What type of clinicians does MIPS apply to?
For performance years 2017 and 2018: MIPS applies to Medicare part B clinicians including Physicians (MD/DO and DMD/DDS), Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists.
For performance year 2019: MIPS will be applicable to Physical and Occupational Therapists, Speech-language Pathologists, Audiologists, Nurse Midwives, Clinical Social Workers, Clinical Psychologists, and Dietitians/Nutritional professionals.
Who is eligible for MIPS?
You can check your unique eligibility requirements on www.qpp.gov using your individual NPI. You need to have billed at least $90,000 in Medicare part B payments, or have at least 200 Medicare patients.
Who is exempt from MIPS?
Medicare part B clinicians may be exempted from the payment adjustment under MIPS if they:
Clinicians receiving payments from Medicare part A, Medicare Advantage, Medicare part D, FQHC or Rural Health Clinic Facility payments billed under all-inclusive payment methodologies, and CAH method I facility payments will also be excluded from MIPS.
How are the payment adjustments made under MIPS?
The following are the payment adjustment options available for providers under MIPS:
In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
What are the different reporting options available under MIPS?
MIPS-eligible clinicians have the flexibility to submit information individually or via a group. The various reporting options include: claims (this is not an option for group submissions), EHR, registry, web interface and data submission vendor.
Do I report as an individual or as part of a group?
If your NPI/TIN has been reassigned to a group and each member of that group is MIPS eligible, then you can report to CMS as a group, and each member of the group will receive the same group score. Either every member of the group reports via a group or each member reports individually; there cannot be a combination of clinicians, some of whom report individually, and others who report as a group.
Are there any additional details on group reporting for MIPS?
Yes, if practices choose to report at the group level for one MIPS category, it must do so for all four categories of the program.
How will the ECs and group practices report for measure groups?
ECs and group practices cannot report for measure groups, as CMS has removed measure groups and replaced them with specialty measure set to ensure simplicity in reporting.
What if I belong to multiple TINs?
If you belong to multiple MIPS eligible TINs, CMS will use your highest score across the reported TINs for your final payment adjustment calculation. You are responsible for reporting on each TIN under which you are a MIPS eligible clinician. That is to say, if you bill under more than one TIN concurrently, you must report the minimum requirements for each TIN to avoid penalty under each TIN. CMS will then take the TIN where you earned the highest composite score to adjust the payment for each one of your TINs.
What if I am classified as a rural, small, or hospital-based clinician?
If you obtain any one of these special statuses, you qualify for special scoring under MIPS. Please contact us for more information.
Am I at risk of being penalized?
If you are a MIPS eligible clinician according to the www.qpp.gov eligibility check, and you do not submit the minimum reporting requirements, you will incur a -5% payment adjustment to your Medicare part B reimbursement.
How can I make myself eligible for a bonus?
In order to be eligible for a bonus, you need to report on as many performance categories as possible to earn the highest possible score. CMS sets a performance threshold each year, and in order to qualify for a bonus, you need to perform above the benchmark.
I belong to an advanced APM, do I need to report on MIPS?
If you are in advanced APM you need to have enough participation in your APM to be exempt from MIPS, and even more participation to be eligible for an 8% lump sum bonus.
What if I don’t meet the participation thresholds for my advanced APM?
If you don’t meet the requirements to be classified as a Qualifying APM Participant (QP) or partial QP, you must report on MIPS through standard reporting mechanisms.
What if I am in an MSSP ACO?
If you belong to an ACO, your ACO is responsible for reporting the quality performance category on a group level for each provider in the ACO. If you want to report beyond the quality performance category, you must report those performance categories independent of your ACO. CMS will then use your NPI number to reconcile the scores to come up with your composite score.
I belong to a non-advanced MIPS APM. Do I still need to report on MIPS?
If you belong to a non-advanced MIPS APM, you are scored under a special methodology. For MSSP Track 1 for the 2018 performance year, the APM scoring standard for MIPS is as follows:
Do I need an EMR to report on MIPS?
No. You can report quality and improvement activities without having an EMR by using a qualified reporting mechanism. However, if you do not have an EMR, it is impossible to earn any points for the Promoting Interoperability category.
Where can Eligible Clinicians find more information regarding this program?
CMS has launched a new online tool to make the quality payment program easier for clinicians. For further information visit https://qpp.cms.gov.
I am not participating in the quality payment program. Does that entail any payment adjustment?
If you don't send in any 2018 data, then you will receive a negative 5% payment adjustment.
I don’t want to participate
You have the option not to report, but you will be penalized at 5%.
How many patients do I need to report for?
60% of all patients (including Medicare part B, and non-Medicare part B).
Are measure groups still a reporting option?
Measure groups are no longer a reporting option under MIPS.
If measure groups are no longer a reporting option, how many measures do I need to include?
6 measures need to be reported on, of which one must be an outcome measure; if no outcome measure is applicable, then one high priority measure can be reported instead. Alternatively, eligible clinicians can choose to report measures in a specialty set.
Are there still domain requirements for reporting quality measures?
No, there are no longer domain restrictions for quality measures.
Do I still need to include a cross-cutting measure?
Under MIPS, there are no longer any cross-cutting measures.
What if I don’t have the 6 required measures?
In order to avoid the negative payment adjustment, just one quality measure can be reported. However, it is ideal to report as many quality measures that apply.
Specialty sets are a group of measures that apply to clinicians in a specific specialty. If a clinician reporting for a specialty set doesn’t meet 6 measures, they should only report on the ones that apply.
Previously we have attested for meaningful use through our EHR. How do we report PI measures to CMS?
There are four mechanisms you can choose from to report your PI data: attestation, submitting through a QCDR, submitting via a qualified registry, or submitting through an EHR. The ability to report PI measures via registry and QCDR is new under MIPS, and for consolidation of reporting, you must submit all categories through a single submission mechanism.
Do I need to update my EHR version in order to submit advancing care information?
In 2018, there are two measure set options for reporting advancing care information. Those who have a 2015 certified EHR edition will report the advancing care information measures and objectives, and those who have a 2014 certified EHR edition will report on the advancing care information transition measures and objectives. Note, in both cases, clinicians may report on a combination of both measure sets. The option you’ll use to send in data is based on your certified EHR technology edition.
In the past there were thresholds that needed to be met for all measures in order to pass Meaningful Use. Have they changed this year?
Under MIPS, there are no thresholds tied with the measures. For the base score, a 1 in the numerator is needed on all base measures. For the performance score measures, clinicians should strive to achieve high performance numbers in order to receive the maximum amount of points.
How is the Advancing Care Information performance score calculated for group reporting?
When reporting as a group on the Advancing Care Information performance category, the group would combine their MIPS eligible clinicians’ performance under one taxpayer identification number (TIN). Therefore, they are not calculated based upon one MIPS eligible clinician’s performance.
Do I still need to report on clinical quality measures?
No. You will report your quality data for MIPS as a separate category (quality).
How do I report improvement activities?
You must attest by indicating “yes” to each activity that meets the 90 to 365-day requirement; in other words, activities that you performed for at least 90 consecutive days during the current performance period (2018).
How does reporting improvement activities work in group reporting?
Improvement activities are assessed at the TIN level. Therefore, as long as one eligible clinician reports, the entire group gets credit for that category.
What services do you offer?
HealthEC is a 2018 CMS-approved Qualified Clinical Data Registry (QCDR) by CMS for its MIPS program.
As a QCDR, HealthEC can collect and submit data to CMS on behalf of clinicians for MIPS reporting, and can also create new measures that better serve specialty providers.
Beyond keeping individual providers MIPS compliant, HealthEC offers a range of competitively priced services to evaluate baseline performance, identify an optimal reporting strategy based on performance across the group or system, establish plans to improve metrics and monitor the effects of process changes.
Can HealthEC do my data abstraction for me?
Yes! Data abstraction is included with HealthEC’s consulting service package across TINs based upon the number of MIPS eligible clinicians in each TIN.
How will I know if the data I report is meeting the requirements?
The HealthEC MIPS team will verify your data before it is sent to CMS. They will also provide support over the phone or email to ensure that you meet CMS requirements.
We are not utilizing an EMR.
In order to obtain credit for the category, you have to have an EMR. You CAN report for MIPS without it, but it would automatically preclude you from the measure, therefore drastically cutting your score.
I would prefer to report myself.
You have the option of self-reporting but we strongly recommend allowing us to assist with choosing measures and reporting on your behalf.
Contact us directly to learn more.