By Sonda Eunus, MHA, CMPE, CPB
As the first year of MIPS reporting comes to an end,
healthcare practices and providers don’t have much time left to learn about the
Merit-Based Incentive Payment System and how it will affect their revenue and
credibility. To make things simpler, I have put together some of the most
frequently asked questions about MIPS.
1. How
do I know if I am required to report?
Physicians (MD/DO and DMD/DDS),
Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and
Certified Registered Nurse Anesthetists that bill Medicare are required to
report for 2017. If you meet any of the below exclusion criteria, you are not
MIPS-eligible:
·
You are newly enrolled in Medicare.
·
You see 100 or fewer Medicare Part B patients
per year.
·
You have less than or equal to $30,000
allowed Medicare Part B charges annually.
·
You are on the participant list for a
model that CMS has deemed an Advanced Alternative Payment Model (AAPM).
Look up your participation status
here with your NPI:
2. What
happens if I don’t report at all?
If you are an eligible
clinician who chooses to not participate in the MIPS program, you will face a
4% decrease in your Medicare payments in 2019. These payment adjustments will
become greater every year, with a maximum penalty of 9% of your Medicare
reimbursement. Additionally, every clinician’s score is publicly displayed on
the Medicare Physician Compare website, for everyone to see. Having a low MIPS
score can cost you patients, as well as can undermine your credibility with
insurance payers.
3. What measures should I report on?
It is recommended that
you choose measures that are most representative of your practice, such as
those that apply to the patients you see or the procedures that you perform
frequently to ensure you have a minimum of 20 cases. If possible, avoid
reporting on quality measures that most clinicians generally perform well on
across the board, because you may have to achieve nearly the highest possible
score on the measure to receive more than the minimum number of points for that
measure.
4. I
am part of a group practice, what is the difference between reporting as an
individual and reporting as a group?
For some multi-specialty practices, it may make more sense to report individually so that different quality or Improvement Activity measures may be used that will best fit each specialty. Also, in instances where individual performance may otherwise be unknown, individual reporting may be beneficial to ensure that bonuses or penalties are properly applied to individual physicians, rather than to the group as a whole.
On the other hand, reporting as a group may be easier than reporting individually. For practices that have been reporting as a group to programs such as PQRS, the transition to MIPS may be less burdensome if the practice continues to report as a group. Keep in mind, though, that bonuses or penalties will be applied to the group as a whole regardless of each individual clinician’s performance.
5. I
am a hospital-based physician, am I accountable for the same measures as
outpatient clinicians?
A hospital-based physician is subject
to all of the same MIPS rules as a physician practicing in other settings
except that he or she is not scored on the Advancing Care Information (ACI)
category. Instead, hospital-based physician’s MIPS score will be based on
Quality and Improvement Activities (IA) in 2017.
6. When
is the deadline to report?
March 31, 2018, but if you are
reporting through your EHR then you should verify with your EHR vendor because
they may have a different deadline. If you are using the claims-based reporting method, then you only have until Dec 31, 2017 to report.
7. How
can I track my performance?
CMS will provide data to help you
prepare for MIPS. Many physicians have participated in the Physician Quality
Reporting System (PQRS) and Value Based Modifier (VBM) programs to avoid
payment penalties. CMS provides Quality and Resource Use Reports (QRURs) and
feedback reports which you can obtain on the CMS website. All QRURs are
available on the CMS Enterprise Portal: https://portal.cms.gov/wps/portal/unauthportal/home/.
You
may need to request the appropriate “role” in the system to view your QRUR.
8. Where
can I find more information about the program?
Here are some great links
to get started:
If you would like to
download a free MIPS E-book that explains what you need to do to avoid a 4%
Medicare payment decrease in 2019, as well as to earn a high MIPS score and
Medicare payment increases, go here: www.lmsmips.com.
You will also be able to see the payment adjustments that you may face
depending on your MIPS participation level and annual Medicare revenue.
Leading Management Solutions (www.lmshealthpro.com) provides MIPS consulting and reporting services. We will help you avoid a 4% penalty for 2017, and assist you in earning positive payment adjustments in future years. To schedule a free consultation, go here: https://calendly.com/lmshealthpro.
