DEPARTMENTS: PRACTICE POINTS
In case you missed it, the Centers for Medicare & Medicaid Services1 updated the Merit-based Incentive Payment System (MIPS) Fact Sheets mid-May 2018. Let’s take a look at the criteria for each MIPS category. Remember, documentation details determine your dollars.
MIPS Participation Status
Includes eligible clinicians or groups who bill more than $90,000 in Medicare Part B–allowed charges for covered professional services and furnish covered professional services to more than 200 Part B–enrolled Medicare beneficiaries:
- physician assistants
- nurse practitioners
- clinical nurse specialists
- certified registered nurse anesthetists
- any clinician group that includes 1 of the professionals listed above.
You can use the Participation Status Look-up tool (www.qpp.cms.gov/participation-lookup) to verify your status.
Promoting Interoperability (PI)
This performance category promotes patient engagement and the exchange of health information using certified electronic health record technology (CEHRT). In 2018, there are 2 measure set options to report PI Objectives and Measures or 2018 PI Transition Objectives and Measures. The option you should use to send in data is based on your CEHRT edition. Here are the minimum requirements:
- use CEHRT;
- submit the performance period (a minimum of 90 consecutive days in 2018);
- submit a “yes” to the Prevention of Information Blocking Attestation and the Office of the National Coordinator Direct Review Attestation; and
- submit a “yes” for the security risk analysis measure, and at least a 1 in the numerator for the remaining base score measures or submit an exclusion for the base score measures.
Check the PI Fact Sheet to see if you qualify to have your PI score reweighted. In 2018, this performance category is worth 25% of your MIPS Final Score.
This category gauges your participation in activities that improve clinical practice, such as expanding practice access. In the 2018 performance period, MIPS-eligible clinicians can choose from 100+ activities.
For groups or virtual groups with 15 or fewer clinicians, non–patient-facing clinicians, and/or clinicians located in a rural area or Health Professional Shortage Area, each activity is weighted either medium or high. To achieve the maximum 40 points, pick 1 of these combinations:
- 1 high-weighted activity (any subcategory) or
- 2 medium-weighted activities (any subcategory).
For individuals, groups, or virtual groups with more than 15 clinicians who are not in a rural area or Health Professional Shortage Area, each activity is weighted either medium or high. To get the maximum score, pick:
- 2 high-weighted activities (any subcategory)
- 1 high-weighted activity and 2 medium-weighted activities (any subcategory)
- 4 medium-weighted activities (any subcategory)
The required performance period is at least a continuous 90-day period in 2018, up to and including the full calendar year. This category counts for 15% of a clinician’s MIPS final score, unless the clinician, group, or virtual group is subject to the Alternative Payment Model (APM) Scoring Standard.
There are more than 270 quality measures in MIPS; working with a Qualified Clinical Data Registry offers additional measures. To meet category requirements, pick at least 6 quality measures, including at least 1 outcome or high-priority measure.
You will need to report on a full 12 months of quality data for the 2018 performance period. If you are participating in an MIPS APM, you should work with your APM entity on timelines and required activities for the 2018 performance period. The weight of the quality performance category is 50% of your MIPS final score. Quality measures that can be scored against a benchmark will receive between 3 and 10 points (with exceptions).
This performance category replaces the Value-Based Payment Modifier. The cost of care will be calculated by the Centers for Medicare & Medicaid Services based on your Medicare claims. For the 2017 transition year, the cost performance category did not count toward your total MIPS score. In year 2, it does count for 10% of your total MIPS score.