The Merit-based Incentive Payment System (MIPS)

Overview and Background

The Merit-based Incentive Payment System (MIPS) operates under the Medicare Access and CHIP Reauthorization Act (MACRA), which governs the incentive program throughout the United States. MIPS marks a significant step towards implementing the value-based care model.

Eligible Clinicians for MIPS 2019

Eligible clinicians (ECs) are required to report MIPS for the year 2019. This group includes physicians, osteopathic practitioners, chiropractors, physician assistants, nurse practitioners, and registered dietitians or nutritionists, among others. Providers must meet the low-volume threshold to qualify for MIPS reporting in 2019. As we transition to MIPS 2020, new requirements will be introduced.

Performance Evaluation in Healthcare

MIPS Performance Metrics

MIPS evaluates a clinician’s performance based on care delivery and cost reduction. This article explores five key elements related to the program, referencing preliminary data released by CMS on July 11, 2019.

Quality Payment Program Structure

The Quality Payment Program (QPP) for 2019 consists of two branches: MIPS and Advanced Alternative Payment Models (APMs). Both paths lead to incentives for eligible clinicians, clinician groups, and virtual groups. MIPS and MACRA operate in tandem, with MIPS being the more favored option, supported by positive statistics and reports. Notably, MIPS incentives for 2019 are lower compared to those for 2020. As the program continues to evolve, it aims to enhance the overall healthcare system.

Performance Categories in MIPS

MIPS is divided into four performance categories: Quality, Promoting Interoperability (PI), Improvement Activities (IA), and Cost. Each category includes specific measures that must be reported via a MIPS Qualified Registry, CMS Web Interface, EHR, or Qualified Clinical Data Registry (QCDR). Additionally, there are various collection types that correspond to their respective submission systems.

Participation Trends in MIPS

Increasing Participation Rates

Since its inception in 2017, MIPS has seen a steady increase in participation. The participation rate grew from 95% in 2017 to 98% in 2018, and MIPS 2019 is expected to attract even more eligible clinicians. This trend indicates ongoing progress and higher participation levels nationwide.

Small Practices Engagement in MIPS

According to the Centers for Medicare & Medicaid Services (CMS), 90% of clinicians from small practices participated in MIPS in 2018, an increase from 81% in 2017. This 9% rise reflects the flexibilities introduced in the Physician Fee Schedule (PFS) rule for the 2018 performance year, including an increase in Medicare patient counts and allowed charges. Although fewer clinicians from small practices were eligible to report MIPS in 2018, many chose to do so voluntarily, demonstrating the system’s adaptability to practitioners’ needs. Seema Verma, CMS Administrator, highlighted this development in a blog post on July 11, 2019.

Growth in Advanced APM Participation

The participation rate in Alternative Payment Models (APMs) is also on the rise, with CMS reporting a twofold increase in participants from 2017 to 2018. The number of participants grew from 99,076 in 2017 to 183,306 in 2018, attributed largely to new opportunities for participation, particularly through ACOs in the Medicare Shared Savings Program. Despite any criticisms of MIPS, the opportunities it provides for clinicians to earn incentives are noteworthy.

Program Outcomes and Future Expectations

Incentives and Payment Adjustments

MIPS collects incentives for participating clinicians, with payouts occurring one year after the performance year. For instance, the payouts for MIPS 2017 were distributed in 2019, with 93% of participants receiving positive payment adjustments. Similarly, MIPS 2018 participants are expected to receive their payouts in 2020, with CMS forecasting that 97% of clinicians will secure positive payment adjustments based on their 2018 performance.

Monitoring MIPS Progress

P3 Healthcare Solutions in Ontario, CA, is actively monitoring developments as the MIPS performance period for 2019 approaches its conclusion.