CMS reports that for 2017, just over 90% of eligible clinicians participated in the Quality Payment Program (QPP). That number is impressive, but what about the nearly 10% who declined to participate? Many adopted a “wait-and-see” approach, or were concerned that the required investment of time, money, and effort wasn’t worth the reward. But the QPP is here to stay, and some physicians may only now be wondering where to start, or even whether they can succeed at all after avoiding it for so long.
If you find yourself among that number, don’t worry, because it’s not too late! This week we’re laying out the first things you should know, and the first steps to take.
In 2015, Congress passed a bill called the Medicare Access and CHIP Reauthorization Act (MACRA), which created the Quality Payment Program. The QPP combines earlier reporting programs--such as PQRS, Meaningful Use, and Value-Based Modifiers--into one program with two tracks: Track 1, the Merit-Based Incentive Payment System (MIPS); or Track 2, the Advanced Alternative Payment Model System (AAPM).
Am I Eligible?
During the 2018 performance year, the pool of eligible clinicians excludes some specialties that were previously included in Medicare quality reporting initiatives like PQRS and MU. However, any clinician that bills Medicare Part B is encouraged to report.
In 2019 the pool of eligible clinicians expands to include additional professions.
What Do I Have To Do?
Those eligible for MIPS report performance across four categories:
Quality: This category, closely related to PQRS, requires participants to report 6 measures (one of which is an outcome measure) over a full calendar year for at least 60% of the applicable patient visits.
Promoting Interoperability: This category is Meaningful Use updated to be more flexible, customizable, and focused on patient engagement and interoperability. To receive credit in PI, participants must attest to all base score PI measures. Full credit will only be awarded to participants who also report performance score measures in addition to base score measures.
Improvement Activities: This is a new concept introduced by MIPS and rewards participation in activities related to your patient population.
Cost: 2018 is the first performance year that Cost will be a weighted category for participant's MIPS final score. This will be the average performance score for the Medicare Spending Per Beneficiary (MSPB) measure and the Total per Capita Cost measure. Both Cost measures are automatically captured through administrative claims.
Why Does This Matter?
The performance in each MIPS category can have serious impact on revenue. For the performance year 2018 non-participating eligible clinicians will see an automatic -5% adjustment on their Medicare reimbursements. The cost of not participating in MIPS increases each year and reaches a maximum of -/+ 9% for performance year 2020.Additionally, the top performing professionals are eligible for bonus reimbursements of 25% in the 2018 performance year and up to 37% for performance year 2020.
In addition to impacting eligible clinicians financially, MIPS performance has the potential to affect the reputation of eligible clinicians and groups. Scores will be publicly posted to Physician Compare as soon as the informal review period closes following each performance year.
Do I have To Participate Fully This Year?
To ease the burden of transitioning to MACRA, CMS is providing pacing options for transition year performance. The options for 2018 are slightly more intensive compared to the options available for the 2017 transition year.
0% - 14%: -5% Penalty in 2020 - Not participating in the Quality Payment Program or a low MIPS final score in 2018 will result in a -5% penalty. This is slightly more intensive than in 2017, with the performance threshold raising from 3% to 15%.
15% - 69%: Positive Payment Adjustment in 2020 - Achieving a moderate MIPS final score in 2018 will provide penalty avoidance and maybe a slight incentive.
70% - 100%: Positive Payment Adjustment in 2020 & Possible Exceptional Performance Bonus - High performance will award the 5% incentive and potentially an exceptional performance bonus.
RELATED: Webinar: Navigating MIPS in 2018
Although Medicare quality reporting is complicated, MIPSPRO makes the reporting process easy with an intuitive system and a quality reporting team to guide you through the MIPS reporting process. MIPSPRO provides key features like real-time dashboards; MIPS Quality, PI (formerly ACI), IA, & Cost for all specialties and all measures; choose-your-pace for reporting; integrated data; and data validation and support. Start today!