Overview of MIPS Reporting Changes

Background on MIPS Guidelines

In 2018, the American Medical Association (AMA) emphasized that to avoid penalties related to the Merit-based Incentive Payment System (MIPS) for 2018, clinicians needed to report on certain MIPS quality measures. As we approach the end of 2019, it has become increasingly important to include Promoting Interoperability (PI) and Improvement Activities (IA) in MIPS 2019 reporting. Eligible Clinicians (ECs) scoring above 75 can qualify for bonuses from a $500 million pool allocated for 2019, thereby mitigating potential negative payment adjustments scheduled for 2021.

Performance Categories for Reporting

Currently, the four approved performance categories for attestation are:
– Promoting Interoperability
– Quality
– Improvement Activities
– Cost

Evolution of Reporting Criteria

Changes in Penalty Avoidance Strategies

Eligible clinicians can evade penalties by adhering to a reporting strategy as recommended by the AMA. In 2017, the requirement was a minimum score of three MIPS points to avoid penalties, which only necessitated reporting one quality measure. However, more stringent rules have been implemented, making value-based services a greater focus. The new threshold for MIPS 2018 reporting is now fifteen points; clinicians achieving this score can evade penalties in 2020. Failing to report the minimum required quality measures under the Quality Payment Program can lead to a 5% reduction in reimbursements.

Strategies for Scoring High

Reporting Improvement Activities

To meet the required scoring threshold, it is advisable to report Improvement Activities (IAs) promptly. The Centers for Medicare & Medicaid Services (CMS) has identified 113 measures within this performance category for MIPS 2019, categorized into medium and high-weighted activities. High-weighted activities yield more points, helping clinicians reach the maximum score. Clinicians are expected to report for a minimum of 90 days.

Calculating Performance Categories

Performance category activities revolve around care coordination, population healthcare, beneficiary engagement, and health equity. To score in any category, eligible clinicians must collect and submit data for 90 consecutive days in 2018.

Submission Methods for MIPS Data

Healthcare providers can submit clinical data for MIPS 2018 through:
– Quality Payment Program 2018 (QPP) data submission system
– Electronic Health Record (EHR) system
– MIPS Qualified Registry
– Qualified Clinical Data Registry (QCDR)

Benefits for Small Practices

Reporting Improvement Activities (IAs) under MIPS 2019 can enhance revenue cycles for small practices. The program offers small healthcare practices double the points compared to larger facilities. Additionally, small practices scoring 15 points receive a bonus of five extra points, elevating their score to 20 points. In contrast, larger practices must submit data for two or more improvement activities to achieve the same threshold.

Importance of Quality Measures

Avoiding Negative Payment Adjustments

Negative payment adjustments can significantly impact profitability. Utilizing quality measures effectively is essential for transforming potential setbacks into profitable opportunities. Clinicians can select from 275 quality measures to meet the MIPS 2018 threshold score, with each measure categorized by efficiency, outcome, and patient engagement factors. CMS has developed a specialized set of quality measures to assist physicians in identifying the most appropriate ones.

Reporting Requirements for Performance Categories

To avoid negative payment adjustments, clinicians should report at least two performance categories, such as:
– Improvement Activities and Quality
– Promoting Interoperability and Quality

2019 Reporting Criteria

In 2019, while reporting in one of the categories is mandatory, specific criteria apply, especially for small practices with 15 or fewer clinicians. In these cases, reporting one high-weighted and two medium-weighted improvement activities is required.

Scoring Comparison and Strategies

Historical Reporting Tactics

Typically, small medical practitioners reported one medium-weighted improvement activity and one quality measure, achieving a total of 15 points back in 2018. Currently, however, a score of 30 points is necessary to avoid penalties.

Promoting Interoperability (PI) Overview

Earning points through Promoting Interoperability can yield up to 50 out of 100 points. This category focuses on patient and physician engagement, ensuring that patient information is accessible to all clinicians via EHR technology. ECs are required to report data for a minimum of 90 days based on four or five base score measures.

EHR Technology Considerations

Different EHR editions come with various performance measures. For example, the 2014 EHR edition allows reporting on Promoting Interoperability Transition Objectives.

Effective Reporting Practices

To meet data completeness requirements, quality measures must be reported on at least 20 patients. Reporting two medium-weighted improvement activities and four quality measures can yield a score of 16 points in 2018.

Call to Action for Healthcare Providers

As 2018 concludes, it is vital to advocate for a better healthcare system. If steps have not yet been taken to avoid penalties in 2020, healthcare providers should connect with a reliable MIPS registry for proper submissions. Engaging with P3Care can ensure efficient reporting of QPP measures, alleviating concerns about non-reporting.