Proposed MIPS Rule Tweaks Meaningful Use - DoctorsManagement Proposed MIPS Rule Tweaks Meaningful Use - DoctorsManagement

Proposed MIPS rule tweaks meaningful use

By  Grant Huang, CPC, CPMA

Proposed MIPS rule tweaks meaningful use

Your practice’s performance in terms of quality reporting and electronic health record (EHR) meaningful use will start to be recorded on Jan. 1, 2017 – less than six months from now – in order to determine your future Medicare payment adjustments under the new Merit-Based Incentive Payment System (MIPS). The first adjustment will hit in 2019.

In an earlier issue of The Business of Medicine, we addressed the highlights of the MIPS proposed rule, focusing on the changes to Medicare’s quality reporting program. In this article, we’ll look at changes to meaningful use as well as how the overall MIPS score is generated and how it results in positive or negative payment changes for you.

As promised by CMS, the meaningful use program will be replaced with something called the Advancing Care Information (ACI) category, which is one of the four components of the MIPS program. We will discuss the other components and the overall MIPS score in detail later.

MIPS vs. stage 3 meaningful use

The biggest difference between the ACI category of MIPS and stage 3 of the existing meaningful use program is that ACI is not a pass/fail proposition, says Stanley Nachimson, a former Senior Technical Advisor for Health IT at CMS who is now CEO of Nachimson Advisors in Reisterstown, Md. “Eligible clinicians can get some credit, up to 50% [of the possible MIPS score] for using a certified EHR and performing some tasks,” Nachimson explains. “They are not required to meet every single criteria, as they were in the meaningful use program.”

A major strike against meaningful use is that when providers attest, if they aren’t 100% successful they get no incentive payment. This goes away with MIPS, Nachimson says. The ACI category gives providers a score of up to 131 points based on the measures they report, all of which are adapted from existing stage 3 meaningful use criteria. Earning 100 points or more will give providers the maximum possible category score of 25 points. This 25-point maximum possible score represents the most credit providers can get for the ACI component of MIPS, which is added to the overall MIPS score.

How MIPS score is calculated

Let’s address the confusion, much of which is the result of CMS using the same term, “points,” to grade providers within each MIPS category as well as for the final MIPS score itself. As mentioned earlier, MIPS consists of four components, also known as categories, each of which is scored and weighted individually, then combined to create a final value called the MIPS Composite Performance Score (CPS).

Weighting is crucial, because the quality reporting category (replacing the Physician Quality Reporting System or PQRS) accounts for 50% of the MIPS score. Meaningful use, now the ACI category, accounts for 25% of the CPS. The CPS is a value from 1 to 100 and it ultimately determines the payment adjustment. In 2019, the range runs from a negative 4% penalty to a positive 4% bonus. Your meaningful use performance can contribute at most 25 points to the CPS score, while your quality reporting can contribute at most 50 points. Perfect scores in these two categories alone would yield a 2.5% positive payment adjustment in 2019.

Final rule could change numbers

It’s important to remember that all of these values and calculations are based on the proposed rule, Nachimson says. You can find the full text of the MIPS proposed rule here. The official public comment period ends June 27 and you may submit feedback to CMS until that date. Visit The Federal Register page for MIPS to view or submit comments.

Grant Huang, CPC, CPMA (ghuang@drsmgmt.com). The author is Director of Content at DoctorsManagement.