CMS is now reviewing claims and will be notifying practices which clinicians will need to take part in the Merit-based Incentive Payment System (MIPS), under the new Quality Payment Program (QPP).
In late April through May, you will get a letter from your Medicare Administrative Contractor (MAC) providing the participation status for each MIPS clinician associated with your Taxpayer Identification Number (TIN). Clinicians are included in MIPS if they bill Medicare Part B more than $30,000 a year in allowable charges and provide care for more than 100 Medicare patients a year, and you are a:
Clinical nurse specialist
Certified registered nurse anesthetist
For those of you with multiple TINs or with clinicians who practice under multiple TINs, eligibility notifications will be at the TIN level of their eligibility and therefore may have different eligibilities for each of the TIN/practice combinations.
Also note that if your group chooses to report as a group, MIPS assessment will be based on all individuals in the group including those clinicians who do not exceed the low-volume threshold as individuals.
The Quality Payment Program (QPP) is designed to shift reimbursement from the volume of services provided towards payment that rewards clinicians for their overall work in delivering the best care for patients. QPP replaces the Sustainable Growth Rate (SGR) formula and streamlines the “Legacy Programs” – Physician Quality Reporting System,(PQRS) the Value- based Payment Modifier, and the Medicare Electronic Health Records Incentive Program, also known as “meaningful use”.
During the first performance period that began January 1, 2017, CMS will allow you to pick your pace of participation. If you are participating in MIPS you will have three flexible options to submit data to MIPS and a fourth option to join an Advanced APM in order to potentially become a Qualifying APM Participant.
The first performance period of MIPS is 2017, and the first payment year is 2019. This means that your submitted data in calendar year 2017 will be used to determine your MIPS adjustment to Part B payments for items and services provided in 2019.
We recommend you participate, if for no other reason than to avoid the 4% payment reduction that will be assessed in 2019 if you don’t send in any 2017 data. You can avoid the downward payment adjustment by just submitting a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point in 2017)
This will ensure that you do not receive a negative payment adjustment in 2019.
If you submit 90 days of 2017 data to Medicare, you may earn a neutral or positive payment adjustment and if you submit a full year of 2017 data to Medicare, you could earn a positive payment adjustment for 2019. To potentially earn a positive payment adjustment in 2019, you should send in your data to Medicare no later than March 31, 2018.
There are several ways to report;
Report as an individual.
If you report as an individual, your payment adjustment will be based on your performance.
An individual is defined as a single clinician, identified by a single National Provider Identifier (NPI) number tied to a single Tax Identification Number (TIN).
You will need to send your individual data for each of the MIPS categories through an electronic health record or a registry or include quality data through your routine Medicare claims process.
Report as a group.
Each Clinician participating in MIPS via a group will receive a payment adjustment based on the group’s performance.
Under MIPS, a group is defined as a single Taxpayer Identification Number (TIN) with 2 or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their National Provider Identifiers (NPI), who have reassigned their Medicare billing rights to the TIN.
If your group would like to participate in MIPS via the CMS Web Interface and/or elect to administer the CAHPS for MIPS survey, you should register between April 1 and June 30, 2017.
Only these two options require registration.
If your group registered for the GPRO Web Interface in 2016 to report for The Physician Quality Reporting System (PQRS), CMS automatically registered your group to use the CMS Web Interface in 2017 for MIPS. If you want to report under another method, you need to cancel the GPRO election during the registration period (4/1 to 6/30/2017)
If you registered for the Web Interface in 2016 and wish to continue in 2017, you should review and update your information, between April 1-June 30, 2017, if:
The number of eligible clinicians in your group has changed since 2016
Your group wants to enroll in the Consumer Assessment of Health Providers and Systems (CAHPS) for MIPS survey
What should you do “NOW”.
We strongly suggest you complete the following action items to insure you are ready for MIPS.
Make sure your electronic health record is certified by the Office of the National Coordinator (ONC) for Health Information.
Check if you want to use a qualified clinical data registry or other registry to submit your quality data.
See what MIPS data your practice can choose to send in. Figure out which measures and activities best fit your practice.
Go to: Explore the MIPS Measures
Decide whether you should report as an individual or with a group.
CMS has provided quite a few educational resources to help you. Please visit their site https://qpp.cms.gov/resources/education