The Centers for Medicare and Medicaid Services (CMS) says over 33,600 psychiatrists provide services reimbursed under Medicare Part B. The Merit-based Incentive Payment System (MIPS) is part of Medicare’s new Quality Payment Program (QPP). MIPS payment adjustments begin in 2019, and depend on your performance score from two years earlier. So now is the time to take action to avoid penalties in 2019.
How to avoid the MIPS penalty?
Must I Do MIPS Reporting to Avoid Future Penalties?
Yes: For 2017: I am a physician, physician assistant, nurse practitioner, or clinical nurse specialist, and I (or my group practice) have over 100 Medicare Part B patients AND over $30,000 in Part B allowable charges per year. These include separate Part B payments/patients seen through federally qualified health centers (FQHCs) and rural health centers (RHCs). This is a great year to try out MIPS reporting, since less is required to avoid future penalties.
For 2018 & Beyond: The low-volume threshold MAY increase to $90,000/200 patients per
year.
I am a “partially qualifying participant” in an Advanced Alternative Payment Model and I choose to participate in MIPS reporting.
This is a great year to try MIPS reporting. Minimal reporting is needed to avoid a future penalty. And it is good preparation for when other payors adopt quality programs similar to MIPS.
Many exempt
Several classes of physicians, accounting for about two-thirds of the clinician population, are exempt from MIPS and QPP reporting. These include:
- Physicians who practice exclusively in Rural Health Clinics or Federally Qualified Health Centers.
- Physicians enrolling in Medicare for the first time during a MIPS reporting period.
- Those who bill only $30,000 or less in Part B charges or who have only 100 or fewer Part B-enrolled Medicare beneficiary patients.
- Those participating in an advanced alternative payment model (APM).
- Non-patient-facing specialists who bill for only 100 or fewer patient-facing encounters during a reporting period.
Physicians can check their MIPS status by entering their National Provider Identifier into the CMS QPP portal.
It’s unknown what kind of transitional allowances might be developed for 2018, so physicians are encouraged to practice filing quality measures in preparation for when full reporting is required.
What Should I Report to Avoid a MIPS Penalty?
To avoid 2019 MIPS penalties, you only need to do ONE of the following:
- Report ONE quality measure for ONE patient – Via claims, electronic health record (EHR), qualified data registry, or qualified clinical data registry (QCDR).
- Report ONE improvement activity — Submit an attestation (marked “Yes”) that you have
performed the activity for at least 90 days, to CMS via the QPP website, EHR, qualified registry, or QCDR. - Report ALL base score measures for the advancing care information category, for use of
certified electronic health record technology (CEHRT), for part of 2017.
CMS Proposed Quality Payment Program Rule For Providers 2018
On June 20, 2017, The Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) proposed rule, which proposes policies for the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) programs 2018 to impact 2020 Medicare physician payments.
It doesn’t seem that long ago when MACRA was first announced and the final rule was released last October. But now, providers are anticipating what’s ahead for the program in its second year, especially for the Quality Payment Program. The healthcare industry received its first glance at what’s in store for 2018 as CMS released the QPP proposed rule earlier this week.
Read our blog post to more about on CMS http://localhost/main-site-update/cms-releases-2018-proposed-quality-payment-program-rule/
CMS Final 2019 MIPS Rules Are Here – What You Need to Know
CMS has made several changes to the 2019 Merit-based Incentive Payment System (MIPS) as part of the final 2019 Medicare physician fee schedule. While CMS did not finalize any sweeping changes to the program, physicians should be aware of changes to MIPS weights and scoring, the low-volume threshold exemption, and other provisions that will impact reporting in 2019.
Changes to MIPS performance weights and scoring
CMS has announced that the minimum score necessary to avoid a penalty in 2021 (reporting in 2019) is 30 points — this is twice the 2018 threshold of 15 points. The minimum required number of points to be eligible for the exceptional score bonus is 75.
CMS also finalized its proposal to reduce the weight of the Quality category from 50% to 45% and increase the Cost category from 10% to 15%.
Tweaks to the MIPS low-volume threshold exemption
CMS added an opt-in opportunity for physicians and providers who want to participate in MIPS but meet the low-volume threshold exemption criteria.
If a MIPS-eligible clinician meets or exceeds one, but not all, of the low-volume threshold exemption criteria — as defined by dollar amount ($90,000), beneficiary count (200), or covered professional services to Part-B enrolled individuals (minimum threshold of 200) — then the clinician may elect to submit data and opt-in to MIPS.
If a clinician does not meet at least one of these low-volume determinations — or meets at least one, but not all, of these low volume determinations and elects not to opt-in — the clinician is not eligible and is excluded from MIPS.
At WWS, we understand not only how important it is to avoid penalties, but how to help you stay compliant where any billing issue is present.
Feel free to schedule a live demo http://localhost/main-site-update/live-demo/ with us today to find out more about what we can do for you.
]]>It doesn’t seem that long ago when MACRA was first announced and the final rule was released last October. But now, providers are anticipating what’s ahead for the program in its second year, especially for the Quality Payment Program. The healthcare industry received its first glance at what’s in store for 2018 as CMS released the QPP proposed rule earlier this week.
What changes mean for Providers?
More solo practitioners and small groups will be excluded from the Merit-based Incentive Payment system (MIPS) in 2018; those remaining in the program will need to prepare for increased reporting requirements. Simultaneously, many healthcare organizations will need to begin defining a broader value-driven care strategy, and considering how to structure contracts with non-Medicare payers.
CMS will accept comments on the proposed rule until August 18, 2017, and the Final Rule will be published in the fall.
MIPS Transition Reporting and Scoring Thresholds
CMS proposes a continuation too many of its initial transition year policies in 2018 and to moderately increase the thresholds for MIPS eligible clinicians from the 2017 performance year. This includes:
- Increasing the performance threshold from three points to 15 points in 2018 and maintaining the additional performance threshold at 70 points.
- Slightly increasing data completeness thresholds for most reporting mechanisms within the Quality category from 50 percent in 2017 to 60 percent in 2019 and continuing to implement scoring floors.
- Increasing the performance period to a full calendar year for the quality category in 2018, while keeping the performance periods for Improvement Activities and Advancing Care Information at 90 days.
Highlights from the QPP Proposed Rule
- 2018 will feature continuation of “pick your pace” for the new payment system’s data reporting and expands exemption of physicians from mandatory participation.
- Physicians will be able to participate in MIPS through Virtual Groups working with other small practices to combine their administrative costs.
- Physicians in small practices will receive extra “bonus” points within the Composite Performance Score for MIPS to recognise their value to communities where they practice.
MIPS Cost Performance Category Delay
The cost performance category has been a significant concern for clinicians and provider groups of all sizes and as a result, CMS proposed to eliminate the domain for an additional year.
Changes to the Cost category proposed by CMS include:
- Measuring clinicians on Medicare Spending per Beneficiary (MSPB) and total per capita cost measures. However clinicians will not be scored on these in 2018.
- Eliminating the previously finalized 10 episode-based measures and continuing to work with stakeholders on replacing these measures.
Virtual Groups in 2018
Beginning in 2018, solo practitioners and groups of 10 or fewer will be able to partner virtually with other solo practitioners or groups of 10 or fewer, regardless of location or specialties. They will generally be treated as any other group in the QPP. This could be an attractive option for clinicians who may not have the resources to perform well in the QPP independently.
All-Payer Combination Advanced APM Option
Alternative Payment Model (Advanced APM) track by participating in a combination of Medicare and other payer models. In its 2018 proposed rule, CMS provides the first details of the All-Payer Combination methodology which will be used to shape contracts with non-Medicare payers over the next several years. Key provisions include:
- Determining Qualifying Participants under the All-Payer Combination Option at the individual clinician level only.
- Allowing clinicians to self-submit other payer data to CMS without requiring that payers attest to this data.
- Implementing an eight percent revenue-based threshold in addition to the existing benchmark-based total risk threshold, similar to the finalized Medicare nominal amount standard
For more information or to discuss implications for your organization, please contact us.
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CMS will be sending letters to physician practices throughout the month of May with important, practice-specific information regarding eligibility to participate in the Merit-Based Incentive Payment System (MIPS) at the group/individual level for the performance year 2017.
Everyone Taxpayer Identification Number (TIN) should enrolled to participate in the Medicare program will be receiving a letter that includes a summary of the Quality Payment Program (QPP),
The Following steps towards participation and reporting, and the exemption eligibility guidelines:
- Being a less volume clinician: Identified by using historical Medicare claims data and defined by having less than $30,000 in annual Medicare Allowable charges or by treating fewer than 100 Medicare patients.
- First-year Medicare enrolled clinicians.
- Not being one among the categories of clinicians included in the program’s first year, i.e. therapists, audiologists, and others.
- Participants in certain Advanced Alternative Payment Models (APM), if participation is sufficient to meet certain thresholds.
If you find that your questions regarding MIPS are still left unanswered, Please give us a call or send an email at +1(302) 613-1356 or support@wonderw.com
MIPS Participation Attachments:
The true value of the letter is found in its two attachments which contain information specific to you and your practice.
Attachment A: It contains the Eligibility /Exemption status for the TIN and each individual provider enrolled under the TIN. This can be used to help you determine whether your group will be required to participate in MIPS for performance year 2017 and if you should report as a group or as individual clinicians.
NOTE: If your group chooses to report as a group, MIPS assessment will be based on All Individuals in the group. This will not take into consideration any providers who would be individually exempt from participation.
Attachment B: It contains CMS’s best effort to answer some of the many questions you may have about the Quality Payment Program, its two tracks: MIPS and APM, and how you should prepare for participation.
If you have not received your letter from CMS, you can also look up your MIPS eligibility on the QPP website at: http://qpp.cms.gov/learn/eligibility
More information on MACRA, MIPS can be found on our blog at http://localhost/main-site-update/among-uninformed-macra-mips/
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