MIPS Reporting Options

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).  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 2017 transition year to avoid a negative payment adjustment in 2019:

"Test" the Quality Payment Program
"Test" the Quality Payment Program

 If a provider submits a minimum amount  of 2017 data to Medicare (for example, one quality measure or one improvement activity or the required ACI measures), they could avoid a downward payment adjustment in 2019.

Participate - Part of the Calendar Year
Submit a Partial Year

If a provider submits 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 measures),  they may earn a neutral or small positive payment adjustment in 2019.

Participate - Full Calendar Year
Full Reporting 

If a provider reports all required measures for a full year, they may earn a moderate positive payment adjustment in 2019. 

Participate in an Advanced Alternative Payment Model (APM) in 2017.
Participate in an Advanced Alternative Payment Model (APM)

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 receive the 4% penalty in 2019 (unless they fall under one of the exemptions).

 

Reporting Options

Individual clinicians and groups would have various options to submit their MIPS data to CMS:

For Individuals:

  • Quality: Qualified Registry (such as MDinteractive), Qualified Clinical Data Registry (QCDR), EHR and Administrative Claims (no submission required)

  • Advancing Care Information: Qualified registry, QCDR, EHR and Attestation

  • Clinical Practice Improvement Activities:  Qualified registry, QCDR, EHR, Attestation and Administrative Claims (if technically feasible; no submission required)

  • Cost:  Administrative Claims (no submission required)

For Groups:

  • Quality: Qualified registry (such as MDinteractive), QCDR, EHR, CMS Web Interface (groups of 25 or more), CAHPS for MIPS Survey (must be reported in conjunction with another data submission mechanism), and Administrative Claims (no submission required)

  • Advancing Care Information: Qualified Registry, QCDR, EHR, CMS Web Interface (groups of 25 or more) and Attestation

  • Clinical Practice Improvement Activities:  Qualified registry, QCDR, EHR, Attestation, CMS Web Interface (groups of 25 or more) and Administrative Claims (if technically feasible; no submission required)

  • Cost:  Administrative Claims (no submission required)

GPRO reporting - GPROs will no longer have to formally register with CMS as groups to submit data using third party entities, such as qualified registry, health IT vendor, or QCDR.   When one of these entities submits data for a group, CMS is able to obtain group information from the third party and determine if the data submitted represents group submission or individual submission.  CMS may establish a voluntary registration process in the future.

 

APMs

The final rule provides incentives for eligible clinicians who participate in eligible advanced APMs.  Advanced APMs must meet three requirements:

  • Required use of certified EHRs

  • Payment based on quality measures comparable to MIPS

  • The APM either requires APM entities to bear more than “nominal” financial  risk for losses or meet the criteria for an expanded Medical Home Model

 

Further information can be found at:

 

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