentive payments available each year. CMS will continue to ramp up the requirements under this program so it is important that providers start implementing these processes into their everyday practice now.
Here are some of the changes that were made to the program for 2018:
Low Volume Threshold: In 2018 a provider will be excluded from participation if they have $90,000 or less in Medicare Part B allowed charges OR see 200 or less Part B beneficiaries.
Reporting Periods: Quality and Cost will be scored based on a full year performance period. Advancing Care Information and Improvement Activities will be a 90 day performance period.
Performance Threshold: The minimum score needed to avoid the penalty for 2018 is 15 points, up from 3 points in 2017.
Payment Adjustment: The adjustment for 2018 ranges from a -5% negative payment adjustment up to a 5% positive payment adjustment based on the provider’s performance.
Quality (50%): The Quality category is now worth 50% of the total MIPS score, down from 60% in 2017. The data completeness standard for providers to earn more than the minimum amount of points increase to 60%, whereas in 2017 the standard was 50%. There are 7 topped out measures that will only be eligible for a maximum of 7 points instead of 10.
Improvement Activities (15%): CMS has added approximately 20 new activities for 2018. There have been some modifications to existing improvement activities, so you should double check the requirements for any improvement activities that you plan to continue into 2018.
Advancing Care Information (25%): CMS will continue to allow providers to use either 2014 or 2015 Certified EHR Technology (CEHRT) in 2018, but there will be a 10% bonus available to providers who use 2015 CEHRT exclusively. CMS also increased the number of Improvement Activities that qualify for the provider to receive an additional 10% bonus for choosing an activity that involves CEHRT. Providers can also earn an additional 5% bonus for submitting to an additional public health agency or clinical data registry not reported under the performance score. CMS also created exclusions for the E-Prescribing and Health Information Exchange required measures.
Cost (10%): This category will be comprised of the Medicare Spending Per Beneficiary (MSPB) and Total Per Capita Cost Measures found in the Quality Resource and Utilization Report (QRUR).
Complex Patients Bonus: Providers can receive up to a 5 bonus points for treating complex patients. CMS will determine complexity by looking at a combination of the Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated by the provider.
Small Practice Bonus: MIPS eligible providers who are in a group with 15 or fewer eligible clinicians (whether they report individually or as a group) will earn an additional 5 points as long as they submit data on at least 1 performance category during the performance period.
