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Quality & Practice

Merit-Based Incentive Payment System (MIPS)


Within the Quality Payment Program, there are 2 paths providers can choose and use to report quality data:

 

The Merit-Based Incentive Payment System (MIPS) is the program that will determine Medicare payment adjustments. Using a composite performance score, eligible clinicians (ECs) may receive a payment bonus, a payment penalty, or no payment adjustment.

MIPS streamlines 3 currently independent programs to work as one:

  1. Electronic Health Record Incentive Program/Meaningful Use (MU)
  2. Physician Quality Reporting System (PQRS)
  3. Value-Based Modifier (VBM) 

MIPS also adds a fourth component, Improvement Activities (IA), to promote ongoing improvement and innovation. This new program will ease clinician burden and allow clinicians to choose the activities and measures that are most meaningful to their practice to demonstrate performance. 

The performance year for MIPS will begin in 2018, making 2020 the year any adjustments in payments will be made. 2018 reporting closes on March 31, 2019. MIPS reporting can be submitted to CMS through AAPM&R's Registry.

 

Who is eligible for MIPS?

mips eligible

What are exclusions from MIPS?

There are 3 exclusions of providers from MIPS eligibility:

  1. Providers participating in an APM, as defined by MACRA, are not subject to MIPS.
  2. Low Volume Threshold: Clinicians who bill less than $90,000 in Medicare beneficiaries in a designated period OR provide care for less than 200 Medicare patients a year are exempt from MIPS. CMS will conduct low-volume status determinations prior to and during the performance period using claims data. 
  3. New Medicare-enrolled Eligible Clinicians: Providers who enroll in Medicare for the first time during a performance year are exempt from MIPS until the next subsequent performance year. 

 

4 Basic Paths to Avoid a MIPS Penalty in 2018

For more information on the below pathways, read this article from The Physiatrist.

Path 1: Fully report under the Quality Category

  • Report 6 measures, including 1 outcome measure (or a high priority measure if an outcome measure is not available) with at least 60% data completeness.
  • A minimum of 3 points on each measure will allow you to avoid a negative adjustment.

Path 2: Fully report under the Improvement Activities Category

  • Small, rural, Health Provider Shortage Areas (HPSA) practices: Attest to at least 1 high-weighted or 2 medium-weighted activities.
  • Other practices: Attest to 2 high-weighted activities, 4 medium-weighted activities, or 1 high and 2 medium-weighted activities.
  • You must complete each Improvement Activity for at least 90 consecutive days.

Path 3: Combined reporting under the Quality and Improvement Activities Categories

  • Report 3 measures under the quality category with at least 60% data completeness AND report 1 high-weighted or 2 medium-weighted improvement activities.
  • A minimum of 3 points on 3 quality measures plus half credit in the Improvement Activity Category will allow you to avoid a negative adjustment. 

Path 4: For clinicians who qualify for 0% weighting of the Advancing Care Information (ACI) Category

  • If you qualify for 0% weighting of the Advancing Care Information Category, the weight of the quality category will increase. Therefore, you can report on 4 measures with at least 60% data completeness.
  • A minimum of 3 points on 4 quality measures (when the quality category has a higher weight of 75%) will allow you to avoid a negative adjustment.