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THE MERIT-BASED INCENTIVE PAYMENT SYSTEM – MIPS IN 2018. OVERVIEW

2018 is the second year of Quality Payment Program (QPP) and it’s referred as “The Quality Payment Program Year 2” which includes many of the flexibilities from the transition year (2017) to help clinicians get ready for Year 3.

One of the major changes is that CMS set the 2018 MIPS final score threshold at 15 points, up from 3 points in 2017. To avoid the 5% penalty, physicians must earn at least 15 MIPS points. Let’s see all the changes:

  • Raising the performance threshold to 15 points in Year 2 (from 3 points in the transition year);
  • Allowing the use if 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2. You will be given a bonus for using only 2015 CEHRT;
  • Giving up to 5 bonus points on your final score for treatment complex patients;
  • Automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the final rule score for clinicians impacted by hurricanes Irma;
  • Adding 5 bonus points to the final scores of small practices.
THE MERIT-BASED INCENTIVE PAYMENT SYSTEM

Also, there are more options for small practices (15 or fewer clinicians) including:

  • Excluding individual MIPS eligible clinicians or groups with less than or equal to $90,000 in Part B allowed charges or less than or equal to 200 Part B beneficiaries;
  • Adding 5 bonus points to the final scores of small practices;
  • Giving solo practitioners and small practices the choice to form or join a Virtual Group to participate with other practices;
  • Continuing to award small practices 3 points for measures in the Quality performance category that don’t meet data completeness requirements;
  • Adding a new hardship exception for the Advancing Care Information performance category for small practices. 

The performance period for the quality and cost categories is a full calendar year (January 1 - December 31, 2018). The performance period for the improvement activities and advancing care information (ACI) categories is any consecutive 90 days.

The MIPS 15 points threshold can be met in a variety of ways, such as:

  • Full participation in the Improvement Activities category, such as submitting one high-weighted activity or two medium weighted activities for small practices, or two high-weighted activities, four medium-weighted activities, or a combination of both medium- and high-weighted activities;
  • The Advancing Care Information (ACI) category base score and one quality measure meeting the measure threshold, or data completeness, but not benchmarks;
  • ACI base score and one medium-weighted improvement activity; or
  • Six quality measures meeting data completeness, but not measure benchmarks. 

MIPS Reporting Options You may report using different mechanisms between categories, but only one method of reporting can be used within each category.

  • Medicare Part B claims-based reporting
  • Qualified registry
  • Certified electronic health record technology (CEHRT)
  • Qualified clinical data registry (QCDR)
  • CMS Web Interface (for groups of 25 or more eligible clinicians)
  • Consumer Assessment of Healthcare Providers and Suppliers (CAHPS) for MIPS (counts as one quality measure; remaining measures must be reported using one other reporting method).

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Insights
April 2018