Merit-Based Incentive Payment System (MIPS)

Reporting for 2017 — Pick Your Pace Options and AGA Quality Measures and Improvement Activities

For performance year 2017, if a CMS eligible clinician (EC) chooses the Pick Your Pace option for the MIPS path of the Quality Payment Program (QPP), there are three reporting options — test, partial or full. If you choose not to participate in the QPP and don’t send data, then you receive a negative 4 percent payment adjustment in 2019. Check your QPP status by using your NPI number.

 

MIPS 2019 Pick Your Pace Payment Adjustments

The MIPS 2019 payment adjustment is based on performance data submitted in 2017. Generally, the maximum MIPS payment adjustment can be achieved by participating in the QPP for a full year. However, you may still earn the maximum adjustment if you report for less than a full year, but at least 90 days – there are no penalties or score reductions if you only report 90 days. Your score will depend on the measure(s) you select.
 

Pick the Pace That’s Best for Your Practice

Pick Your Pace reporting mechanisms for quality and improvement activities include:
  • Qualified registries.
  • Electronic health records (EHRs).
  • Qualified clinical data registries (QCDRs).
  • CMS web Interface (for groups of 25 or more).
  • An attestation portal. 
Selecting the most appropriate reporting mechanism is typically based on the type and size of your practice and your practice’s health IT capabilities.
 

Improvement Activity Attestation

If you report participation in at least one improvement activity, this will allow you to avoid a penalty in 2019, based on 2017 performance.
 
AGA is promoting several MIPS-eligible Improvement Activities (IA) to assist GIs in identifying appropriate and practice-relevant Improvement Activities to meet Pick Your Pace requirements. If you downloaded and used at least one of these IAs (or any other CMS-approved IA) in 2017 and attest to your participation by Mar. 31, 2018, you will avoid a 2019 payment penalty.  
 
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After downloading and actively participating in an improvement activity, you will be able to attest to the fact you have met the 2017 MIPS Improvement Activity requirement. CMS will release its attestation website around Jan. 1, 2018.
 

Snapshot

The Merit-Based Incentive Payment System (MIPS) is a path proposed by CMS under the Quality Payment Program (QPP) to determine physician reimbursement beginning in 2019. CMS has designated 2017 a “transition year” to allow providers to learn about MACRA and test their preparedness. The only providers who will experience a -4 percent payment penalty in 2019 are those who do not report any performance data. Therefore, it is important to understand MIPS requirements and start making decisions now in 2017 to avoid the penalty in 2019 and prepare for full participation in the MIPS program. The services you provide in 2018 could negatively impact your Medicare reimbursement in 2020.

In 2017, the quality category accounts for 60 percent of your total MIPS score. Physicians can take steps to guarantee a favorable quality score, while also positioning themselves for long-term success by addressing cost.

Financial Impact

  • MIPS works on a two-year cycle. Participants will eventually be subject to reimbursement adjustments — positive or negative — of up to 9 percent beginning in 2022 (for services provided in 2020). However, there is a transition period during which the maximum adjustment will be phased in. 
    • 4 percent in 2019, for services in 2017.
    • 5 percent in 2020, for services in 2018.
    • 7 percent in 2021, for services in 2019.  

Background

The new program, which uses quality and cost data to determine your payment, replaces the existing framework that includes the Medicare EHR Incentive Program, the Physician Quality Reporting System and the Value-Based Payment Modifier program.  Physicians participating in MIPS will be scored on four categories: 

  1. Quality. 
  2. Advancing care information (ACI).
  3. Improvement activities (CPIA).
  4. Cost.

Keep in mind, while quality is by far the largest single factor in your 2019 reimbursement, this will gradually change. The quality category will be reduced to 30 percent of your MIPS score beginning in 2019 for reimbursement in 2021 and will then receive the same amount of consideration as cost and resource use.

September 2017