MIPS – Changes for 2018

Just when you think you have a proficient grasp on the new CMS Quality Payment Program-The Merit-based Incentive Payment System (MIPS) has changes in store for January 1, 2018.  There are some helpful changes such as an increase to the “Low-Volume threshold” and additional points being awarded for improvement in the Quality and cost category to name a few. There are some other changes however, that necessitate your attention such as needing a higher score in your overall final MIPS score in order avoid a negative payment adjustment in 2020. A final score of 15 points will be needed to avoid a penalty in payment year 2020, this is an increase from 3 points in 2017. This is the first year that the Cost category will be included in your final score and is worth 10% of your total MIPS score for 2018 and for the quality category you must report data on the full calendar year.

Many of the changes have been outlined below but it is your responsibility to review all the changes for the upcoming year so that you can avoid a negative payment adjustment in 2020 and help secure a healthy financial outcome for your practice.

CMS has provided some good resources that your practice should review, specifically:

  • Year 2 Overview fact sheet
  • Final rule executive summary

These documents and many others can be found at: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html

Final Scoring Changes for MIPS Year 2 (2018)

Final Score 2018 Change for 2017 Y/N Payment Adjustment in 2020
≥ 70 Points N POSITIVE ADJUSTMENT GREATER THAN 0%
ELIGIBLE FOR EXCEPTIONAL PERFORMANCE BONUS – MIN. OF ADDITIONAL 0.5%
15.01 – 69.99 Points Y POSITIVE PAYMENT ADJUSTMENT GREATER THAN 0%
NOT ELIGIBLE FOR EXCEPTIONAL PERFORMANCE BONUS
15 Points Y NEUTRAL PAYMENT ADJUSTMENT
3.76 -14.99 Points Y NEGATIVE PAYMENT ADJUSTMENT GREATER THAN -5% AND LESS THAN 0%
0 – 3.75 Points Y NEGATIVE PAYMENT ADJUSTMENT OF -5%

 

There is no change in the type of clinician included in MIPS year 2 (2018)

  • Physicians (Defined by Medicare), PAs, Nurse Practitioners, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists.

The Low-Volume Threshold for 2018 has changed

  • If you are a clinician who bills Medicare $90,000 or more a year in Medicare Part B allowed charges or provide care to 200 or more Medicare patients a year, you MUST report in 2018. This was increased from $30,000/100 patients in 2017

There is no change in Basic Exemptions in year 2

  • You are exempt if you are newly enrolled in Medicare in 2018 (you must report in 2019)
  • You are exempt if you are below the low-volume threshold as noted above
  • Significantly participate in Advanced APMs

Reporting Options

  • Report as an individual, group (2 or more NPIs under 1 TIN, or Virtual Group

Submission Mechanisms (No change from 2017)

Only 1 submission mechanism can be used per performance category

 

Performance Category Submissions for Individuals Submissions for Groups/Virtual Groups
Quality QCDR, Qualified Registry, EHR, Claims QCDR, Qualified Registry, EHR, CMS Web Interface (groups of 25 or more)
Cost Administrative claims (no submission required) Administrative claims (no submission required)
IA Attestation, QCDR, Qualified Registry, EHR Attestation, QCDR, Qualified Registry, EHR, CMS Web Interface (groups of 25 or more)
ACI Attestation, QCDR, Qualified Registry, EHR Attestation, QCDR, Qualified Registry, EHR, CMS Web Interface (groups of 25 or more)

 

Category Information

Quality:

  • Weighted score – worth 50% of your total MIPS score
  • Select 6 measures (1 must be an outcome or high priority measure)
  • Submit on 50% or more of qualifying Medicare Patients (measures that do not meet data completeness criteria will be worth only 1 point
  • Report for a full 12 months (1/1/2018 – 12/31/18)
  • Review “6 Topped Out Measures for 2018”

Cost

  • Weighted score – worth 10% of your total MIPS score
  • Medicare will calculate Cost scores based on 12 months of claims (1/1/2018 – 12/31/18) – no additional data submission is required

Improvement Activities (IA)

  • Weighted score – worth 15% of your total MIPS score
  • Review the list of activities – will go up from 92 to 112 in 2018
  • The goal for most eligible clinicians is to achieve a total of 40 points (medium=10, high=20)
  • Report for at least 90 consecutive days in 2018. If attesting, “yes” is all that is required to complete

Advancing Care Information (ACI)

  • Weighted score – worth 25% of your total MIPS score
  • May use either 2014 or 2015 CEHRT or a combination; there are still 2 measure sets
  • Still must report on all Base measures to receive a score and then can report on performance and bonus measures
  • Report for at least 90 consecutive days in 2018.

Additional Bonus Opportunities

  • MIPS scoring improvement for Quality and Cost
    • Quality – Based on rate of improvement. A higher improvement will result in additional points- up to 10 % are available
    • Cost – Based on statistically significant changes at the measure level- up to 1% is available
  • Complex Patient Bonus
    • Up to 5 bonus points are available for treating complex patients based on medical complexity.
    • Eligible clinicians or groups must submit data on at least 1 performance category to earn the bonus
    • Scoring is based on Hierarchical Conditions Category (HCC)
  • Small Practice Bonus
    • 5 bonus points added to the final score of any MIPS eligible clinician or group who is in a small practice (15 or fewer clinicians)
    • Eligible clinicians or groups must submit data on at least 1 performance category to earn the bonus