2018 MIPS Reporting Checklist
We have finally reached the end of the 2018 MIPS performance year. MIPS eligible clinicians and groups must achieve at least 15 MIPS points for 2018 to avoid an automatic 5% penalty against their 2020 Medicare Part B payments. We have developed this MIPS Reporting Checklist to help you determine if you are required to report MIPS this year and to understand your reporting options.
STEP 1: Determine if you are required to report MIPS this year.
Before you start reporting MIPS, you should first check your MIPS participation status on the CMS QPP Participation Status tool to see if you are required to report this year. You can enter your individual National Provider Identifier (NPI) here to check your status now. The tool will tell you which practice(s) you must report for, if you are part of a qualifying Alternative Payment Model (APM), and whether you have special status designation (e.g., small practice, non-patient facing, hospital-based, etc.).
If you are not required to report in 2018, you can choose to report voluntarily to gain reporting experience.
STEP 2: Will you report as an individual or a group?
Providers can choose to report as an individual or as a group if they have 2 or more clinicians who bill with the same tax identification number (TIN). When reporting as a group, performance data is aggregated across the TIN for all clinicians, so you will receive the collective score of the group for all 4 MIPS categories. There will be one MIPS submission under your TIN, rather than a separate submission for each clinician. This means you will earn the same MIPS score and receive the same payment adjustment as everyone else in the group.
Remember, all of the providers in a group are taken into account when determining if the group collectively meets the volume threshold, even those clinicians who were below the low-volume threshold as individuals (bill for $90,000 or less or see 200 Medicare patients or less a year).
More information about group reporting and its advantages can be found here.
STEP 3: Decide your reporting goals.
Are you looking to simply avoid the automatic 5% penalty (neutral payment adjustment), or do you want to try to maximize your Medicare reimbursement? Whatever your reporting goals, you have several reporting options to choose from.
You can achieve the 15 point threshold to just avoid the penalty 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.
Learn how to report a minimal amount of data to avoid the penalty by clicking here.
If your goal is to earn a possible positive payment adjustment, you will want to earn more than 15 MIPS points. The top MIPS performers who earn 70 or more MIPS points will be rewarded with an exceptional performance bonus in addition to their positive payment adjustment. The more MIPS categories you report, the higher possible MIPS points you can earn.
Click here to learn how to maximize your reimbursement.
STEP 4: Determine which MIPS performance categories you will report.
Your 2018 MIPS score will be based on your performance in 4 categories:
Quality - This category is worth a maximum of 50 points. Eligible MIPS clinicians and groups must report 6 Quality measures this year, with at least 1 measure being an Outcome measure (or a High Priority measure if an Outcome measure is not available). Each measure should be reported on at least 60% of eligible patients or visits for the full calendar year. Measures that do not meet this data completeness standard will receive just 1 point (3 points for small practices with 15 or fewer in the TIN).
You can review all of the available 2018 Quality measures here or review suggestions for your specialty here.
Promoting Interoperability - This category is worth a maximum of 25 points. A 2014 or 2015 certified Electronic Health Record (EHR) is required for this category and all base score measures must be reported for a minimum of 90 consecutive days. Any MIPS eligible clinicians using only 2015 certified EHR technology could earn a 10% bonus.
CMS will reweight this category to 0 and reallocate the performance category weight of 25% to the Quality performance category for the following reasons:
Automatic reweighting:
- Hospital-based MIPS eligible clinicians;
- Non-Patient Facing clinicians;
- Ambulatory Surgical Center (ASC)-based MIPS eligible clinicians;
- Nurse practitioners, physician assistants, clinical nurse specialist, certified registered nurse anesthetists
Reweighting through an approved application (was due by December 31, 2018):
- You’re in a small practice
- You’re using decertified EHR technology
- You have insufficient internet connectivity
- You have extreme and uncontrollable circumstances
- You don’t have any control over whether CEHRT is available
More information on Promoting Interoperability, and how to attest to this category in your MDinteractive account, can be found here.
Improvement Activities - This category is worth a maximum of 15 points. It remains a simple attestation process for activities performed for a minimum of 90 consecutive days. The number of activities you report are based on the size of your practice:
- Groups with over 15: attest to 2 high-weighted IAs; OR 1 high-weighted and 2 medium-weighted IAs; OR 4 medium-weighted IAs;
- Solo providers and groups with 15 or less: attest to 1 high-weighted IA OR 2 medium weighted IAs.
More information on the Improvement Activities and how to attest in your MDinteractive account can be found here.
Cost: Worth a maximum of 10 points. CMS will use Medicare claims data to calculate the Cost performance score, so you do not need to submit separate data for this category.
STEP 5: Begin your reporting.
MDinteractive provides one-stop shopping for submitting Quality, Promoting Interoperability, and Improvement Activity data to CMS to fulfill your MIPS requirements. We support all 2018 MIPS categories and measures, regardless if you are reporting as an individual or a group. We also offer unlimited customer support, via phone, live chat and email, to assist you throughout the entire reporting process.
You can create a free account here or log into an existing account from our website to report 1 or more MIPS categories. Our deadline to receive all of your data is March 1, 2019.
Completing your MIPS Reporting
It’s not too late to get started with your 2018 MIPS reporting, whether you are just trying to avoid the 5% penalty or you are seeking to maximize your Medicare payments. Our MIPS Reporting Checklist walks you through the key steps you can take to get started and successfully complete your reporting.
At MDinteractive, we strive to make your reporting quick and easy so you can fulfill your MIPS requirements and protect your Medicare payments. Contact one of our MIPS specialists today if you have any questions.
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