As we near October 2nd, the last day to start participating in MIPS and satisfy the 90-day minimum performance period, it's important to separate fact from fiction. According to CMS, nearly 600,000 clinicians will participate in MIPS under the Quality Payment Program but there's still some confusion surrounding participation options, eligibility, and the program in general. Here we'll clear up some common misconceptions about the MIPS program to help you better understand what MIPS is and how it affects your practice.
1. All clinicians are eligible for MIPS.
There are exemptions to the MIPS program. If any of the following apply to you, you may be exempt from MIPS. However, it is best that you check this CMS web page where you can see if you need to submit data to MIPS. You will need to enter your 10-digit NPI in order to make this inquiry.
- You are newly enrolled in Medicare for the first time during the performance period.
- You are participating in an Advanced Alternative Payment Model (APM) as a "Qualifying APM Participant."
- You fall below the low-volume threshold of seeing 100 or fewer Medicare Part B patients a year or having less than or equal to $30,000 in allowed Medicare Part B charges in a year.
Still have questions? Here's more about these exemptions from MIPS.
You are newly enrolled in Medicare.
Clinicians who enroll in Medicare for the first time during a MIPS performance period are exempt from reporting on measures and activities for MIPS until the following performance period. In order to be considered a new Medicare-enrolled eligible clinician, clinicians cannot have previously submitted claims to Medicare under any other enrollment as an individual or through a group.
You fall below the low-volume threshold.
Providers who have met a minimum volume threshold of Medicare Part B patients or payments will be exempt from MIPS.
Clinicians that bill less than $30,000 in Medicare Part B allowed charges or who provide care for 100 or fewer Medicare Part B enrollees during either of the two previous years are exempt from MIPS for the 2017 performance year. If a clinician meets any one of those two thresholds then they are exempt from MIPS under the low-volume provider exemption. This threshold is the same whether the clinician reports individually or as a group.
You are participating in an Advanced Alternative Payment Model (APM) as a "Qualifying APM Participant."
Providers who participate in an Advanced Alternative Payment Model (AAPM) may be exempt from the Merit-Based Incentive Payment System (MIPS).
Advanced APMs are APMs that meet these additional requirements:
- Payment based on quality measures comparable to those in the MIPS quality performance category
- Participants use certified EHR technology
- APM entities must either bear more than “nominal financial risk” for monetary losses or the APM is a Medical Home Model expanded by the CMS Innovation Center
Click here to learn more about Advanced APMS and view a full list of approved Advanced APMS for the 2017 performance year.
Are you part of a Rural Health Center or FQHC?
Clinicians practicing in RHCs or FQHCs who provide services that are billed exclusively under the RHC or FQHC payment methodologies are not required to participate in MIPS (they may voluntarily report on measures and activities under MIPS) and are not subject to a payment adjustment. However, if these clinicians provide other services and bill for those services under the Physician Fee Schedule (PFS), they would be required to participate in MIPS and such other services would be subject to a payment adjustment.
2. Participating in MIPS is time consuming.
Most providers assume that participating in MIPS is time consuming and time is one thing they do not have. However, MIPS does not have to be a huge time investment. Your entire workflow should be evaluated, yes but often times, it doesn't need to be changed dramatically in order for you to participate in MIPS.
Most EHR systems also offer a MIPS dashboard which can also help you stay on track and develop an effective plan for participating in MIPS. Plus, with 2017 being the transition year, there are multiple options to participate. One of these options only requires that you submit only one quality measure for one Medicare Part B patient.
Learn more about MIPS participation options here but don't assume that MIPS is going to take a massive amount of time. Especially considering that if you choose not to participate, your revenue is going to take a hit.
3. MIPS scores will be publicly available online.
MIPS scores are going to be publicly reported on the CMS Physician Compare consumer website. This, along with the rise of consumerism in healthcare, means that patients will likely make decisions based on a clinician’s MIPS score which in turn can affect your patient volume.
Furthermore, clinician contracts will likely incorporate MIPS scores because new clinicians joining practices will bring along their MIPS scores and thus, their incentives and penalties as well.
4. I have to submit a full year of data to CMS for MIPS.
Although submitting a full year of data to CMS is an option, it is not required. There are four MIPS participation tracks that allow flexible attestation for providers which include:
- Submit Minimum Data: Submit a minimum amount of 2017 data to Medicare and you can avoid a downward payment adjustment. This minimum amount could be, for example, one quality measure or one improvement activity for any point in 2017.
- Partial a Partial Year: Submit 90 days of 2017 data to Medicare and you may earn a neutral or small positive payment adjustment.
- Submit a Full Year: Providers who are ready to embrace MACRA standards may elect to submit all required data to the Quality Payment Program for the entire year and qualify to earn a “modest positive payment adjustment.”
5. You must notify CMS that you are reporting as a group (GPRO).
Sound familiar? GPRO was introduced with PQRS as a reporting option and each year CMS required that Eligible Providers register using the CMS online portal to alert CMS that they would be using GPRO.
If you plan to report as a group for MIPS, you do not need to notify CMS.
However, if you choose to report as a group and are planning on using the CMS Web Interface as your submission method you must have already notified CMS by June 30, 2017.
According to CMS, for 2017 groups are able to choose from a list of available data submission mechanisms (some options vary based on performance category) including:
- CMS Web Interface (only available to groups with 25 or more eligible clinicians)
- Qualified Clinical Data Registry (QCDR)
- Qualified Registry
- Electronic Health Record (EHR)
- Administrative Claims
- CAHPS for MIPS Survey (only available to groups with 2 or more eligible clinicians)
Between April 1 through June 30, 2017, registration was open for groups planning to participate in MIPS via the CMS Web Interface or Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS survey. Only these 2 submission options require registration.
For more information on individual and group participation and options for reporting your data, visit the CMS Quality Payment Program Website.