CMS released the final rule that calls for significant legislative changes to the Medicare Access and CHIP Reauthorization Act (MACRA) in October 2016. MACRA repeals the Medicare Part B Sustainable Growth Rate (SGR) reimbursement formula and replaces it with Merit-Based Incentive Payment System or MIPS.
As per MIPS, 85% of the Medicare reimbursements must be tied to quality. To accomplish this, the health care providers should take part of an Alternative Payment Model or the Merit-based Incentive Program System (MIPS).
MIPS will measure Medicare Part B providers in four different categories. The providers will be scored on a scale from 1 to 100. Based on their score, providers will either get incentive, will be penalized, or remain neutral.
MIPS defines four categories of eligible clinician performance:
- Quality (60% for 2017)
- Advancing Care Information (25% for 2017)
- Cost (0% for 2017)
- Improvement Activities (CPIA) (15% for 2017)
The final score of a clinician for a performance year will determine the payment adjustments for MIPS in the second year after the performance year. In addition to that, the annual final score of each clinician will be released to the public by CMS.
To ease the transition for the 2017 performance year, there are varying extents for organizations to either participate in or alternatively, be exempt from MIPS. Here is a brief summary of the options:
- No participation: Organizations not exempt from MIPS that does not send in any 2017 data will receive a negative 4% payment adjustment.
- Report one measure for a minimum 90-day period to avoid a penalty: Reporting only one Quality, ACI, or CPIA measure will earn enough MIPS points to avoid a penalty and possibly earn a small incentive.
- Report more than one measure for a minimum 90-day period: Reporting more than one measure in any or all of the Quality, ACI, or CPIA categories avoids a penalty, maximizes the MIPS score, and potentially earns the highest possible incentive.
- Participate in an Advanced APM: Organizations that participate through an Advanced APM earn a 5% Part B bonus and are exempt from MIPS.
To Prepare For MIPS Reporting
There are a few things, which medical billing services need to do in order to be prepared for the start of MIPS reporting. This includes:
- Educate your clients: physicians, clinics and provider groups about the details of MIPS, as soon as possible.
- Finding the current MIPS score of your organization. You can make use of your current MU, VBM and PQRS score.
- Optimizing the PQRS, MU, and VBM quality to ensure maximum MIPS score.
- Evaluating the resources, staff, and organizational structure of each practice. For instance, you may combine the PQRS and MU efforts under a single person.
Medical billing services also need to find and understand the CY2017 deadlines that affect the CY2018 APM or the MIPS participation. For instance, the NCQA PCMH application deadlines or Medicare Shared Savings Program track 2/3 ACO to get MIPS points or exemptions. It is also recommended to monitor and improve their existing programs to be prepared for MIPS implementation.
Please feel free to post your comments or questions in the fields below. Our MIPS professionals at 4D Global will try to help.