What is MIPS?
The Centers for Medicare & Medicaid Services (CMS) rewards (or penalizes) clinicians or groups who see Medicare Part B beneficiaries based on quality of care, cost efficiency, and patient outcomes. CMS does this through their payment incentive program known as the Quality Payment Program (QPP).
The Merit-based Incentive Payment System (MIPS) is the more common reporting path of two reporting options offered to clinicians and groups under the QPP.
MIPS is the new comprehensive reporting standard that combines elements of and replaces the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VBM), and the Medicare Electronic Health Records Incentive Program for Eligible Clinicians.
participate in MIPS?
If you are one of the following clinician types:
- Physicians (including doctors of medicine, doctors of osteopathy, osteopathic practitioners, doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors)
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Groups or virtual groups that include one or more of the clinician types above
And you meet or exceed the following billing and patient volume thresholds:
- Clinicians or groups with allowed annual Medicare Part B charges over $90,000 in Physical Fee Schedule (PFS)
- See more than 200 Medicare Part B beneficiaries during a calendar year.
How does MIPS work?
Your final score, which determines your payment adjustment, is made up of four performance categories, each with their own weight:
This category is about the quality of care you and/or your group delivers to your patients. This category replaces the Physician Quality Reporting System (PQRS).
Most participants will report at least 6 quality measures, including an outcome measure. There are more than 270 possible measures in this category.
2. Promoting Interoperability (PI) – NEW IN 2018
This category promotes both patient engagement and the productive use of the healthcare information you create utilizing certified electornic health record technology (CEHRT). For 2018, Certified EHR Technology use is required for this category unless you are eligible for a hardship exemption. This category replaces the Medicare EHR Incentive Program, also referred to as Meaningful Use and was formally known in 2017 MIPS as Advancing Care Information (ACI).
There are 2 measure sets for submitting data for this category:
- Promoting Interoperability Objectives and Measures
- Promoting Interoperability Transition Objectives and Measures.
Your Base Score for this category requires you to report 4 or 5 performance measures (which are dependent on your CEHRT Edition) for 90 days or more during 2018 – this is required in order to be able to earn Performance or Bonus points for this category.
In addition to submitting the Base Score measures, participants must attest to two statements when submitting: “Prevention of Information Blocking Attestation,” and “ONC Direct Review Attestation.”
For additional points, you can report on up to 9 performance score measures (or 7 Performance Score measures if you choose the PI Transition Objectives and Measures set).
Bonus points are available for this category depending on your use of public health and clinical data measures as well as use of Certified EHR Technology to complete activities in the IA performance category. You can earn an additional bonus percentage point by submitting only PI Objectives & Measures Set (and only using 2015 edition CEHRT).
We review your data for compliance, suggest optimizations, and can help you with earning bonus points for extra measure reporting.
3. Improvement Activities (IA)
This category shows CMS, activities you’ve undertaken to improve your care processes, patient engagement, and increase access to your care. This is a new category added in 2017.
Most participants will attest to completing up to 4 activities during the course of a calendar year. Depending on your practice type, you may be eligible for full credit for this category automatically.
We review your data for compliance and make sure that the IAs you’ve chosen are compatible with QPP’s requirements for this category.
This category is calculated by CMS based on your Medicare claims over the course of the calendar year. This category replaces the Value Based Modifier (VBM). 2018 is the first year this category counts towards your MIPS final score.
Through very timely (weekly or monthly) analysis of Medicare claims costs with comparison against national benchmarks, we help you understand and address the Cost performance category.
At a federal level MIPS must be budget neutral, meaning all of the incentives must be covered by penalties. Thus, if your organization does not successfully implement a MIPS strategy, the penalties you incur may be distributed as bonuses to competitors.
Penalties adjustments grow by the year as follows:
- 2019 – 4%
- 2020 – 5%
- 2021 – 7%
- 2022 and after – 9%
Individual, Group, & Virtual Group Reporting
Participants in MIPS may report as individuals or as a member of a group. In 2018, clinicians have the additional option of participating in a virtual group.
If you report MIPS data in as an individual, your payment adjustment will be based only on your performance. An individual is defined as a single NPI tied to a single TIN.
If you report MIPS data with a group, your payment adjustment is based on the group’s performance. A group is defined as a set of clinicians – identified by their National Provider Identifier (NPI) – sharing a common Taxpayer Identification Number (TIN), no matter the specialty or practice site.
Virtual Group – NEW IN 2018
A Virtual Group is a combination of two or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter specialty or location) to participate in MIPS for a performance period of a year.
To be eligible to submit as a Virtual Group in the 2019 performance year, all groups need have received CMS approval prior to close of business on December 31, 2018.
What is the MIPS reporting deadline?
The MIPS Performance Year follows a standard calendar year starting on January 1 and ending on December 31. MIPS participants must submit their calendar year’s worth of data by March 31 of the following calendar year.