CMS tries to ease MIPS burden with 2018 final rule
You will see more benefits from participating in the Merit-based Incentive Payment System (MIPS) in 2018 and may even be exempt under relaxed eligibility requirements established by CMS’ Quality Payment Program (QPP) final rule for 2018. The QPP governs both MIPS and all of Medicare’s recognized Advanced Alternative Payment Models (APMs).
MIPS consolidates all of the earlier CMS quality reporting programs under a single umbrella and thus the QPP rule, as a single document, has tremendous power and scope over all of Medicare’s incentive programs. Below is a list of highlights in the QPP final rule:
- Higher bar for minimum reporting. Though CMS is trying to make MIPS less of a burden, it is required to raise the bar for minimum participation in 2018, which is year 2 of the MIPS program. This means that in 2018, the minimum MIPS composite score required to avoid a pay cut in 2020 is 15 points, up from only 3 points in 2017 (which affects 2019 payments).
- Older EHR certifications will be accepted. In the final rule, you may use EHR software certified under either the 2014 or 2015 Edition Certified Electronic Health Record Technology (CEHRT) guidelines. In fact, if you use an EHR with the 2015 Edition certification, CMS will give you a bonus to your score under the Advancing Care Information (ACI) category of MIPS, which accounts for 25% of your overall MIPS composite score.
- Get bonus points for treating complex patients. CMS will automatically determine whether you see any complex patients and award up to 5 points toward your MIPS composite score based on how many such patients your providers see. This determination is based on a patient’s clinical risk score, as calculated by the Hierarchical Condition Categories (HCC) model (covered in depth in the October 2017 issue of The Business of Medicine), as well as whether a patient is a dual-eligible beneficiary (i.e., qualifies for both Medicare and Medicaid).
- Small practices get bonus points for free. To help smaller practices cope with MIPS, CMS will simply award them 5 points to their MIPS composite score without them needing to take any action. For the purposes of this bonus, CMS is defining a “small” practice as a group of 15 or fewer providers.
- Small practices change join Virtual Groups. CMS is allowing solo practitioners and small practices (defined as having 10 or fewer providers) to join “Virtual Groups,” which are a combination of two or more entities based on their tax identification numbers (TIN). This combined entity or Virtual Group will have their MIPS performance assessed as a group rather than individually, allowing smaller practices to pool their resources and earn a potentially higher payment adjustment. Note that a “small” practice for Virtual Groups means 10 or fewer providers while “small” for the small practice bonus means 15 or fewer providers.
- More Part B providers are exempt from MIPS. The MIPS program comes with a “low-volume” threshold below which providers were exempt from having to participate in the program. For an individual provider, this threshold was set at $30,000 or less in total annual Part B charges or seeing 100 or fewer Medicare beneficiaries per year. This threshold is increasing substantially in the QPP final rule: For 2018, a provider who bills $90,000 or less in Part B charges a year, or who sees 200 or fewer beneficiaries per year, will be exempt from MIPS.
- Cost performance will count in 2018. The Cost performance category, which replaces the value modifier program, will account for 10% of your MIPS composite score in 2018, up from 0% in 2017. You will still receive a breakdown of your Cost performance in 2017 when CMS releases its MIPS report card early next year, but it won’t affect your payment adjustment. For 2018, it will. Even so, you won’t be able to do too much about it, as the methodology isn’t changing much in the near-term from that used in the value-modifier (see related story on QRURs and cost measurement, pg. 8).
More guidance to come
Look for a complete guide to MIPS in 2018 in the next issue of The Business of Medicine. We will cover what the higher 15-point score threshold means for minimum participation (just to avoid a negative payment update in 2020), whether exemptions apply to you under the final rule, and strategies to boost your MIPS score if your practice intends to dive into the program.