Call Sales: (866) 382-5932, option 2
— Peter Sundwall Jr., MD, Family Medicine
Answers to Your Most Common MIPS Questions
Amazing Charts is currently 2014 Certified Technology and can be used for MIPS reporting in 2017.
However, if you are on a version below Version 9.0 of Amazing Charts, we strongly recommend you update to Version 9.3, which includes a number of bug fixes that will be beneficial to your practices and for MIPS reporting. If you are on a version of Amazing Charts below Version 9.0, and you contact Amazing Charts Customer Support with questions regarding MIPS, they will suggest you to update to Version 9.3; please update now so you are prepared for 2017 reporting.
Please see our Release Notes about these versions to review all the new features and bug fixes that have been introduced. Make an appointment to upgrade or ask questions by emailing firstname.lastname@example.org.
Yes. You are required to be on a specific certified technology in 2018. We will be planning for this certified technology, Version 10, to be available in late 2017.
For 2017 and 2018, the following clinicians are eligible for MIPS and therefore would be affected by payment adjustments for their participation or non-participation in MIPS:
The following clinicians are exempt from participating in MIPS
(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.)
Your 2019 Medicare payments adjustment will be based on what you report on in 2017.
For 2017, you can avoid any negative adjustment by reporting under the “Test” option. You can earn a positive adjustment on your 2019 by participating in the “Partial” or “Full” option for MIPS.
Test: Under the test option, you would have to do the following:
Want to avoid the 2019 penalty and nothing more? Follow the MIPS Test Path in 2017.
Partial: Under the partial option, you can earn a small positive adjustment (depending on the number of overall points you earn) by doing the following over a 90 day to full year period:
Full: Under the full option, you can earn a larger positive adjustment (depending on the number of overall points you earn) by doing the following over a 90 day to full year period:
Note: The cost category will be calculated in 2017, but will not be used to determine your payment adjustment.
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 data you submit and your performance in 2017.
You can earn up to 100 total points for your MIPS score. 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.
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.
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.
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.
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
Also, you can always visit this page of the overview page (http://amazingcharts.com/support/macra-mips) for up-to-date checklists and 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:
Follow the MIPS Test Path in 2017.
Partial/Full Path: Under the Partial/Full paths, you can earn up to 100 points. You can earn 50 of those points by reporting for at least 90 days on the following:
You can earn up to 50 more points by reporting on the following
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 in the Wizard by looking for the correct measure/objective name.
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.
What you have to do depends on which path you take:
Yes, in Version 10. Version 10 of Amazing Charts, which will be certified for use in the 2018 MIPS program, will include more (and more relevant) measures than currently offered in Amazing Charts. Version 10 will be out in late 2017.
What should I do for 2017 for the Quality Measures category if you aren’t updating the quality measures in Amazing Charts yet?
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” or “Partial” path, or earn 3 points per measure (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.
If you want to go for the “Full” path or try to earn the full 10 points for quality measures you submit, we suggest pairing with a qualified registry or QCDR, or do Medicare Part B claims-based reporting, to track and report quality measures. Learn more about how claims-based reporting worked for PQRS; it will be similar for MIPS.
Note that some registries and QCDRs are automatic and some are manual. For manual entry, like with PQRSwizard that was used for PQRS, you may have to keep track of patients by hand, and fill out forms about those patients, then enter that data into the QCDR/registry system. Automatic entry generally means the QCDR pulls data from your database automatically instead of you having to enter it. You can ask your registry/QCDR what kind of system they have, and review the Quality Category webinar for more detailed information.
PRIME (and the rest of the FIGmd registries), PQRSwizard and MDinteractive have all been used by Amazing Charts users for other quality measures programs. The ABFM suggests using the PRIME registry, which extracts data automatically directly from the Amazing Charts database. The AAFP suggests using the PQRSwizard registry, which requires manual entry of data, and which the organization reports will be ready for MIPS. Providers should research the options, talk to their professional organizations, and choose what works for them. You can find a full list of the 2016 qualified registries here. You can connect with these registries to determine if they are reporting for MIPS. When we have an updated list on registries and QCDRs for 2017, we will update this link.
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:
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
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 and 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).
Yes. On the Quality Payment Program website, there is a list of all the possible quality measures you can report on in 2017. You can filter by specialty. See the list here.
Note that just because the measure is on the list doesn’t mean a registry will include that in their offering. If you are a specialist and you’re looking to go the “full” reporting route and seek the full 10 points per measure, speak to your professional organization about the registry you should use.
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). To maximize your point-earning capability, review the question below about earning points.
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.
How quickly must Medicare Part B claims be submitted if I’m using them to turn in data for Quality Measures?
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.
CAPHS 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 registry 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.
What you have to do depends on which path you take:
If you are a small practice (1-15 practitioners), 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. Other clinicians that do not fall in those categories have to complete 40 points worth of 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 in 2017 if:
Was your question not answered here? Send an email to Amazing Charts Client Services with your question at email@example.com.