There has been widespread fear of MIPS and its quality measures for some time. The program has been on the table for awhile, but has only recently began to gain momentum, particularly within the past few months. Before we dive into the ocean that is MACRA and MIPS though, it is very important that you do register for MIPS. Not registering can result in hefty financial penalties, which will only increase as time goes on.
Perhaps the biggest concern being expressed is that there is no time to prepare appropriately for MIPS measures before the December 31, 2017 deadline. While there should be a certain level of urgency to submit MIPS measures well before that date, there is also no need to panic. Especially since MIPS is offering a "Pick YourPace" option for the 2017 transition year. But first, there should be some clarification.
What Exactly is MIPS?
To put it plainly, and to borrow from CMS itself, MIPS is a new program that streamlines three currently independent programs to work as one and to ease clinician burden. MIPS also has a fourth component that promotes ongoing improvement and innovation to clinical activities. Simplifying it further, the main focus of MIPS is quality, resource use, clinical practice improvement activities, and advancing care information. Clinicians are also provided the flexibility to choose the activities and measures that are most meaningful to the practice to demonstrate performance.
Timing of 2017 MIPS Transition Year
2017 is regarded as the "Performance Year." The first performance period opened back on January 1, 2017 and and will close December 31, 2017. 2018 is the year when MIPS picks up some steam. In order to potentially earn a positive payment adjustment under MIPS, data must be submitted regarding the care provided and how your practice used technology in 2017 to MIPS by the deadline of March 31, 2018. Between March 2018 and January 2019, Medicare will offer feedback about your performance after you send your necessary data. On January 1, 2019, the payment adjustment period begins. You have the opportunity to earn positive MIPS payment adjustments if you submitted your 2017 data on March 31, 2018. Easy enough, right?
Pick Your Pace
There are four options for participation. You can either 1) submit something, 2) submit for part of the year, 3) submit for a full year, or 4) don't participate. To elaborate further, we'll break each option down.
Option 1: Submit Something
- Submit minimum amount of 2017 data to Medicare by March 31, 2018
- Avoid 4% penalty
- Minimum amount of data: 1 quality measure, or 1 improvement activity, or required base score advancing care information measures
Option 2: Submit for Part of the Year
- Physicians may submit 90 days of 2017 data to Medicare
- Doing so may earn physicians a positive payment adjustment, depending on performance
- You must submit performance data by March 31, 2018
Option 3: Submit for a Full Year
- Physician may submit a full year of 2017 data to Medicare
- Doing so may earn physicians a positive payment adjustment
- Best way to earn largest payment adjustment is to submit data on all MIPS performance categories
- Full participation in MIPs means the clinicians should, at least, meet the following criteria: Report six quality measures, report four medium-weighted or two high-weighted improvement activities, report advancing care information measures
- positive adjustments are based on performance
Option 4: Do Nothing
- Not participating in the Quality Payment Program for the transition year will result in a 4% penalty
MIPS is definitely worth your attention and time. However much of a pain-in-the-rear it is. While some may blow it off and opt to just take the penalty, this is not the wisest decision. In the march towards providing better quality care for patients, MIPS offers a simpler transition path than many expected. Or even realize existed in the first place. While it is fast approaching, MIPS should not incite panic amongst clinicians. Simply follow CMS's full scoring methodology for MIPS here.
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