Confused by the MIPS Deadline?

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) replaced three Medicare reporting programs (Medicare Meaningful Use, the Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier) with the Merit-Based Incentive Payment System (MIPS). In MIPS, you earn a payment adjustment based on evidence-based and practice-specific quality data. Based on your performance in 2017, you will see a positive, neutral, or negative adjustment of up to 4% to your Medicare payments for covered professional services furnished in 2019. This adjustment percentage grows to a potential of 9% in 2022 and beyond. In addition, during the first six payment years of the program (2019-2024), MACRA allows for up to $500 million each year in additional positive adjustments for exceptional performance. In total, MACRA provides for up to $3 billion in additional positive adjustments to successful clinicians over six years.

Under the combination of the previous programs, you would have faced a negative payment adjustment as high as 9% total in 2019, but the MACRA ended those programs, reduced the potential negative payment adjustments in the early years, and streamlined the overall requirements. While these three programs will end in 2018, if you have participated in these programs in the past, then you will have an advantage in MIPS because many of the requirements should be familiar.

Unfortunately, the first half of 2017 is behind us, and June 30th marked an important day for any group’s 2017 MIPS performance year reporting. Was your group planning on submitting data via the Centers for Medicare & Medicaid Services (CMS) Web Interface? Was your group planning on participating in the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey to measure patient experience and contribute to the overall MIPS score? If your group submitted 2016 PQRS data via the Group Practice Reporting Option (GPRO) Web Interface and you wanted to do the same for MIPS this year, no action was required to register and everything is okay.

If you planned on using the CMS Web Interface for the first time in 2017, you needed to register by the June 30th deadline, so there is a possible problem. In general, if you participate in MIPS, you have a total of six options for reporting Quality Performance Category data to the CMS, but you must decide by October 2nd 2017.

What’s the difference between them? Well, the CMS Web Interface is for physician groups of 25 or more, while CAHPS is for groups of two or more. The other four choices, which have the October 2nd deadline, are via claims (for individuals only), qualified registry, qualified clinical data registry (QCDR), and electronic health record (EHR). If your group used the old Physician Quality Reporting System, then you do not need to register with CMS if they plan to report Quality Payment Program data via a qualified registry, QCDR, or EHR.

You are eligible to participate in the MIPS track of the Quality Payment Program if you bill more than $30,000 to Medicare, and provide care to more than 100 Medicare patients per year, and you are a:
Physician, Physician Assistant, Nurse Practitioner, Clinical Nurse Specialist, Certified Registered Nurse Anesthetist.

If you haven’t already started, you must start between now and October 2, 2017. Whenever you choose to start, you’ll need to send in your performance data by March 31, 2018. The first payment adjustments based on performance go into effect on January 1, 2019.

Depending on the track of the Quality Payment Program you choose and the data you submit by March 31, 2018, your 2019 Medicare payments will be adjusted up, down, or not at all. CMS will provide additional information on payment adjustments for 2020 and beyond beginning next year.

Carefully choose your pace in MIPS: With the MIPS track of the Quality Payment Program, you have four options.

Not participating in the Quality Payment Program:

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If you don’t send in any 2017 data, then you receive a negative 4% payment adjustment.

Test: If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity), you can avoid a downward payment adjustment.

Partial: If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.

Full: If you submit a full year of 2017 data to Medicare, you may earn a moderate positive payment adjustment.

Quality Replaces the Physician Quality Reporting System (PQRS) and accounts for 60% in 2017. Most participants need to report 6 quality measures, including an outcome measure, for a minimum of 90 days to receive full credit.

Improvement Activities is a new category and accounts for 15% in 2017. Most participants need to attest completion of up to 4 improvement activities for a minimum of 90 days to receive full credit.
Advancing Care Information replaces the Medicare EHR Incentive Program also known as Meaningful Use and accounts for 25% in 2017. By fulfilling the required measures for a minimum of 90 days, which include: Security Risk Analysis, e-Prescribing, Providing Patient Access, Sending Summary of Care, and Request/Accept Summary of Care. In addition, choose to submit up to 9 measures for a minimum of 90 days for additional credit in 2017.

The next and final deadline will be October 2, 2017, so don’t delay or you will be penalized in 2019.

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