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Developing a 2018 MIPS Reporting Strategy to Avoid a Penalty

Loading up MIPS reporting on one of three performance categories can help eligible clinicians prevent a negative payment adjustment in 2020, the AMA found.

Merit-Based Incentive Payment System (MIPS) reporting

Source: Thinkstock

By Jacqueline LaPointe

- Eligible clinicians can avoid a financial penalty under the Merit-Based Incentive Payment System (MIPS) in 2020 by focusing their reporting on one of three performance categories: Quality, Improvement Activities, or Promoting Interoperability, the American Medical Association (AMA) recently advised.

Loading up reporting on one of the three MIPS performance categories will ensure eligible clinicians meet the new 15-point threshold in 2018, the AMA stressed in its new resource guide.

For MACRA’s second performance period, CMS upped the MIPS reporting stakes. In 2017, eligible clinicians only had to earn three points to prevent a negative payment adjustment by the 2019 payment year. That means clinicians could report on just one Quality measure on one eligible patient to avoid a penalty.

Now, eligible clinicians must earn at least 15 points in 2018 to avoid a negative payment adjustment. And clinicians who fail to report MIPS measures or score lower than 15 points will face a penalty up to five percent in 2020.

For eligible clinicians who do not qualify for special circumstances, the key to quickly meeting the increased MIPS threshold is reporting on Improvement Activities, the AMA advised.

Reporting on Improvement Activities to avoid a MIPS penalty

READ MORE: Dissecting Merit-Based Incentive Payment System Reporting

CMS approved 113 Improvement Activities for the 2018 MIPS performance period. The activities are categorized as either medium or high-weighted, with high weighted activities earning clinicians more points compared to the medium-weighted activities.

The activities are also divided into subcategories, such as achieving health equity, care coordination, beneficiary engagement, and population health.

To earn points on Improvement Activity reporting, eligible clinicians must collect data for the activities for at least 90 days during 2018.

They can submit Improvement Activities data to CMS by attesting through the Quality Payment Program data submission system, their EHR system, a qualified clinical data registry, or a qualified registry.

For eligible clinicians in small practices of 15 or fewer clinicians, reporting on just one high-weighted Improvement Activity will earn eligible clinicians in small practices 15 points, the AMA stated.

READ MORE: 4 Strategies for Merit-Based Incentive Payment System Success

Eligible clinicians in small practices earn more points for reporting on Improvement Activities because the value-based purchasing program rewards double points to small practices.

These clinicians will also receive the five-point small practice bonus, bringing their total MIPS score up to 20 points.

Eligible clinicians in large practices of 16 or more clinicians must report on either two high-weighted or four medium-weighted Improvement Activities to earn 15 points in the MIPS performance category, the industry group added.

Using Quality measures to prevent a negative payment adjustment

Eligible clinicians in small practices can also focus their MIPS reporting strategy on Quality measures to avoid a financial penalty in 2020, the AMA found. Earning a minimum of 18 out of 60 points in the performance category will meet the reporting threshold in 2018.

To earn 18 points in the Quality performance category, eligible clinicians must report on six measures.

READ MORE: Top 5 Facts About the Merit-Based Incentive Payment System

Clinicians can choose from 275 Quality measures to meet the MIPS reporting threshold in the second year of the value-based purchasing program. The measures are divided into types, such as efficiency, outcome, process, and patient engagement.

Participating clinicians can also select measures based on their specialty. CMS developed specialty measure sets to help specialists identify the appropriate Quality measures for their clinical area.

CMS requires eligible clinicians to report on at least six Quality measures for the 12-month performance period, which is from Jan. 1 to Dec. 31, 2018. One of the measures must also be an outcome measure, or a high-priority measure if no applicable outcome measure exists.

Eligible clinicians in small practice can submit Quality performance data to CMS using their EHR system, a qualified clinical data registry, a qualified registry, or claims. Clinicians participating in a virtual group, which allows small practices to band together for MIPS reporting, can also use the CMS Web Interface or the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey.

Splitting reporting between two MIPS performance categories

Eligible clinicians do not have to put all their eggs in one basket to prevent a negative payment adjustment based on their 2018 MIPS performance. The AMA also found ways for clinicians to report on two performance categories to meet the 15-point threshold.

For eligible clinicians in small practices, the industry group recommended either reporting on Improvement Activities and Quality or Promoting Interoperability and Quality.

To earn 15 points, clinicians in small practices can report on one medium-weighted Improvement Activity and one Quality measure. The reporting will earn clinicians ten points and the five-point small practice bonus will bring their total score to 15 points.

Eligible clinicians in small practices can also report on one Quality measure and earn 50 out of 100 points in the Promoting Interoperability performance category.

Formerly the Advancing Care Information performance category, Promoting Interoperability measures a clinician’s patient engagement and electronic exchange of information using certified EHR technology. Clinician’s must submit data on four or five Base Score measures in the category for 90 days or more in 2018.

The number of Base Score measures required will depend on the Certified EHR Edition clinicians are using.

The Edition will also dictate from which measure set the clinician can choose. Eligible clinicians using the 2014 Edition can only report on measures in the Promoting Interoperability Transition Objectives and Measures set, while clinicians with the 2015 Edition can report on either the Promoting Interoperability Objectives and Measures set or the Promoting Interoperability Transition Objectives and Measures set, or a combination of both.

CMS will accept Promoting Interoperability data submissions from the Quality Payment Program submission system, a clinician’s EHR system, a qualified clinical data registry, or a qualified registry.

Eligible clinicians in large practices can also report on Promoting Interoperability and Quality measures to meet the MIPS reporting threshold. These clinicians must report the Promoting Interoperability base score to earn 50 out of 100 points and two Quality measures to earn a minimum of six out of 70 points.

AMA noted that it assumed the quality measures reported would meet the data completeness requirement, which is 60 percent of all eligible patients and each measure contains data for a minimum of 20 patients. The industry group also assumed that the practice scored on the all-cause hospital readmission measure.

In total, the Promoting Interoperability and Quality reporting strategy will earn eligible clinicians in large practices 16.7 points, the AMA found.

Clinicians in large practices can also report on Improvement Activities and Quality measures to avoid a financial penalty in 2020, the industry group added.

Reporting on two medium-weighted Improvement Activities and four Quality measures will earn these clinicians 16 points in 2018 as long as the clinicians earn a minimum of 12 out of 70 points in the Quality performance category and 20 out of 40 points in the Improvement Activities performance category.

Eligible clinicians should be considering their 2018 MIPS reporting strategy as soon as possible. With most performance categories requiring at least 90 days of data collection, and 365 days for the Quality category, clinicians should develop their reporting strategy now to ensure they have complete data to avoid a penalty by 2020.

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