Navigating MIPS Year 2

Britney 
Manager, Quality Program Specialist

It’s that time of the year again; on November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) issued the final rule that will make changes in the second year of the Quality Payment Program as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). As part of TSI Healthcare’s ongoing commitment to keeping you informed on the latest news in federal policy, this blog will cover the key changes your practice will face during the 2018 performance period of the Quality Payment Program (QPP). With these changes, CMS’ goal is to simplify the program, especially for small, independent, and rural practices, while ensuring fiscal sustainability and high-quality care within Medicare.

The items covered in this blog  ONLY pertain to the 2018 reporting year of the Merit-Based Incentive Payment System (MIPS) program.

 Reporting Period Options
The first major change your practice will see in 2018 is that Eligible Clinicians (ECs) and Groups will be required to report on the Quality category for the entire year. The Quality and Cost categories are the only categories that will require full year reporting; all other categories will retain their 2017 reporting period requirements. Find the reporting time period requirements below:

 

Who Will Participate?
MIPS ECs: In the 2018 performance year, there are no changes to which providers qualify as ECs.

Non-MIPS ECs: There was one key change to Non-MIPS ECs. In the 2018 performance year, clinicians who are below the Medicare low volume thresholds for payment OR patient volume will not need to submit data. This means that clinicians who bill out less than $90,000 in Medicare billing charges OR see fewer than 200 Medicare Part B patients are exempt from reporting MIPS data in 2018.

MIPS Composite Scoring Breakdown
The Cost category is here! In 2018, the Quality category will be weighted at 50% while the Cost category will be weighted at 10%.

During the 2017 performance period, the Quality category was weighted at 60% and the Cost category was weighted at 0%.   

Quality
As mentioned above, the Quality category will be weighted at 50% for the 2018 reporting period. As a reminder, this category will decrease to 30% for the 2019 performance year.

Topped Out Measures: Measures deemed “topped out” for two consecutive years will be capped at 7 performance points. This is a change from 2017 where topped out measures were capped at 10 performance points along with all other measures.

Improvement Bonus: MIPS ECs and Groups can earn a maximum of 10 percentage bonus points for improving performance on their Quality Category score from 2017 to 2018. You must fully participate in 2018 MIPS reporting to earn a bonus.

Data Completeness: In 2018, the data completeness threshold will increase from 50% to 60%. This means that at least 60% of patients will need to be seen and documented in the EHR.

Advancing Care Information (ACI)
Public Health and Clinical Data Registry Bonus: MIPS ECs and Groups can earn 10% toward their performance score for being interfaced with a public health or clinical data registry. A 5% bonus is still available for reporting to an additional registry separate from the performance score.

Certified EHR Technology Bonus: CMS will allow ECs to use either 2014 or 2015 CEHRT during the 2018 performance year. If you use 2015 CEHRT during your entire ACI reporting period, your practice will be required to report on ACI Core measures and will receive a 10% bonus.

Objective Exceptions: Any MIPS ECs or Group that makes less than 100 referrals during the 2018 reporting period can exclude the Health Information Exchange (HIE) objective. In addition, any MIPS ECs or Groups who write less than 100 prescriptions during the 2018 reporting period can exclude the
E-prescribing objective.

ACI Category Exceptions: CMS will allow the ACI category to be re-weighted to 0% and reallocated to the Quality category under the following circumstances:

 Automatic Reweight   Reweighting Through an Approved Application 
  • Hospital-based MIPS ECs
  • Ambulatory Surgical Center (ASC) – based MIPS eligible clinicians*
  • NPs, PAs, Clinical Nurse Specialists, and CRNAs
  • Clinicians in small practices (15 or fewer clinicians)
  • ECs whose EHR was decertified during the performance period*
  • Significant Hardship

 

The deadline to submit an ACI hardship exemption application for 2018 is December 31st.

Improvement Activities
Updates: With the release of the final rule, CMS added 21 new activities. There are now 112 activities in the inventory
for 2018.

Cost
As mentioned above, the Cost category will be weighted at 10% for the 2018 reporting period. As a reminder, this category will increase to 30% for the 2019 performance year.

Measures: The two measures that will be included are Medicare Spending per Beneficiary (MSPB) and Total Per Capita Cost for All Attributed Beneficiaries. The Episode-based Measures will not be included for the 2018 reporting year.

Improvement Bonus: MIPS ECs and Groups will have the potential to earn up to 1 bonus point for improving performance from 2017 to 2018 at the measure level.

Click here to learn more about the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Additional Bonus Points
There are additional ways your practice can earn bonus points toward your final MIPS Composite Score.

  • Small Practice Bonus: Practices with 15 or fewer ECs will have 5 bonus points added to their final MIPS Composite Score for the 2018 performance year
  • Complex Patient Bonus: Based on an average Hierarchical Condition Category (HCC) score, this bonus will award up to 5 bonus points to the ECs or Group’s MIPS composite score

Virtual Group Reporting Options
New in 2018, ECs will be able to participate in MIPS as a virtual group. This means that any combination of two or more TINs can elect to formally create a group with no restrictions based on specialty, geography, or total virtual group size. This is open to MIPS eligible solo practitioners and groups that have 10 or fewer eligible clinicians and exceed the low-volume threshold at the group level. When it’s time to report, virtual groups must be able to manually aggregate performance data across TINS for all MIPS performance categories. Once you declare membership in a virtual group, you will not be permitted to score MIPS individually or at the TIN level. The deadline for a Virtual Group Election is
December 31, 2017.

Want To Know More?
If you would like a more in-depth look at all of the changes your practice will face in 2018, watch our webinar “MIPS Program Year 2: Final Rule Overview.”

Watch Recording Now

Download our 2018 MIPS infographic for a summary of the program.

Download Infographic

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