MIPS

The Merit-based Incentive Payment System (MIPS) adjusts reimbursement based on reporting and performance. The data submission period for the 2017 MIPS performance year closed on April 3, 2018. Final scores and feedback are now available through the QPP website. Physicians who were not exempt from the MIPS program in 2017 will receive a payment adjustment based on their MIPS score in January 2019. You can now use the updated MIPS Participation Lookup Tool to check on your 2019 eligibility for the Medicare Access and CHIP Reauthorization Act (MACRA) Quality Payment Program (QPP). To check your status, click on the link and enter your National Provider Identifier (NPI).

 Exemptions for 2019:

  1. Ob-gyns or their practices that submit $90,000 or less in Medicare Part B charges for covered professional services, see 200 or fewer Medicare patients annually, or provide 200 or fewer covered professional services under the Medicare Physician Fee Schedule are exempt from MIPS under the 2019 low-volume threshold.

  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 Alternative Payment Model (A-APM) are exempt from MIPS.

  • New in 2019: Ob-gyns or practices that meet or exceed 1-2 of the low volume threshold criteria (listed in the first bullet above) can choose to opt in to MIPS participation. Those who choose to opt in will be treated as MIPS eligible clinicians, meaning their MIPS performance will be scored and they will receive a payment adjustment in 2021. Ob-gyns or practices that fall below all three of the low-volume threshold criteria cannot opt in, and those that meet or exceed all three (and are not new to Medicare or a qualifying participants in an A-APM are required to participate.

Exemptions for 2018:

  1. Ob-gyns or their practices that submit $90,000 or less in Medicare Part B charges or see 200 or fewer Medicare patients annually are exempt from MIPS under the 2018 low-volume threshold.

  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 A-APM are exempt from MIPS.

Payment incentives for higher performing physicians 

  • The 2019 performance period starts January 1, 2019 and will affect payment in 2021.
    • Non-exempt ob-gyns who submit a full year of data on all four performance categories may be eligible for a positive payment adjustment of up to 7%
    •  Non-exempt ob-gyns and other providers who do not submit data will be subject to a negative penalty of 7%.
  • Positive payment adjustments are subject to a scaling factor to achieve budget neutrality. Based on results from the first performance year, positive payment adjustments for the highest performing clinicians are likely to be lower than 7%.
  • The exceptional performance bonus is also subject to a scaling factor, which is not to exceed 1%.
  • There is no scaling factor for negative adjustments, cuts are capped at 7%.
  • 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.  
  • You may also report on care delivered to non-Medicare patients, although the payment adjustments will only apply to your Part B payments.
  • You can also participate in MIPS through a MIPS Alternative Payment Model (APM).

 

Performance Categories

1. Quality

This category will account for 45% of a physician’s MIPS score during the 2019 performance year, down slightly from 50% in 2018.

In performance year 2019, you should report on 6 quality measures for the full year.

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.  Groups with 25 clinicians or more must report on all 15 quality measures.

Visit the QPP website to view the list of available quality measures and filter by specialty to see a list of appropriate measures for ob-gyns.

2. Promoting Interoperability (previously Advancing Care Information)

This category will account for 25% of your total MIPS score in 2019, the same as in 2018.

Beginning in 2019, CMS is implementing a new scoring methodology for the Promoting Interoperability performance category. This new methodology is individual measure-based and the points received for each measure add together to total the score for this category. In 2019, non-exempt clinicians will be required to use 2015 Certified Electronic Health Record Technology (CEHRT) to report to MIPS.

Physicians are also required to complete the Security Risk Analysis measure, which does not have any points assigned to it.

Visit the QPP website  for more information on this new scoring methodology, new measure exclusions, or to see how this category was scored in previous performance years. 

3. Improvement Activities

The improvement activities category accounts for 15% of the MIPS score 2019, the same as in 2018.

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 QPP website for the full list of improvement activities and their associated weights.

To earn full credit in this category, physicians will need to report doing 2 high-weighted activities, 4 medium-weighted activities, or 1 high-weighted activity and 2 medium-weighted activities. 

Individuals or groups who practice in a small practice of 15 or fewer clinicians, rural practices, a health professional shortage area (HPSA), or in a non-patient facing practice will receive double points for all completed improvement activities. 

Beginning in 2019, ob-gyns can receive credit for one medium-weight activity if they complete the Safety Certification in Outpatient Practice Excellence for Women's Health (SCOPE), and receive Maintenance of Certification Part IV credit for completion.

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 count towards 15% of your total MIPS score in 2019, up from 10% in 2018.

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 and Medicare spending per beneficiary, and provide feedback to ob-gyns and other providers based on performance in 2019 and beyond. Visit the QPP website for more information on these cost measures. CMS also adopted several episode based cost measures for the 2019 performance year, but none of them apply to ob-gyns at this point.

 

Facility Based Scoring

Beginning in 2019, facility-based clinicians can apply their Hospital Value Based Purchasing (VBP) program score to their scores for the MIPS cost and quality categories. CMS defines facility-based individual clinicians as those who furnish 75% or more of their covered professional services in inpatient hospital, on-campus outpatient hospital, or emergency room locations. Facility-based groups are those in which at least 75% of the MIPS eligible clinicians billing under the groups Tax Identification Number (TIN) are eligible for facility-based measurement as individuals. CMS will automatically apply the higher score to participants' cost and quality categories, whether it is the VBP score, or data submitted by the participants themselves.

 

MIPS APMs

Ob-gyns and groups that participate in an APM, but are not eligible to be Qualifying Participants in an A-APM, may choose to participate in MIPS through a MIPS APM. Some Medicare APMs do not qualify as A-APMs under the QPP, but do qualify as MIPS APMs. Some physicians and groups participate in APMs that do qualify as A-APMs, but do not meet or exceed the payment and patient thresholds required for participation. For performance year 2019, APM entities must receive at least 50% of their payments through the APM, or see at least 35% of their patients through the APM to qualify as an A-APM. Those who don't meet these thresholds should consider reporting to MIPS as a MIPS APM.

 Participants in MIPS APMs receive special scoring under the APM scoring standard. For the quality performance category, MIPS APMs are only scored on those measures that are required for their specific APM. 

MIPS APMs are subject to the same low-volume threshold criteria, but these criteria are applied at the APM entity level. The performance period for MIPS APMs is also the regular 12-month MIPS performance period. 

MIPS APMs are alternative payment models that meet the following criteria:

  • APM entities that participate in the APM under an agreement with CMS
  • Have one or more MIPS eligible clinician on the Participation List for the APM
  • APM bases payment on quality measures and cost/utilization (either at the APM entity or individual provider level)

The following models are eligible to be MIPS APMs in the 2019 performance year:

  •  Bundled Payments for Care Improvement Advanced Model (BPCI Advanced)
  • Comprehensive ESRD Care - 1-sided and 2-sided risk
  • Comprehensive Primary Care Plus (CPC+) Model
  • Independence at Home Demonstration (IAH)
  • Medicare Shared Savings Program (all tracks)
  • Medicare Accountable Care Organization (ACO) - Track 1+ Model
  • Maryland Total Cost of Care Model
  • Oncology Care Model (all tracks)
  • Vermont All-Payer ACO Model

 

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