The 5 FAQs That Everyone Has About MIPS

The 5 FAQs That Everyone Has About MIPS

MIPS – Merit-based Incentivized Payment Systems – is part of the CMS (Centers for Medicare & Medicaid Services) Quality Payment Program, and is designed to reward physicians and clinicians who report with quality data about patient outcomes, and other key metrics that can help determine the overall level of care for Medicare beneficiaries.

MIPS can be confusing – like many incentivized rewards programs. You’ve got questions, and we’ve got answers. In this article, we’ll take a look at the top 5 most frequently asked questions about MIPS, to help you more thoroughly understand the program.

Who Is Eligible For MIPS?

Eligible professionals for 2017 and 2018 performance years include:

  •    Physicians
  •    Physicians Assistants
  •    Nurse Practitioners
  •    Nurse Anesthetists
  •    Clinical Nurse Specialists

In 2019, more categories will be added, including:

  •    Physical/Occupational Therapists
  •    Speech/Language Pathologists
  •    Audiologists
  •    Dietitians/Nutrition Professionals
  •    Clinical Social Workers
  •    Nurse Midwives

Currently, there are three categories of healthcare providers exempt from MIPS.

  •    Providers who do not meet the “low volume threshold” of $30,000 in Medicare billings or 100 Medicare patients seen per year
  •    Providers participating in MSSP ACO and other “Alternative Payment Models” (APMs).
  •    First-year Medicare providers

Eligible professionals may choose to submit their MIPS documentation on their own or, as provisioned by MACRA, two or more physicians who share a Tax Identification Number (TIN) may submit as a group.

What Is The “Pick Your Pace” Option?

“Pick Your Pace” offers healthcare providers a way to avoid negative payment adjustments in 2017 as they ready themselves for MIPS compliance.

This can be done in one of four ways:

  •    Test – Providers will report at least one quality measure, one improvement activity, or a required ACI measure. Doing so will allow them to avoid any negative payment adjustments.
  •    Partial Participation – Providers report at least 90 days of data for more than one improvement activity, a quality measure, or more than the required ACI measures. Doing so will allow them to qualify for a small positive payment adjustment.
  •    Full Participation – If a provider chooses, they can report a full 90-day period of all required ACI measures, quality measures, and improvement activities. This will earn them the maximum chance of a moderate positive adjustment in 2019.
  •    Participate In An Advanced APM – If desired, a provider may participate in an advanced APM to be exempted from all MIPS payment adjustments.

These measures allow physicians and practices to choose how quickly they abide by MIPS regulations. If there is no time to fully adhere to the requirements they can submit partial measurements and avoid negative payment adjustments while preparing to adhere to required standards in 2018.

How Will I Be Paid?

Payments are done on a sliding scale and are budget-neutral. In 2019, physicians will be eligible for a payment adjustment of up to 4% – either positive or negative – and this number will increase to 9% in 2022.

The threshold of quality is determined by the overall performance of all participants.

  •    If a physician scores at the threshold, a neutral payment adjustment will be applied.
  •    If a physician has a final score above the threshold, a corresponding positive payment adjustment will be made on all Medicare Part B claims from the payment year.
  •    If a physician scores below the threshold, a negative payment adjustment will be applied to all Medicare Part B claims from the payment year.
  •    If a physician scores in the lowest quartile of all participants, they will receive the maximum applicable negative payment adjustment of Medicare Part B claims from the payment year.

What Is The New “Clinical Practice Improvement” Performance Category? What Does It Mean?

This performance category measures the dedication that an individual practice or clinic has, to self-improvement. The eight most common categories are:

  •    Expanded access to healthcare.
  •    Enhanced population management and monitoring of population health.
  •    Better care coordination.
  •    Higher levels of beneficiary engagement.
  •    Patient safety and practice safety assessments.
  •    Emergency response preparedness.
  •    Integrated behavioral/mental health systems.
  •    Dedication to health equity.

In the first year of the MIPS program, these CPIA activities constitute 15% of the total score of a physician or a practice.

What Are The Absolute Financial Impacts Of MIPS In Dollars?

MIPS defines an “exceptional performance bonus” for top performers that exceed the top 25% of all MIPS eligible professionals, and this payment adjustment can be as high as 10%. This national bonus pool will be set at $500M each payment year from 2019 to 2024.

Also, CMS will account for the year-over-year improvement in health care providers – if a provider does poorly but then improves about their previous metrics, they will still get credit for that improvement.

Taking into account each negative and positive performance metric, the total maximum top-to-bottom dollar variation for a healthcare provider can be up to 28.8% of the total Medicare Part B payments to the organization.

This will be the absolute financial impact of the first four years of MIPS – the most exceptional organizations will be making approximately 28.8% more than the lowest-performing organizations.

Understand MIPS – And Use It To Improve Your Practice

Whether you’re planning on only partial submission of your metrics this year, or are putting yourself on the path to total MIPS compliance, we hope this guide has helped you understand the most five frequently asked questions about this new merit-based payment initiative.