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Understanding the Impact of MIPS in 2017 and Beyond

by Bill Finerfrock on February 13, 2017 at 3:06 PM

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As of January 1, 2017, eligible clinicians, or ECs, such as physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists can begin reporting data under Medicare’s Quality Payment Program or QPP. The QPP allows clinicians to participate in either the new Merit-based Incentive Payment System, known as MIPS, or the Advanced Alternative Payment Models or APM.

The vast majority of ECs are expected to participate in MIPS. To do this, ECs will need to report data across four categories:

  1. Quality
  2. Resource Use
  3. Advancing Care Information
  4. Clinical Practice Improvement Activities

Based on their performance under each category, ECs will receive a score known as the Composite Performance Score. Depending on the score they receive, ECs can earn a positive, negative or neutral payment adjustment to their Medicare Part B reimbursement in the corresponding payment year. As such, performance data reported in 2017will affect Medicare reimbursements in 2019.


Related:  Watch our on-demand webinar which allows you to understand more about the Merit-Based Incentive Payment System and its affect on your Medicare reimbursements.

2017: The Year for MIPS Transition

To ease the transition of ECs into MIPS, the Centers for Medicare and Medicaid Services, or CMS, has designated 2017 a transition year. For the year, CMS is allowing ECs to pick their pace for participation. This is intended to make it easier for ECs to avoid a negative payment adjustment, while also giving ECs an opportunity to test their systems and processes for an increased level of participation in the future.

In addition to reducing reporting criteria in 2017, CMS is also re-weighting the performance categories so that Resource Use will be zero percent of an EC’s MIPS score. Cost data for this category will still be obtained automatically through claims and ECs will still receive feedback on their cost performance, however it will not count towards their MIPS score in 2017. Performance data for the Quality category will count as 60 percent of an EC’s score, while Advancing Care Information and Clinical Practice Improvement Activity will count as 25 percent and 15 percent respectively.

It should be noted, hospital-based ECs can qualify for an exemption from the Advancing Care Information category because they do not have control over the technology their hospital requires them to use. For the first year, these ECs will only have to report under the Quality and Clinical Practice Improvement Activity categories. CMS has re-weighted the Quality category to 85 percent for hospital-based ECs. More information about this exemption is available on the CMS QPP website.

All ECs will be evaluated under MIPS unless they are exempt from the program, as allowed in Medicare Part B, due to falling below the low-volume threshold of $30,000 in revenue (Medicare allowed charges) or having fewer than 100 Medicare patients. ECs are also exempt from MIPS if they qualify as partial or full Advanced APM participants by meeting specified revenue or patient targets. While those who qualify as full Advanced APM participants in 2017 can earn a five percent lump sum bonus in 2019, it is important to verify whether you meet the APM or MIPS reporting requirements.

Under MIPS, ECs that report any amount of Quality and Clinical Practice Improvement Activity data for any period of time in 2017 will avoid a negative payment adjustment. ECs that report under all performance categories for a period of 90 consecutive days will be eligible for a small payment adjustment. ECs that report under all categories for the full 2017 performance year will be eligible for the maximum positive adjustment of four percent on their Medicare Part B revenue in 2019. Finally, ECs that do not report any MIPS data will automatically receive a four percent negative payment adjustment in 2019.

Additional information about how to report performance data can be obtained through the CMS QPP Website.

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This post was written by Bill Finerfrock

Bill Finerfrock is a consultant at Intermedix and is president of Capitol Associates (CAI). Finerfrock specializes in health care financing, health systems reform, health workforce and rural health. Finerfrock has worked in and with the U.S. Congress and Federal agencies on health policy matters for nearly 40 years