MIPS Reporting

Overview, Measures and Scoring

The Merit-based Incentive Payment System (MIPS) is one of the two tracks under the CMS Quality Payment Program (QPP). MIPS reporting is already in effect for the performance year 2017. MIPS eligible clinicians who take no action will get progressively more payment reductions from 2019 onwards. The participants, on the other hand, will get a score to determine their corresponding payment adjustments, ranging from zero to some positive amount (up to +4% in 2019) and possibly some sharing of a bonus (from a $500M fund).

MIPS reporting means that you have to submit performance data to CMS based on your patient and practice records. There are 4 categories of reporting as shown in the diagram above. Each category has its own reporting requirements. For example, the Quality category has over 270 quality measures defined, and you have to choose a set of measures to do the reporting. Some quality measures are specialty specific and some are general. Each category reporting will be given a score and then weighed by the percentage indicated in the diagram for the performance year 2017. Your total score will be the weighed sum of the individual category scores. The total score will then determine your payment adjustment.

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Timeline

Transition and Rollout

2017 is called the transition year as it is the first performance year defined under MIPS. Although data in the entire calendar year are acceptable for submission, CMS provides a flexibility for you to participate in the so-called Pick Your Pace, meaning that you can submit very minimal amount of data per your choice, or a full set per the guideline. In any event, March 31, 2018 is the deadline for the 2017 data submission. CMS will provide feedback to your submission, and the payment adjustment will take effect in 2019.

Those who don’t participate will see negative payment adjustments in each year, or -4% in 2019, -5% in 2020, -7% in 2021 and -9% in 2022. The participants, on the other hand, will receive zero to positive adjustments in each year – up to +4% in 2019, up to +5% in 2020, up to +7% in 2021 and up to +9% in 2022.

You can learn about the latest MIPS news and announcements here.

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Impact

Financial Implications

We highlight the financial implications in your practice based on your MIPS score. The diagram shows the possible cumulative gain or loss in dollar amounts in the 4-year cycle based on a yearly Medicare Part B revenue of $100,000. If your annual revenue were $1M, then these numbers would be scaled up by 10 times. The financial impact is quite serious whether you are an individual or a group of providers.

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Deadlines

Actions and Considerations

The most important deadline is that the 2017 data need to be submitted by March 31, 2018. CMS will start accepting submission in January 2018, and everyone is advised to make their submission well before the deadline.

Clearly much work has to be done prior to the submission. You need to decide quickly what your MIPS goals are and how to achieve them. Taking no action will surely land your practice into serious penalties as described previously. The 2017 transition year is “gifted” with Pick Your Pace and other incentives. We can help you to get the most out of the program without minimum time and efforts on your part.

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Dilemma

Efforts vs. Return

Understanding MIPS reporting and doing it properly to achieve your goals will involve time and efforts. The reporting details and actions are non-trivial as summarized in the diagram. The time burden on each clinician is clearly not insignificant.

The bottom line question to many clinicians is if the time and efforts are worthwhile in business terms. The answer lies in each individual situation, at least for the transition year. This is precisely the reason that we offer a no-risk assessment to help you decide easily and quickly. We provide a quick review of that in the next section.

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Practice-specific Solution

Free Assessment for a Best-Matched Solution

Each practice may have its own combination of business process, financials and goals. Our services are designed to give you a solution best matched to your existing situation because of the impending deadline and the continuing evolution of QPP. Our first priority is to provide an option that involves minimum efforts and almost zero disruption to your practice. In doing so, we are also cognizant of your need to have a positive return to your use of our services. We believe that once you start using our services to solve your immediate problem, you will find the same value of our advice and services to make your practice future proof in evolving towards total IT integration. Our help is only a message away.

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