On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment period to implement MACRA's new Quality Payment Program (QPP). Providers can choose between two payment models under Medicare:
- The Merit-Based Incentive Payment System (MIPS) and
- The Advanced Alternative Payment Models (APMs)
MIPS combines 3 existing quality and value reporting programs into one: the Physician Quality Reporting System (PQRS); the Value-Based Modifier (VBM); and the EHR Meaningful Use (MU) program. MIPS also adds a 4th component for practice improvement activities (CPIA). Most providers will initially participate in Medicare through MIPS.
- Quality (formerly PQRS),
- Advancing Care Information (formerly EHR Meaningful Use),
- Clinical Practice Improvement Activities (new), and
- Cost (formerly Value-based Modifier)
Provides incentive payments for participation in eligible APMs
When does MIPS begin?
The program begins in 2017, with payment adjustments beginning in 2019. Providers can “pick their pace of participation” by choosing one of the following four options during the 2017 transition year to avoid a negative payment adjustment in 2019:
Option 1: "Test" the Quality Payment Program. If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity or the required ACI base measures), you can avoid a downward payment adjustment.
Option 2: Submit a Partial Year. If you submit 90 continuous days of 2017 data to Medicare (for example, more than one quality measure or more than one improvement activity or the required ACI base measures), you may earn a neutral or small positive payment adjustment.
Option 3: Full Reporting. If you report all required measures for a full year in 2017, you may earn a moderate positive payment adjustment.
Option 4: Participate in an Advanced Alternative Payment Model (APM) in 2017. If providers receive 25% of their Medicare covered professional services, or see 20% of their Medicare patients, through an APM in 2017, they could qualify for incentive payments in 2019.
*Only eligible clinicians who choose not to report any data during the 2017 transition year would be subject to the 4% penalty in 2019 (unless they fall under one of the exemptions outlined below).
Who is eligible to participate in MIPS?
MIPS eligible clinicians include:
- Physicians assistants
- Nurse practitioners
- Clinical nurse specialists; and
- Nurse anesthetists
- ***This list may be expanded by CMS in 2019 to include other types of providers (e.g., physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, dietitians/nutritional professionals)
MIPS non-eligible clinicians would be permitted to voluntarily report under MIPS in 2017 and 2018, but will not be subject to the MIPS payment adjustment.
Are any providers exempt from MIPS?
Yes, the following providers would be exempt from MIPS:
- Newly enrolled in Medicare (exempt until the following performance year)
- Clinicians meeting a low-volume threshold ($30,000 or less in billed Medicare Part B allowed charges OR provide care for 100 or fewer Medicare Part-B enrolled patients in one year)
- Clinicians significantly participating in "alternative payment models" (APMs)
Can providers participate in MIPS as an individual provider or a group practice?
Providers can participate in MIPS as either:
- An individual (defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number (TIN); or
- A group defined as a set of clinicians (identified by their individual NPIs) sharing a common TIN.
A group would be measured as a group practice across all 4 MIPS performance categories. Solo providers and small practices may be able to join “virtual groups” in future years to combine their MIPS reporting.
How will MIPS work?
Providers participating in the MIPS program will receive a “composite performance score” based on their performance in 4 categories:
60% of the total score in year 1
(Decreases to 50% in 2018; 30% in 2019 and thereafter)
|25% of the total score in year 1|
Improvement Activities (new)
|15% of the total score in year 1|
0% of the total score in year 1
(Increases to 10% in 2018; 30% in 2019 and thereafter)
*In 2017, any provider who reports on one quality measure for at least one patient will receive at least 3 points on the measure and avoid a payment adjustment in 2019.
How is the new Quality category different from PQRS?
- Each provider must report 6 individual measures or a specialty measure set (one must be an outcome measure, or if no outcome measure is available, a high-value measure).
- Providers reporting on quality measures must report on at least 50% of their eligible Medicare and non-Medicare patients who are eligible for the measure.
- For the 2017 transition year, providers whose measures fall below the data completeness threshold of 50% would receive 3 points for submitting the measure.
- In 2018 this threshold increases to 60% of eligible Medicare and non-Medicare patients.
- Measures Groups are no longer available for reporting.
- There is no requirement to report a cross cutting measure in 2017.
- There are no domain requirements.
- CAHPS is no longer required for groups of 100 or more.
- *View the list of the Quality measures: https://qpp.cms.gov/measures/quality
Will there be a Measure Applicability Validation (MAV) process under MIPS if I cannot report 6 measures?
CMS will develop a new process to review and validate a provider’s inability to report on the quality performance requirements under MIPS. This validation process will be part of the quality performance category scoring calculations and not a separate process as the MAV was under PQRS. This process will apply for claims and registry submissions to validate whether MIPS eligible clinicians have submitted all applicable measures when MIPS eligible clinicians submit fewer than six measures or do not submit the required outcome measure or other high priority measure if an outcome measure is not available, or submit less than the full set of measures in the MIPS eligible clinicians’ applicable specialty set.
How will the Improvement Activities category work?
- Performance in this category is calculated based on the provider’s attestation to completing 2 high-weighted activities or 4 medium-weighted activities for a minimum of 90 days. Some examples of improvement activities include care coordination, beneficiary engagement and patient safety activities.
- For small practices (less than 15 in the TIN), rural practices, or practices located in geographic health professional shortage areas (HPSAs), providers are only required to report 1 high-weighted or 2 medium-weighted activities for full participation.
*View the list of Improvement Activity measures: https://qpp.cms.gov/measures/ia
How will the Advancing Care Information category work?
- Performance in this category is calculated based on the submission of 5 EHR (or 4 depending on the EHR edition) use-related measures for a minimum of 90 days in 2017 and 2018. These base measures are required in order to then go on to earn additional performance and bonus points.
- Base Measures include: security risk analysis; e-prescribing; providing patient access; sending summaries of care; and requesting/accepting summaries of care.
*View the list of the Advancing Care Information measures: https://qpp.cms.gov/measures/aci
How will my Medicare payments be impacted under MIPS?
MIPS eligible clinicians will receive neutral, positive or negative payment adjustments based on their composite performance score. Only eligible clinicians who choose not to report any data during the 2017 transition year would be subject to a 4% penalty in 2019. The maximum negative adjustments are: 4% in 2019; 5% in 2020, 7% in 2021, and 9% in 2022 and subsequent years. Exceptional performers could receive positive adjustments up to 3x this amount. The threshold for these payment adjustments will be the mean or median composite score for all MIPS eligible clinicians during the previous performance period.
Where can I get more information?
You can find additional information on the CMS website at: https://qpp.cms.gov/
What do I need to do now to prepare for MIPS?
Determine your eligibility
Pick your measures
Decide if you will be reporting as a group or as individuals
For what period of time will you be reporting
What mechanism will you use to report each component of MIPS?
Will MDinteractive still submit my data to CMS?
Yes! We will offer 3 services to help you report:
- Data on Quality (replacing PQRS)
- Improvement Activities (new)
- Advancing Care Information (replacing EHR Meaningful Use)
Further information can be found at:
- Quality Payment Program Educational Resource Library
- MIPS Quality Benchmarks
- CMS webinars about the MACRA final rule
- High-level overview of the Quality Payment Program (presented on October 26, 2016)
- Medicare Shared Savings Program in the Quality Payment Program (presented on October 27, 2016)
- Medicaid in The Quality Payment Program (11/1/16)
- Quality Payment Program Final Rule MLN Connects® Call (11/15/16)
- Merit-based Incentive Payment System (MIPS) Overview (11/29/16)
- MIPS Performance Categories: Advancing Care Information & Improvement Activities (12/13/16)
- Advancing Care Information Fact Sheet
- Transitioning from PQRS to MIPS (1/24/2017)
- Quality Payment Program Training Videos