Merit-based Incentive Payment System (MIPS)

The Medicare Physician Fee Schedule (PFS) regulation makes updates to the Quality Payment Program (QPP), the major quality reporting program for physicians under Medicare. Failure to successfully participate in the Merit-based Incentive Program (MIPS)—the main track within the QPP—could eventually result in a 9 percent reduction to your Medicare payments. We are doing all that we can to simplify the requirements and make it easier to avoid a penalty and even be eligible for a bonus.

Read below about MIPS and what ACEP is doing to help emergency physician successfully participate.

Latest MIPS Updates

CMS Announces Proposed 2021 MIPS policies

On August 3, 2020, the Centers for Medicare & Medicaid Services  (CMS) issued the proposed Medicare annual payment rule for calendar year (CY) 2021 that impacts payments for physicians and other health care practitioners. In this rule, CMS proposes numerous changes and updates to MIPS, including delaying the transition to MIPS Values Pathways (MVPs). The rule also proposes modifications to the four performance categories, the overall performance threshold, and to reporting requirements for qualified clinical data registries (QCDRs)—which directly affect ACEP’s QCDR the Clinical Emergency Data Registry (CEDR).

• For ACEP’s high-level summary of the proposed rule, please click here.
• For a CMS fact sheet highlighting proposed MIPS policies, please click here. 

Your 2019 MIPS Results are Available

CMS has released 2019 Merit-based Incentive Payment System (MIPS) performance feedback and final scores. If you submitted data for the 2019 performance period, you can view your MIPS performance feedback and final score on the Quality Payment Program website. 

You can access your 2019 MIPS performance feedback and final score by:

• Going to cms.gov/login
• Logging in using your HCQIS Access Roles and Profile (HARP) system credentials; these are the same credentials that allowed you to submit your 2019 MIPS data

The final scores you receive in 2019 affect your Medicare payments in 2021.  Since MIPS adjustments are made in a budget neutral way, and many clinicians were held harmless from negative adjustments in 2019 due to the COVID-19 pandemic, the amount available for bonuses is very small.  If you achieved a perfect score of 100 percent in 2019, you will only receive a 1.78 percent positive adjustment to your Medicare claims in 2021.

To learn more about performance feedback, review the 2019 MIPS Performance Feedback Resources.

A fact sheet explaining the MIPS adjustments can be found here.

 COVID-19 Flexibilities

CMS has announced some needed relief to MIPS reporting requirements due to COVID-19. 

CMS announced changes to the 2019 performance period in March but refined its policies for the 2020 performance period in June. 

 2019 Performance Period
You were originally required to submit your 2019 performance data by March 31, 2020. CMS extended the deadline for reporting to April 30, 2020. If you did not submit MIPS data by April 30, 2020, you will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year (i.e. if you didn't report, you will be held harmless.) For more details on your reporting options, please see CMS' fact sheet.

2020 Performance Period
CMS announced on June 24 that you can submit an application to have your MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0% due to COVID-19. 

Specifically, if the COVID-19 pandemic prevents you or your group from collecting 2020 MIPS performance period data for an extended period of time, or could impact your performance on cost measures, you can submit an extreme and uncontrollable circumstances application through December 31, 2020.

On July 13, ACEP had a call with CMS to find out more about the hardship exemption application process.

• CMS stated on the call that the agency is being extremely flexible of granting hardship exemptions due to COVID-19. In the application, there is an open text box that allows you or your group to explain why you are requesting a hardship exemption. CMS told ACEP that as long as you include as part of your rationale that you are claiming the hardship exemption because of your inability to report due to “COVID-19” or the “coronavirus,” CMS will most likely grant your exemption request. CMS did note that the operative words to use in your application are “COVID-19” and “coronavirus.” CMS will not be requiring you to submit documentation and is trying to make the application process as easy as possible.
• CMS stated that it will likely approve individual hardship exemptions within 24 to 48 hours after the request is submitted. As stated above, you can apply for the hardship exemption now until the end of the calendar year.
• CMS did say that if you claim a hardship exemption and then still submit data, it will score the data submitted and override the hardship exemption. For example, if you submit a hardship exemption for all four MIPS performance categories (and it is approved), but then decide to submit data on two performance categories later on, CMS will use the data submitted to determine a MIPS performance score.

For more information on submitting a hardship exemption for the 2020 performance period, and to apply, please go to CMS’ website here.  

This MIPS relief was one of the major requests that ACEP included in our letter to the Secretary of the Department of Health and Human Services (HHS) on March 13th.

The MIPS 2019 Data Submission Period is Now Open

CMS is now allowing clinicians to submit MIPS data from the 2019 performance period. Data can be submitted and updated from 10:00 a.m. EST on January 2, 2020 until 8:00 p.m. EDT on March 31, 2020.

How to Submit Your 2019 MIPS Data

Clinicians will follow the steps to submit their data:

1. Go to the Quality Payment Program (QPP) website
2. Sign in using your QPP access credentials (you must have a username and password)
3. Submit your MIPS data or review the data reported on your behalf by a third party (such as ACEP’s qualified clinical data registry, the Clinical Emergency Data Registry or CEDR)

If you have questions about reporting, please contact the Quality Payment Program at 1-866-288-8292 or QPP@cms.hhs.gov.

Check Your Initial 2020 MIPS Eligibility

You can now use the updated CMS Quality Payment Program Participation Status Lookup Tool to check on your initial 2020 eligibility for MIPS. Just enter your National Provider Identifier, or NPI, to find out whether you need to participate in MIPS during the 2020 performance period.

You can find more about general MIPS eligibility rules here.

CMS Announces Final 2020 MIPS policies

On November 1, 2019, CMS issued the final Medicare annual payment rule for calendar year (CY) 2020 that impacts payments for physicians and other health care practitioners. In this rule, CMS finalizes numerous changes and updates to MIPS, including a new MIPS Values Pathway (MVP) framework, that, once implemented, will hopefully provide a more cohesive and meaningful participation experience for clinicians. Further, CMS makes modifications to the four performance categories, the overall performance threshold, and to reporting requirements for qualified clinical data registries (QCDRs)—which directly affect ACEP’s QCDR the Clinical Emergency Data Registry (CEDR).

• For ACEP’s summary of the final rule, please click here.
• For a CMS fact sheet highlighting final MIPS policies, please click here. 
• For a CMS FAQ of the final MIPS policies, please click here.

Now Available: 2018 MIPS Performance Feedback and Final Score

If you participated in MIPS in 2018, you can now view your results. 

2018 MIPS Results Details

2017 Experience Report Released

In March 2019, CMS released the results from the first year (2017) of the Quality Payment Program (QPP).  There is also an accompanying appendix that provides more details. Highlights from the report are found below. 

2017 Experience Report Statistics

• As a reminder, the QPP includes two tracks: the Merit-based Incentive Payment System (MIPS) and Advanced alternative payment models (APMs)
• 1,006,319 (95 percent) of eligible clinicians participated in MIPS.  93 percent earned a positive adjustment. 
• 99,076 were qualifying participants (QPs) in an Advanced APM.
• 54 percent of clinicians reported for MIPS as a group; 34 percent reported through a MIPS APM; and 12 percent reported as individuals
• 31.6 percent of MIPS eligible participants reported using a registry or QCDR.
• MIPS APM participants received the highest scores (achieving a mean or average score of 87 out of 100), followed by those that reported through a group practice (76 average), and then individuals (55 average)
• Of those that participated through a MIPS APM, over 90 percent did so through an MSSP track one ACO
• Overall, nearly 75 percent of clinicians submitted quality category data for a full-year, even though only a 90 day period was required.

CMS Seeks Comment on Potential MIPS Measure for Acute Admission for Patients with Multiple Chronic Conditions

CMS is gathering comments on a potential measure that impacts emergency physicians.  Interested in learning more and providing feedback to ACEP?  Please contact Jeffrey Davis at jdavis@acep.org.

Background

In 2015, Congress enacted the Medicare Access and CHIP Reauthorization Act (MACRA), which created a new physician performance program in Medicare called the Quality Payment Program (QPP). The QPP includes two tracks: The Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). The Centers for Medicare & Medicaid Services (CMS) within the U.S. Department of Health and Human Services is responsible for operating the program.

Most emergency physicians participate in the first track of the QPP: MIPS. MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2020 will impact Medicare payments in 2022).

MIPS Impact on Emergency Physicians

Most emergency physicians will need to participate in MIPS to avoid a penalty and perhaps get a bonus. You can report as an individual or as part of a group. For the 2018 performance year, the potential payment adjustments range between -5 and +5 percent. Potential bonuses and/or penalties grow over time, so they can have a major impact on your revenue.

Find Out Whether You’re Eligible

If you see a minimum number of Medicare patients, have a small amount of Medicare charges, or provide a small number of services to Medicare beneficiaries, you may be excluded. You'll need your National Provider Identifier (NPI) number to determine your eligibility.

Find out whether you must report in MIPS

What is ACEP doing?

ACEP continually advocates on behalf of emergency physicians to reduce provider burden and help our members succeed in the program. Every year, CMS updates program requirements through federal regulatory rulemaking and ACEP actively comments on these regulations. A summary of our comments on the last rule that sets policies for 2020 is found below. Also found below is a summary of the final policies CMS has adopted for 2020.

ACEP also provides our members with helpful tools to report in MIPS. Thousands of emergency physicians are now using CEDR to meet the Quality Reporting requirements and participating in E-QUAL to meet the Improvement Activities requirements.

MIPS Facility-based Scoring Option Preview

CMS is now providing a facility-based scoring preview that allows you to see what your Quality and Cost performance category scores could look like for the 2019 MIPS performance period if you're identified as facility-based. 

Find out if you're eligible for the facility-based scoring option.

How to Access the Facility Based Preview

1. Sign into the QPP website.
2. On the QPP homepage, click Preview Facility Score (or click Facility Based Preview in the left-hand navigation).

Please note that these are not your 2019 MIPS performance period Quality and Cost performance category scores under the facility-based scoring option. This preview is based on earlier data from the HVBP and should give you an idea of what your facility-based scores for these performance categories may resemble.

For More Information

To learn more about facility-based measurement for MIPS in 2019, view the 2019 Facility-based Measurement Fact Sheet and the Facility-based Preview FAQs.