MIPS

The Merit-based Incentive Payment System (MIPS) adjusts reimbursement based on reporting and performance.  

Exemptions:  

  1. Ob-gyns or their practices that submit $30,000 or less in Medicare Part B charges or see 100 or fewer Medicare patients annually are exempt from MIPS under the low-volume threshold. For example, if a practice sees 90 Medicare patients and submits $50,000 in Medicare Part B charges, it would be exempt.  Another example of the low-volume threshold exemption is if a practice sees 120 Medicare patients and submits $28,000 in Medicare part charges.  CMS will calculate this threshold and will notify providers between by the end of May 2017 whether or not they must participate in MIPS in 2017 as an individual.  To see if you are exempt, visit CMS's webpage on provider eligibility.

  2. Ob-gyns who are new to Medicare and do not have a full year of claims history are also exempt.  

  3. Physicians who are Qualifying Participants in an Advanced APM are exempt from MIPS.

Less Red Tape

  • MIPS combines three existing Medicare reporting programs - the Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM) program, and the Medicare Electronic Health Record (EHR) Incentive (meaningful use) program - into one single program.

  • MIPS requires reporting on four categories:

    • Quality
    • Cost
    • Advancing Care Information (meaningful use), 
    • Improvement Activities (new category)

  • You will be able to report through claims, qualified registries, Qualified Clinical Data Registries, electronic health record systems, and certified survey vendors.

Payment incentives for higher performing physicians 

  •  The first year of the program will be a transition year.  The performance period starts January 1, 2017 and will affect payment in 2019.
    • Non-exempt ob-gyns and other providers who do not submit data will be subject to a negative penalty of 4 percent.
    • Non-exempt ob-gyns who submit at least one measure in quality, advancing care information, or improvement activities will not be subject to any negative adjustments.
    • Non-exempt providers who submit at least 90 days of data may be eligible for a small positive payment adjustment.  Providers would need to start collecting data by October 2, 2017 in order to be eligible.
    • Non-exempt providers who submit a full year of data on quality, advancing care information, and improvement activities may be eligible for a positive payment adjustment of up to 4 percent.  Exceptional performers may be eligible for even higher payment adjustments.

  • To reward higher performers and incentivize others toward performance improvements, the positive adjustments can be scaled up to 3 times the positive adjustment – 12% – to achieve budget neutrality. 
  • Positive and negative adjustments will increase to +/- 9 percent by 2022, with a potential 27 percent upward adjustment to Part B payments. 
  • There is no scaling factor for negative adjustments, cuts are capped.
  • 2019 – 2024: $500 million in additional performance bonus dollars for exceptional performers, not subject to budget neutrality.
  • Ob-gyns can choose to report as an individual or as a group.  CMS has not established a process yet for practices to identify whether or not they are reporting as groups or individuals.
  • You can also report on care delivered to non-Medicare patients, although the payment adjustments will only apply to your Part B payments.

 

Performance Categories

1. Quality

This category will account for 60 percent of a physician’s MIPS score in the first payment year, 2019 (based on reporting in 2017).

If you opt to report for the full year, you’ll choose at least 6 quality measures that best match your practice.  

You’ll choose one outcomes measure (if available) or another high-priority quality measure. High-priority quality measures relate to patient outcomes, appropriate use, patient safety, efficiency, patient experience, or care coordination.  For groups with 16 clinicians or more, CMS calculates one population measure on all-cause hospital readmission.  

Visit CMS’ website to view the list of available quality measures and filter by specialty to see a list of appropriate measures for ob-gyns.  You must use the same submission mechanism for all of your quality measures.

2. Advancing Care Information

This category will account for 25 percent of your MIPS score in the first year.

Using a certified electronic health record technology (CEHRT), you’ll report a set of measures that reflects how you use EHR in your practice, with an emphasis on interoperability, information exchange, and patient privacy. Your overall Advancing Care Information score will be made up of a base score and a performance score for a maximum score of 100 points. 

If you are using the 2015 standard of CEHRT, you will report on the following measures.

Base Score

The base score accounts for 50 points of the total Advancing Care Information category score. To receive the base score, you’ll provide the numerator/denominator or yes/no for each objective and measure. 

  • Security Risk Analysis 
  • Electronic Prescribing
  • Provide Patient Access
  • Send a Summary of Care Record
  • Request/Accept a Summary of Care

Performance Score

The performance score accounts for up to 90 points towards the total Advancing Care Information category score. You’ll be asked to select the measures that best fit your practice from the following:

  • Provide Patient Access
  • Patient-specific Education
  • View, Download, and Transmit (VDT)
  • Secure Messaging
  • Patient-generated Health Data
  • Send a Summary of Care
  • Request/Accept a Summary of Care
  • Clinical Information Reconciliation
  • Immunization Registry Reporting     

Bonus points are also available for reporting to additional public health and clinical data registries beyond the Immunization Registry Reporting measure as well as for reporting improvement activities via CEHRT.

Visit CMS’ website to view more details on the measures that you will be scored on.

Your base score, performance score, and bonus points (if applicable) are added together for a total of up to 155 points. Ob-gyns earning 100 points or more will receive the full 25 points in the Advancing Care Information category. If you earn fewer than 100 points, your overall performance category score declines proportionately.

You will also have to attest that you are not engaging in activities that block the exchange of data.  You will also have to acknowledge the requirement to cooperate in good faith with the Office of the National Coordinator of Health IT (ONC) direct review of CEHRT. 

 

3. Improvement Activities

The improvement activities category accounts for 15 percent of the MIPS score in the first year.

Physicians will be rewarded for implementing improvement activities that focus on care coordination, beneficiary engagement, and patient safety.  You’ll have more than 90 options from which to choose under the following categories:

  • Expanded practice access
  • Beneficiary engagement
  • Achieving health equity
  • Population management
  • Patient safety and practice assessment
  • Emergency preparedness and response
  • Care coordination
  • Participation in an APM, including a medical home model
  • Integrated behavioral and mental health

Visit CMS’ website for the full list of improvement activities that CMS has proposed.

The maximum total points in this category will be 40 points. CMS proposes weighting the activities in this category.  High-weighted activities – those that support the patient-centered medical home, as well as activities that support the transformation of clinical practice or a public health priority – are worth 20 points.  Medium-weighted activities are worth 10 points.  You will need to report doing 2 high-weighted activities, 4 medium-weighted activities, or some combination of activities that totals at least 40 in order to achieve the highest possible score. 

Small practices with 15 or fewer clinicians and practices located in rural and geographic health provider shortage areas (HPSAs) can report one high-weighted or two medium-weighted activities to achieve a full score in this category.

You can also receive credit in this category for participating in alternative payment models (APMs) and Patient-Centered Medical Homes (PCMH).  Physicians participating in an accredited PCMH will get full credit under this category and do not have to report on any other activities.

4.Cost

This category will not be a part of your MIPS score in the first year. 

In future years, your score will be automatically calculated based on your Medicare claims; you will not have any reporting or other requirements to receive your score.  

CMS will calculate scores for total per capita cost, Medicare spending per beneficiary, and 10 episode group measures and provide feedback to ob-gyns and other providers.  However, these scores will not affect the overall performance score for the first year.  

Email your questions about the MACRA Quality Payment Program to practicemanagement
@acog.org

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