So what do you get when you mix Meaningful use (MU), PQRS(physician quality reporting system) and value-based modifier? The answer is MIPS or Merit-based incentive payment system( Medicare newest talent in the system of payment structure for the physicians). In April 27,2016 CMS proposed MACRA rule containing MIPS regulations. MIPs is what you can call bringing above mentioned plans onto one platform and consolidate them and further enhance their financial impact. The month of October in 2016 has been pretty happening for the payment structure and quality reporting systems as not only it marks the final implementation of ICD-10 billing system and also in this same month on Oct 14th,2016 the final rule for MIPS was published when CMS released final rule for the changes in MACRA (Medicare access and CHIP reauthorization ACT of 2015). MACRA replaced the SGR (Medicare Part B Sustainable Growth Rate) reimbursement method with Quality Payment Program(QPP) which consists of
1.MIPS(Merit-Base Payment incentive system)
2.APMs ( advanced alternative payment models)
MIPS make multiple quality reporting programs more streamline and into a single data submission.
MIPS SCORING SYSTEM:
MIPS basically has four categorizes on which eligible physicians performance is scored.
Above mentioned percentages are values for the year 2017 which also marks the first performance year for MIPS. For the year 2017 clinicians must be rated in at least two of above mentioned categories in order to obtain a final score. Clinicians can also choose to be scored as an individual or part of a clinician’s group which is defined by a tax ID. The weightage of QUALITY and RESOURCE USE will change to about 30% for the year 2019 and beyond. Clinicians participating in alternative payment methods like Medicare Shared Savings Program ACOs must be rated as groups and not individuals.
PERFORMANCE PERIOD: After being scored in above mentioned categories physicians get the final score which determines their MIPS payment adjustments for the calendar year coming second to the performance year. In simple words the score determined for a physician/health care provider in 2017 determines his or her adjustment for the year of 2019. The health care professional has time up to March 31st of the following year ( march of 2018 for the year of 2017) for the data to be submitted to CMS.
FINANCIAL IMPACTS OF MIPS:
The finally score obtained by a practice is what determines the financial impact of MIPS on that practice. The score determines incentive or penalties depending upon that 100 point score system. There is also a small inflationary adjustment to the Medicare part B schedule. The inflationary adjustment is about +0.5 percent increase per annum for the year 2016 to 2019. It resumes in 2026 with +0.25 percent adjustment for MIPS eligible clinicians. The organizations choosing to participate through advanced APM are exempt from MIPS.
Value based payment adjustments will determine the incentive/penalties under MIPS. Here is a breakdown of how the incentive/penalty will work
For learning in depth about how the value based payment adjustment will work for MIPS please check our related article.
ELIGIBILITY REQUIREMENTS FOR MIPS:
Physicians, Physician assistants, Clinical nurse specialist and certified registered nurse anesthetists.
In addition to the eligible parties for the above mentioned years pretty much every one related to health care industry including physical and occupational therapists, midwives, psychologists, clinical social workers and nutritionists all can be eligible.
The providers have to be the ones who bill for Medicare part B or CAH method II. Those who bill for Medicare part A or C or D, payments from CAH method I, FQHC is excused from MIPS payment adjustments.
EXEMPTIONS FROM MIPS:
So who is exempted from MIPS?
As mentioned above MIPS streamlines the data submission onto one platform. Existing PQRS reporting methods like registry, EHR and QCDR are expanded and used for scoring for the MIPS categories of Quality, ACI, CPIA (The resource use category is claim based). All this needs to be submitted by a provider on or before march 31st of the next year ideally to be considered for performance adjustment for the year next to it.
HOW TO PREPARE FOR MIPS:
A word of caution for those clinicians who have performed well under MU and have managed to avoid penalties under PQRS and VBM, they may not do as good on MIPS now because it includes all 3 so they may have to re-evaluate their performance status. January 1st 2017 is fast approaching and if you haven’t done so by now then do it ASAP now and re-evaluate your practice status, educate you staff of the new changes, improve your resources, organize your structure accordingly and estimate your own scores for MU, VBM, PQRS scores to see where you stand. Being prepared is very essential if you want to maximize your payments and earn higher incentives and avoid penalties. Analyze your declined claims for coding errors and let the transitional year get you ready for subsequent years.