Posted on September 19, 2018
Reporting the Bare Minimum to Avoid a Penalty
We have heard from a number of clinicians who lack the resources to fully report MIPS this year, but want to report a minimal amount of data to make sure they don’t get hit with a penalty. There are a few different ways you can meet the minimum 15 point threshold and it’s a fairly simple process. Before beginning your reporting, however, you should check the CMS Participation Status Tool to verify you are required to report MIPS in 2018.
If you determine you are a MIPS eligible clinician, you can achieve this threshold by submitting data in one of the MIPS performance categories (Quality, Improvement Activities or Promoting Interoperability), or a combination of 2 categories. How much you have to report for Quality or Improvement Activities will vary based on your practice size.
Small Practices (15 or fewer clinicians)
CMS considers a small practice to include solo practitioners and practices with 15 or fewer providers who bill under the same Tax Identification Number (TIN). Providers can confirm if they have small practice special status by checking their individual National Provider Identifier (NPI) on the CMS Participation Status website.
If you are a MIPS eligible clinician or group with small practice status, you can earn 15 MIPS points by reporting one of the following options as an individual clinician or as a group:
Improvement Activities: Attest to 1 High-weighted or 2 Medium-weighted Improvement Activities. Fully reporting this category will result in 15 MIPS points. There are over 100 activities to choose from this year and CMS has weighted each activity as “High” or “Medium”. A complete list of available 2018 Improvement Activities, suggested documentation for each activity and how to attest to them in your MDinteractive account can be found here.
Quality: Report 6 Quality measures on at least 1 eligible patient for each measure. At least 1 of the 6 measures should be an Outcome or High Priority measure. Small practices will continue to receive at least 3 points for Quality measures, even if they do not meet the data completeness requirements (at least 60% of eligible cases reported for 12 months). This will equate to 15 MIPS points since the Quality category counts as only 50% of your final MIPS score this year. A list of recommended Quality measures by specialty can be found here.
Promoting Interoperability (formerly ACI): Attest to all of the base score measures under this category and report 1 Quality measure or attest to 1 Improvement Activity. You must have a certified EHR (2014 or 2015 Edition) to report the Promoting Interoperability (PI) category. If you report some of the additional PI performance measures listed in this category, it is possible you may earn 15 MIPS points without reporting an additional Quality measure or Improvement Activity. A list of required base score measures based on your EHR edition and how to attest to PI in your MDinteractive account can be found here.
*Additionally, CMS is making it easier for small practices to reach the minimum threshold this year with a small practice bonus. Small practices will have 5 additional points added to your final MIPS score if you submit data in at least one MIPS performance category.
Large Practices (16 or more clinicians)
Large practices will have to report more data to meet the minimum reporting requirements and avoid the automatic 5% penalty. If you are a MIPS eligible clinician or group with 16 or more clinicians in your TIN, you can reach 15 MIPS points by reporting one of the following options as an individual clinician or a group:
Improvement Activities: Attest to appropriately weighted Improvement Activities to receive full credit for this category:
- 2 High-weighted activities; OR
- 4 Medium-weighted activities; OR
- 1 High-weighted and 2 Medium-weighted activities
Click here for a full list of 2018 Improvement Activities.
Quality: Report 6 Quality measures on at least 60% of eligible cases for 12 months. At least 1 of the 6 measures should be an Outcome or High Priority measure. A minimum of 3 points would be earned for each measure that meets this data completeness standard, but more points could be earned depending on your performance and whether the measure has a national benchmark and at least 20 cases have been reported. If you earn more than 15 MIPS points, you could receive a possible positive payment adjustment based on your final score for this category. Click here for a list of recommended Quality measures for each specialty.
Keep in mind, any measure reported by a large practice provider that does not meet the data completeness standard would only earn 1 point and could result in a final MIPS score of less than 15 points.
Promoting Interoperability (formerly ACI): Attest to all of the base score measures under this category and report 1 Quality measure that meets data completeness or attest to 1 Improvement Activity. By reporting additional PI performance measures, you may earn 15 MIPS points in the PI category without reporting an additional Quality measure or Improvement Activity.
Click here for a list of 2018 PI measures.
Avoiding the Penalty is Easy with MDinteractive
MDinteractive can help you choose a reporting plan that is right for your practice and avoid an automatic 5% reduction to your 2020 Medicare payments. Clinicians have a few different options to report a minimum amount of data and fulfill the reporting requirements. While we have covered some of the easiest ways to earn at least 15 MIPS points, it’s not a complete list of all of the possible scenarios your practice can report. Our MIPS specialists are available to discuss your reporting plans to ensure you reach 15 MIPS points and avoid a penalty.
MIPS MIPS Penalty 2018 MIPS Threshold