By Polly Friend, RN, Senior Director of Clinical Strategy, CareCloud
On November 2nd, the Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) final rule outlining how physicians will be held accountable under year 2 of the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) law. While many practices decided to hold off implementing Year 1 of the Merit-based Incentive Payment System (MIPS) track given uncertainties about the program’s future, they now find themselves in a crunch to plan for both the 2017 and 2018 programs.
Here are answers to the most pressing questions facing practices when it comes to determining – and meeting – near term MIPS compliance requirements.
Is it too late to participate in Year 1 of MIPS?
If you aren’t 100 percent sure you even need to participate in MIPS, simply enter your 10 digit National Provider Identification number here to determine your eligibility. Your 2017 composite score will determine whether your 2019 Medicare fee schedule will include an incentive payment or a fee reduction. If you haven’t started tracking your measures yet, your best option to avoid penalty is to work toward the minimal requirements of 1 patient, 1 measure.
For the 2018 year, the minimal requirements are more stringent, requiring a full 90 days of data.
Can I still aim for an incentive in 2019?
To get an incentive in 2019, you must submit 90 days of data in 2017. Unfortunately, we have passed the cutoff for that final 90-day window, so it is no longer possible to aim for a 2019 incentive if you have not begun. The best you can aim for with your 2019 Medicare fee schedule is to avoid penalties by working toward the minimal requirement of 1 patient, 1 measure.
How do I aim for an incentive under MIPS?
Although the deadline has passed to aim for an incentive in 2019 as part of Year 1 of the program, you can begin now to aim for an incentive in 2020 as part of Year 2. To aim for an incentive, you will need to capture 90 days of data. In order to submit the best 90 day window of data, we recommend that you track the full calendar year, beginning on January 1, 2018.
Starting on January 1, 2018, you can begin tracking the measures you would like to work toward. If you haven’t decided what measures to work toward, that is the first step. Then using your EHR, you need to determine the documentation that is needed to support those measures. Luckily with CareCloud, we work with you to get that process underway.
In order to maximize your potential for an incentive, track more measures than you need. For example, if you track ten measures, you can then choose the six measures that demonstrate the best performance.
Which 90 days of data do I submit?
The 90 days for submission is any consecutive 90 days, not necessarily a calendar quarter. This applies to both Year 1 and Year 2 of the program, although submitting 90 days of data is only a requirement for Year 2 of the program.
You must use the same reporting period for all measures you are reporting within each category (Quality, Advancing Care and Improvement Activities), but you can submit a different reporting period for each category. In other words, if I am pursuing the partial pace of 90 days, I can report from Jan 2017 to March 2017 for Quality measures, then I can report Oct 2017 to December 2017 for Advancing Care Information measures and I can report April 2017 to June 2017 for the Improvement Activities. This flexibility of reporting period can help practices aim for incentives with the best span 90 day span of data for each category.
If I am exempted from MIPS in 2018, do I still need to submit in 2017?
One of the changes CMS has made for 2018 includes a “significant hardship” exception to opt out of the MIPS Advancing Care Information (ACI) performance category starting in 2018. Under new authority granted by last December’s 21st Century Cures Act, CMS could offer practices with 15 or fewer clinicians a new category of hardship exception to reweight the ACI performance category to zero and shift the ACI scoring weight of 25% to the quality category.
This hardship exemption is not retroactive. There may be some clinicians exempt from MIPS in 2018 who will face a 2019 Medicare fee reduction if they fail to submit the minimum requirements for Year 1 of MIPS for the 2017 calendar year, which is one measure, one patient.
In Year 2 of MIPS for 2018, the Final Rule supports decreasing the number of doctors and clinicians required to participate in MIPS by excluding individual MIPS-eligible clinicians and groups with less than $90,000 in Part B allowed charges or fewer than 200 Medicare Part B beneficiaries.
For more about the differences between 2017 and 2018 MIPS requirements, stay tuned for our upcoming post, MIPS 2017 vs. 2018: A Comparison. Also, be sure to bookmark the Quality Payment Program resource library, a current and easy-to-search set of all MIPS and MACRA information from CMS.
