Doctor for Doctors
MIPS Reporting Countdown:
Act Now to Avoid Penalties
By Nargiza Nurlybaeva, WCH Billing Group Supervisor
It's been six months since the MIPS (Merit Based Incentive Pay System) program began. Do you know what you need to do to comply in 2017? Or if you even need to start reporting quality and improvement measures yet?
WCH can help you understand MIPS, what it means for your practice, how to choose which measures to report, what method to use and your timeline for avoiding penalties.
Who Needs to Report Now
First, you need to verify whether or not you need to start reporting MIPS information.
As reported in the July issue of Medical Economics (“Looking ahead at MACRA/MIPS reporting for physicians”, Kevin N. Fine, MHA), “More than 800,000 physician practices got a temporary pass on MACRA (Medicare Access and CHIP Reauthorization Act) compliance from the Centers for Medicare & Medicaid Services (CMS) in May. But practitioners shouldn’t breathe easy just yet.
“The break is only for certain providers and it only applies for 2017, which was slated to be a transition year anyway. Physicians who want to avoid future penalties should start preparing now to comply with MACRA and MIPS reporting requirements in 2018 and beyond.”
Providers exempt from reporting 2017 information include:
- Clinicians in their first year of Medicare Part B participation
- Clinicians billing $30,000 or less in Medicare charges with 100 or fewer Medicare Part B patients per year
- Clinicians in entities that are participating in an advanced Alternative Payment Model (APM)
If you haven’t received a letter from Centers for Medicare and Medicaid Services (CMS) notifying you of your practice’s reporting status, you can check MIPS eligibility by entering your individual National Provider Number (NPI) into CMS’s online verification tool.
Still, close to 419,000 clinicians who don’t qualify for the exemptions must submit MIPS data for 2017. They include:
- Physicians (MDs, DOs, DPMs and chiropractors)
- Physician’s assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Any clinical group that includes one of these professionals
MACRA was designed to streamline value-based programs, including Meaningful Use (MU) of electronic health record (EHR) technology, the Physician Quality Reporting System (PQRS) and the Value Based Payment Modifier (VBM).
There are two different tracks for participating in this Quality Payment Program:
- Advanced Alternative Payment Model (APM)—Models qualifying as APMs in 2017 include Comprehensive ESRD Care (CEC) – Two-Sided Risk, Comprehensive Primary Care Plus (CPC+), Next Generation ACO Model, Shared Savings Program – Track 2, Shared Savings Program – Track 3, Oncology Care Model (OCM) – Two-Sided Risk, Comprehensive Care for Joint Replacement (CJR) Payment Model (Track 1- CEHRT), and Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model).
- MIPS – There are several ways to report, and three initial levels of participation. The deadline for reporting practice data collected in 2017 is March 31, 2018, or providers face stiff penalties.
Providers who choose the MIPS path must first pick their level of participation. Then they can decide which quality measures to report and the best methods for reporting them.
There is a full-year model and a partial-year reporting option which mandates consistently recording required measures for a continuous 90-day period. This means you have two months to get started, if you haven’t already. The 90-day reporting period must begin by October 2, 2017.
A minimum “test” level of participation requires submitting at least one measure for one patient, one improvement activity, or four or five core advancing care information measures to avoid a negative four percent payment adjustment in 2019.
Choosing What to Report
Providers have several reporting options. WCH can help narrow down the best choices for your practice.
MIPS reporting components include:
- Quality (formerly PQRS)
- Improvement activities (new category)
- Advancing care information (formerly MU)
- Cost (formerly VBM)
Providers may report information in several ways:
- Qualified Clinical Data Registry (QCDR)
- Qualified registry
- Attestation web portal
Picking Your Pace
CMS established three options to help providers, participating as either a group or individual provider, start transitioning to MIPS reporting in 2017:
Full-year reporting: If you report all of the required measures for all eligible patients for 12 months, you may be eligible for a positive payment adjustment, depending on performance results.
Partial-year reporting: If you submit performance data on one quality measure, more than one improvement activity or more than the required measures in the advancing care information category for a minimum of a continuous 90-day period, you may earn a neutral or positive payment adjustment—depending on your results.
Minimum “test” reporting: If you report a minimum amount of 2017 data (even one quality measure for one patient, one activity in the improvement activities category, or four or five of the core advancing care information measures), you can avoid a negative payment adjustment, but you will not be eligible for a performance bonus.
For more information, visit the Quality Payment Program website.
How WCH Can Help
Sorting through MACRA and MIPS letters, emails, articles and websites can be overwhelming. WCH can help guide providers through the process of choosing quality measures to report, and provide information and resources for establishing a documentation process that meets MIPS guidelines. The most important thing is to get started!
The minimum test reporting guidelines call for reporting one performance measure or improvement activity for one patient. This can be as simple as selecting a code to track a quality measure on a patient’s claims. This is a good option for providers who aren’t familiar with reporting quality measures. Once you’re in the system, CMS will start tracking your quality efforts from now on.
Providers who are submitting data gathered over 90 continuous days should be documenting six quality measures for each eligible patient visit—in their charts and on their superbills—and submitting them through their claims. They may also report them through an approved registry or EHR.
Improvement activities may be reported through an approved registry, EHR or attestation. Advancing care information (formerly MU) may be reported by attestation, QCDR, a qualified registry or EHR vendor. Don’t wait until the last minute to pull everything together. Make sure to document everything right away, include all pertinent details, and submit regularly.
WCH account representatives will continue to share information with clients regularly, research options and guide providers to helpful resources. We understand how easy it is to get lost in information overload. Experienced billers can help figure out what to report and how. For example, last year WCH researched 50 registries for submitting data and narrowed it down to the three best suited for our clients.
WCH will do everything we can to make the MIPS transition easier. Watch for updates and emails. Talk to your account representative. We’re here to help!