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Preparing for 2018 MIPS Reporting: Top 5 Questions for Small Practices

The Merit-Based Incentive Payment System (MIPS) is one of two payment tracks used by the Centers for Medicare and Medicaid Services (CMS) to determine Medicare Part B payment adjustments for eligible clinicians under the Quality Payment Program. MIPS combines elements of prior Medicare quality programs into one MIPS score. Reporting season for the 2018 performance year is coming soon, so get ready and embrace your EHR!

You can think about quality program participation like a child, the more you feed and nurture a child, the healthier they will be. In turn, the more time and effort you put into each measure workflow, the greater your chances are to be successful. To assist with a successful outcome, take a look at the top 5 questions asked by Practice Fusion providers.

1. How do I know if I am eligible for MIPS especially if I see both Medicaid and Medicare patients, and I already participate in Meaningful Use?

For the 2018 performance year, a MIPS eligible clinician is defined as the following licensed providers and any group that includes such professionals:

  • Doctors of Medicine
  • Doctors of Osteopathy
  • Osteopathic Practitioners
  • Doctors of Dental Surgery
  • Doctors of Dental Medicine
  • Doctors of Podiatric Medicine
  • Doctors of Optometry
  • Chiropractors
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists

You should check your individual eligibility for MIPS directly with CMS. MIPS eligibility is assessed annually, so be sure to check for 2018, even if you participated last year.

2. What are the eligibility exemptions for MIPS?

There are a few situations when a Medicare provider may be exempt from participating in MIPS in a given performance year. For the 2018 performance year, those exemptions include:

  1. If you are a newly enrolled Medicare provider that enrolled during the performance year (exemption applies until the following performance year)
  2. If you have less than or equal to $90,000 in Medicare Part B allowed charges OR less than or equal to 200 Medicare Part B Beneficiaries in 2018
  3. If you are significantly participating in an Advanced Alternative Payment Model (APM). Advanced APMs are a particular type of alternative payment model that enable clinicians and practices to earn greater rewards for taking on risk related to their patients’ outcomes.

Practice Fusion encourages all providers to check their individual eligibility for MIPS directly with CMS.

3. How will I report my data to CMS?

There are several different ways that you can report your MIPS data to CMS in the 2018 performance year. The methods for data submission can vary between MIPS performance categories and you may use more than one submission method across different categories. Some MIPS reporting options include submitting data to CMS via a qualified registry or QCDR, downloading a CMS-compliant file from your certified EHR and uploading it to the CMS Quality Payment Program website, or reporting G-codes on your Medicare Part B claims through the year.

Practice Fusion customers can report MIPS data to CMS directly through the Practice Fusion EHR by registering for the Practice Fusion Qualified Clinical Data Registry (QCDR). This is the most streamlined way to report to CMS if you use Practice Fusion - no need to download files or fill in online worksheets. More information on how to register for the Practice Fusion QCDR will be available in early 2019.

4. When is the MIPS data submission deadline for the 2018 performance year?

The MIPS data submission window for the 2018 performance year is January 1, 2019, through March 30, 2019.

5. If I choose to report the minimum requirements to avoid a negative payment adjustment, what is required of me?

For performance year 2018 reporting, which determines your 2020 payment, CMS has set the MIPS performance threshold at 15 points. If you are interested in earning a positive 5% payment adjustment, you must score above the performance threshold.

  • In the Quality performance category, eligible clinicians will report up to 6 quality measures, including at least one patient outcome measure, for a full performance year.
  • Most participants will complete up to 4 Improvement Activities for at least 90 days. Groups with fewer than 15 participants, or clinicians in a rural or a health professional shortage area, may complete up to 2 improvement activities for at least 90 days.
  • Promoting Interoperability (PI), formerly Advancing Care Information (ACI) replaces the Medicare EHR Incentive Program (Meaningful Use). A clinician can choose to report on the minimum 4 required measures to achieve the PI base score, which consists of Security Risk Analysis, e-Prescribing, Providing Patient Access, and Health Information Exchange.
  • The Cost performance category replaces the Value-Based Modifier program and will consist of specialty-based measures that encourage efficient resource use.

Like you help your child with homework and school projects, you can help your practice members study the measures inside and out memorizing workflows until they become second nature. Use the dashboard as your report card to check how you’re doing. Ask your teacher (CMS) or your teaching assistant (Practice Fusion) for guidance along the way to ensure you graduate on time, hopefully with honors (a positive payment adjustment in 2020).

Many more questions can be asked and answered on the Practice Fusion help page.

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