MACRA-MIPS FAQ

Answers to Your Most Common MIPS Questions

General Questions

Yes!

Amazing Charts is currently 2014 Certified Technology and can be used for MIPS reporting in 2017.

However, we strongly recommend you update to Version 9.3, especially if you plan to report on the Advancing Care Information measures. There have been a number of bug fixes and upgrades in this release that will be beneficial to your practices and for MIPS reporting.

For 2018, the following clinicians are eligible for MIPS and therefore would be affected by payment adjustments for their participation or non-participation in MIPS:

  • Physicians
  • PAs
  • NPs
  • Clinical Nurse Specialists 
  • Certified Registered Nurse Anesthetists

The following clinicians are exempt from participating in MIPS

  • People in their first year of Medicare Part B participation
  • People below the low patient volume threshold: those $30,000 or less in Medicare billing charges or provide care for 100 or fewer Medicare patients in a year. (The low-volume threshold is determined at the individual level for individual reporting and at the group level for group reporting. A clinician’s eligibility can change based individual/group reporting method.) CMS looks at Low Volume Threshold Assessment Period from September 1st, 2015 through August 31st, 2016. If a provider falls below either $30,000 billed to Medicare in allowable charges OR below 100 individual Medicare Part B patients seen during that assessment period, they will be notifying providers via letter by the end of March 2017 that the provider is exempt for 2017 reporting.
  • Certain participants in Advanced Alternative Payment Models. (Physicians who provide care to Medicare patients through a recognized Advanced APM will be eligible for a 5% bonus payment. Learn more about Advanced APMs at https://qpp.cms.gov/learn/apms.)

(MIPS does not apply to hospitals or facilities. If a hospital or facility is doing Part A billing (generally for inpatient services), they are exempt – If they bill Part B, they are included.)

Clinicians who aren’t eligible for MIPS can still voluntarily report on measures and activities, but won’t get a payment adjustment under MIPS, negative or positive. 

For 2017, no. For further flexibility and ease of reporting the 90-day period can differ across performance categories. For example, a MIPS eligible clinician may utilize a 90-day period that spans from June 1, 2017 – August 30, 2017 for the Improvement Activities performance category and could use a different 90-day period for the quality performance category, such as August 15, 2017 – November 13, 2017.

Unfortunately, this is hard to do. The following explains why.

 

What we know, based on the information published in the final rule, is that you can get between a 4% decrease in your Medicare payments, or a 4% increase, depending on the MIPS score you get for the data you submit in 2017.

 

You can earn up to 100 total points. 60 of those points can come from the Quality Measure category. 25 of those points can come from the Advancing Care Information category. The final 15 points can come from the Improvement Activities.

  • Less the 3 points: If you earn less than 3 points (AKA you don’t participate in MIPS), you’ll have a 4% decrease on your Medicare payments in 2019.
  • Exactly 3 points: If you earn exactly 3 points, you’ll be able to avoid the negative payment adjustment. You won’t get any positive adjustment.
  • Exactly 100 points: If you earn 100 points, you’ll get the highest possible adjustment, which would include both the 4% positive adjustment on your 2019 payments, plus an additional “exceptional performance” adjustment.
  • Between 4 and 99 points: This is where it gets a little complicated. If you earn between 4 and 99 points, you’ll be eligible for between a 0% and 4% payment adjustment increase. There is no table that maps the number of points you get to the adjustment you earn. This is because the MIPS/MACRA is a budget-neutral program – the positive adjustments must equal the negative ones so until all scores are in, you won’t be able to definitively know what adjustment you can earn. And because the threshold for avoid a negative adjustment is so low in 2017 (3 points), there will likely be fewer people who get a negative adjustment (and therefore a smaller amount of money to pass out across those who earn more than 3 points). This much we do know: the more points you get, the better your chance at a higher payment adjustment.

It’s up to you. If you report as a group, you have to report all categories as a group. The same goes if you report as an individual.

 

  • Individual: If you send MIPS data in as an individual, your payment adjustment will be based on your performance. An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number. You’ll send your individual data for each of the MIPS categories through an electronic health record, qualified registry, or a qualified clinical data registry. You may also send in quality data through your routine Medicare Part B claims process.
  • Group: If you send your MIPS data with a group, the group will get one payment adjustment based on the group’s performance. A group is defined as a set of clinicians (identified by their NPIs) sharing a common Tax Identification Number, no matter the specialty or practice site. Your group will send in group-level data for each of the MIPS categories through the CMS web interface or an electronic health record, qualified registry, or a qualified clinical data registry. (To submit data through the CMS web interface, you must register as a group by June 30, 2017.)

You will be submitting your data alongside a TIN (Tax Identification Number). If you report as an individual under an individual TIN, the adjustments will follow that TIN. If you report as a group under a group TIN, the adjustment will follow that group of people.

 

Your payments in 2019 will be decreased or increased by the percentage you earn based on the 2017 data you submit.

In 2017, if you’re eligible for MIPS, you will participate in that. MIPS has taken the place of MU for Medicare Part B providers. Please note that if you still qualify for the Medicaid Meaningful Use program (or the hospital-based Medicare Meaningful Use program), you will still need to report for that program in 2017. 

In addition to checking back here for more information, there is an informative and easy to navigate new website from CMS that has a lot of the information you need: https://qpp.cms.gov/learn/qpp

Advancing Care Information

Test Path: Under the “Test” path you can choose to report on one of the three scored categories in 2017. If you choose the Advancing Care Information category, you’re required to report on the following:

  • Security Risk Analysis: You must complete this analysis and attest “yes” (If you need help completing the Security Risk Analysis, our partner, Emerald Cybersecurity Solutions, can help.)
  • e-Prescribing: The numerator must be at least one  
  • Provide Patient Access: The numerator must be at least one 
  • Health Information Exchange: The numerator must be at least one 

Yes! Even better, there are no longer thresholds you have to meet in order to “pass” the program, so all you need to do is run the report and review your numbers. The new advancing care information measures aren’t numbered like Meaningful Use measures, but you can find them by using both the Test or Partial/Full documents

Yes. Though the Meaningful Use Wizard does not calculate group data, MIPS allows you to aggregate data adding together the numerators and denominators calculated for each MIPS-eligible clinician in Amazing Charts (even though know that this may cause “unique patients” to be counted more than once in the denominator and numerator).

 

Note that if an individual MIPS eligible clinician in that group meets the criteria to exclude a measure, their data can be excluded from the calculation of that particular measure only.

Quality Measures

What you have to do depends on which path you take:

  • Test – Under the “test” option, you can report on 1 Quality Measure over any time period in 2017. (Though, you can also skip this category and choose to report on the four base measures or one improvement activity instead.) 
  • Partial – Under the “partial” option, you can report on 2 or more Quality Measures over a 90 day to full year period. (Though, you can also choose to skip this category if you don’t want the 60 possible points).
  • Full – Under the “full” option, you must report on 6 quality measures (or a measure set) over a 90 day to full year period. (The Quality Payment Program support desk tells us it will be hard on some measures to earn the full 10 points if you only report on 90 days, so they recommend if you’re interested in going for all 10 points that you report for a full year.)

For 2017, what you do depends on which path you want to take.

 

For the 2017 reporting year, if you want to complete the “Test” path, or earn 3 points (see the scoring question if you haven’t reviewed that information yet), we recommend you continue working like you normally do, and update to Version 10 when it is released in Q4 2017.  In Version 10, you will be able to run reports on quality measures. A full list of what we will offer in Version 10 will be available at a later date. You can also submit Medicare Part B claims to submit quality measure data and avoid a 2019 negative adjustment. (See the Test Path document and the Using Claims to Submit Quality Measures document for more information.) 

MIPS quality measure scoring works differently from the PQRS quality measure scoring. PQRS was a pay-for-reporting program. MIPS is a pay-for-performance program. That means that you earn points on measures for how well you do on them.

 

You can earn a maximum of 10 points per measure.

 

In 2017, they have decided to give a number of points per measure just for reporting it: for each measure you submit, you get an automatic 3 points.

 

The other 7 points can be earned only if the measure has a benchmark to measure your performance against and if the following is satisfied:

  • Data Completeness Required: If you’re reporting on quality measures via a QCDR, a qualified registry, or EHR, you need to report on at least 50 percent of the MIPS eligible clinician or group’s patients that meet the measure’s denominator criteria, regardless of their payer (both Medicare and non-Medicare patients). If you’re reporting via claims, you need to report on at least 50% of the Medicare Part B patient seen during the performance period. In 2017, if you don’t follow this requirement for a measure, you’ll receive the minimum score of 3 points for that measure.
  • Case Minimums Required: To qualify for more than 3 points per measures, you are required to have a minimum of 20 cases per measure.

Once you meet those requirements, you will be scored based on a decile system.

 

Note: If you have 0 in the denominator for a measure in 2017, report them anyway. You’ll receive the minimum of 3 points.

CMS published the benchmarks for Quality measures at the end of December. You can find the packet of information here.

In the packet, you’ll find a spreadsheet with all of the quality measures that have a benchmark. You’ll be able to see in this spreadsheets that the benchmark (and the points you achieve for the percentage you report) varies by your submission method. Benchmarks do not vary by location or geography.

Let’s take Diabetes: Hemoglobin A1c Poor Control (Measure ID 1) as our first example. Let’s suppose you’re reporting on this quality measure via a Registry/QCDR (instead of via claims or an EHR, which have separate benchmarks).

Below, we’ve repeated the deciles from the spreadsheet. We’ve added the points associated with each decile. Note that Decile 1 and Decile 2 are not included because CMS is allowing any measures scoring in those percentages to receive 3 points for 2017.

Decile 3:   35.00 – 25.72%  —  Earn 3 to 3.9 points
Decile 4:   25.71 – 20.32%  —  Earn 4 to 4.9 points
Decile 5:   20.31 – 16.23%  —  Earn 5 to 5.9 points
Decile 6:   16.22 – 13.05%  —  Earn 6 to 6.9 points
Decile 7:   13.04 – 10.01%  —  Earn 7 to 7.9 points
Decile 8:   10.00  –  7.42%  —  Earn 8 to 8.9 points
Decile 9:    7.41   –  4.01%  —  Earn 9 to 9.9 points
Decile 10:             <4.00%  —  Earn 10 points

(Also note that this example uses a reversed quality measure — the lower the percentage, the better you did on the measure and the more points you’ll earn)

Many registries and QCDRs plan to display these benchmarks within their portals so you can easily see how you are faring.

Benchmarks are based on different data depending on the method of submission you use. You’ll notice that there are some measures in the spreadsheet that are marked as not having a benchmark. For those measures, if more than 20 clinicians submit the measure in 2017 (and each of those clinicians meet the data completeness and case minimums for that measure), then your percentage will be judged against the benchmark that the 20 or more clinicians create. If fewer than 20 clinicians meeting those requirements report on the measure in 2017, you’ll still be able to receive the 3 points just for submitting the measure (though this will likely change in 2018).

On the Quality Payment Program website, there is a list of all the possible quality measures you can report on in 2018. You can filter by specialty. See the list here.

 

Make sure to remember that you’re required to report on at least one outcome measures (or if no outcome measures apply to you, a high priority measure) if you do the Partial/Full path. 

If the measure set has more than 6 measures, you can choose 6 to report on. If the measures set has less than 6 measures, you must report on all the measures in the set (but you do not need to pick additional measures to reach six).

The codes included in you claim will mark a patient as part of the denominator and/or numerator. Once you choose the measures you want, find them in the list of specifications and determine the codes you need to add to your claims. If you’re doing the “Test” path, you only need to submit one claim in which the patient is in the numerator–this allows you to avoid the 2019 penalty. If you’re doing the “Full” or “Partial” paths, you’d earn 3 points per measure you include codes for, and more than 3 points if you meet the data completeness requirements and the measure has a benchmark.

For Medicare Part B claims, data must be submitted on claims with dates of service during the performance period that must be processed no later than 60 days following the close of the performance period.

CAHPS is reportable for groups in the MIPS program. For the 12-month performance period, a group that wishes to participate in the CAHPS for MIPS survey measures must use a survey vendor that is approved by CMS for a particular performance period to transmit survey measures data to CMS. The CAHPS for MIPS survey counts for one measure towards the MIPS Quality performance category and, as a patient experience measure, also fulfills the requirement to report at least one high priority measure in the absence of an applicable outcome measure. Groups that elect this data submission mechanism must select an additional group data submission mechanism in order to meet the data submission criteria for the MIPS quality performance category.

CMS defines a Qualified Registry as “an entity that collects clinical data from an EP or PQRS group practice and submits it to CMS on behalf of the participants.” It defines a Qualified Clinical Data Registry (QCDR) as a “CMS-approved entity that collect medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care provided to patients.” Basically, QCDRs are the registries of the future, and often include additional quality measures created in conjunction with specialty organizations; these measures can also be reported for the MIPS program. CMS recommends using a QCDR.

Improvement Activities

If you are a small practice (1-15 clinicians), a non-patient facing MIPS eligible clinician/group, or a practices located in rural areas and geographic HPSAs, you only have to complete 20 points worth of activities (1 high activity or 2 medium activities). Other clinicians that do not fall in those categories have to complete 40 points worth of activities (2 high activities, 4 medium activities, or 1 high and 2 medium activities).

Improvement Activities are worth either 10 points, for medium activities, or 20 points, for high activities.

You will receive full credit for the improvement activities performance category without having to complete any activities in 2017 if:

  • You are a MIPS eligible clinician or group that has received certification or accreditation as a patient-centered medical home or comparable specialty practice from a national program or from a regional or state program, private payer or other body that administers patient-centered medical home accreditation and certifies 500 or more practices for patient-centered medical home accreditation or comparable specialty practice certification.
  • If you are an Advance APM Medical Home Model (As of November 1, 2016, the only “Medical Home Model” identified by CMS that meets the qualifications below is the Comprehensive Primary Care Plus (CPC+): Has a primary care focus, offers primary care services with patients empaneled to a primary clinician, and meets other necessary requirements.)

Quality Measure Update (10/19/2017)

If you were planning on reporting on Quality measures for the Partial and/or Full paths, you would have needed to register with FIGmd’s ELIXIR by October 3. 

If you failed to do so then you have the following options for Quality Measure reporting:

  • Manual entry: You can enroll in Polaris for manual data entry even if you missed the ELIXIR registration deadline. You can start the registration process at Click Here by clicking Register and entering your information. 
  • Claims: If you are submitting your quality measures via claims for the Partial or Full paths, and you started prior to October 1, you do not need to use a registry to report quality measures. See the Using Claims to Submit Quality Measures document for more information.

Additionally, if you were late in trying to register, you can skip the Quality category of MIPS for 2017, and instead focus on the Advancing Care Information and Improvement Activities categories. 

We apologize that our earlier communications were misleading or unclear in regards to signing up with the registry for Quality reporting. On our website, webinars, we stressed that signing up for electronic reporting via ELIXIR may take several weeks and to take action sooner than later. However we failed to note that there was a registration deadline of October 3rd.Many practices who decided on Full or Partial path participation were in contact with us earlier in the year and enrolled before the deadline. We did not anticipate that some practices would wait until later in the year to decide which path they wanted to take and subsequently missed the registration period.   – because of that, we failed to emphasize the need to register before registration closed.

As we move forward, we will improve on our communication about registration deadlines like this.