How to Profit From MIPS, Explained in Plain English

Elizabeth W. Woodcock, MBA, FACMPE, CPC

Disclosures

September 06, 2017

In This Article

Learning the Best Ways to Earn

The Merit-based Incentive Payment System (MIPS) has made many doctors frustrated and others confused.

The program does have complexities: For example, you could earn a different number of points depending whether you've submitted your data via an electronic health record (EHR) or whether they are extracted through your claims. Or as another example, different quality measures that you report may not be able to be reported the same way. And to top that off, it's possible that even if you choose the way you want to report, your office system doesn't have the functionality.

Those are some of the issues that physicians are wrestling with. Let's take a look at these issues and gain a better understanding of what you need to do.

The Physician Quality Reporting System (PQRS) was retired December 31, 2016, but that doesn't mean the end of Medicare's quality reporting. In fact, the replacement program expands the breadth and specificity of quality reporting requirements.

Formulated by 2015's Medicare Access and CHIP Reauthorization Act, the Quality Payment Program (QPP) requires time and effort, but may lead to increased business opportunities for practices.

QPP maintains two tracks: participating in MIPS or joining an advanced alternative payment model (APM). Each track features quality measures. The vast majority of physicians will participate in the program via MIPS. The other track—APM—also features quality reporting.

If you're part of an accountable care organization (ACO), you have different reporting requirements. Check with your ACO administration to understand what's being measured.

How MIPS Quality Measures Work

Like PQRS, MIPS presents physicians and other eligible clinicians with quality measures—271, to be exact. The program requires you to report on six measures, one or more of which must be a measure of outcomes, although you can use one designated as "high priority" if an outcomes measure is not applicable. Sixty percent of your total score comes from the quality category in performance year 2017, rounded out by 15% related to improvement activities and the remaining 25% scored on the basis of advancing care information (ACI). ACI was previously the EHR Incentive Program (meaningful use).

Knowing that this is a tough transition for many physicians, the Centers for Medicare & Medicaid Services (CMS) has eased up on this year's requirements. During this initial performance year, the federal government is accepting a single measure as a flexible reporting option for 2017. Taking advantage of this "pick-your-pace" program by submitting one quality measure—or an improvement activity, or the base ACI measures—will relieve you of the 4% penalty scheduled to be imposed in 2019.

For physicians who want to earn the so-called "exceptional performance bonus," in which you can get up to 12% applied to your Medicare reimbursement in the initial adjustment year, a minimum of 70 points are required for consideration. This exceptional performance bonus rises to 15% in 2020, 21% in 2021, and 27% in 2022 and thereafter. These amounts are significant! Therefore, 70 points may be well worth aiming for.

Even though MIPS measures may look similar to those put forth by PQRS, the new program has some distinct differences.

Several Ways to Report Your Data

Each of the 271 measures has an assigned reporting method, and many have more than one. The accepted ways to report it include an EHR, a qualified registry from an approved vendor, a Qualified Clinical Data Registry (QCDR), and claims. The quality measures must be reported via the same method.

So if you choose to report via registry, all of the measures you submit need to be transmitted through the registry. Each measure has a specific reporting method or methods attached, and you want to make sure to report it as required. And when you're selecting measures, be aware that the selected six measures must all be reported by the same method.

Given this restriction, it's very important to decide which measures you want to report—and then look for the transmission method that would accommodate at least six measures. Or choose a reporting method, and then select the quality measures that are best for you.

Before you make the final decision, however, there's one more important step when it comes to reporting. Once you narrow your desired quality measures and reporting methodology, you'll need to determine whether your office's internal functionality can support your choice. Your EHR system, for example, may not be able to transmit quality measures for MIPS.

Likewise, your EHR may have the functionality available, but may require you to pay for an upgrade. If the functionality doesn't exist—even at a price—your vendor may direct you to a data extractor. These are vendors who "sit on top" of an EHR, extracting and reporting data on your behalf.

If you choose a registry, determine the price and availability, as well as which measures the registry offers. Many registries only offer only a selection of measures, often geared toward a specific specialty.

Once you have your measures and reporting methodology set, it's vital to recognize which patients qualify for reporting. All patients—not just those covered by Medicare—must be considered when reporting on the basis of EHR, registry, and QCDR. These popular reporting methods feature a requirement to report all patients who meet the criteria for a measure's denominator.

Keep in mind that registry-based reporting under MIPS involves reporting at least 50% of all patients (regardless of payer) who are eligible for the selected measure. PQRS, in contrast, required only a small fraction of your patients—for example, 20 records for registry-based reporting.

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