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 Proposes 2020 MIPS Policies

On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) released a proposed Medicare annual payment rule for calendar year (CY) 2020 that impacts payments for physicians and other health care practitioners. In this rule, CMS proposes numerous changes and updates to MIPS, including laying out a new MIPS Values Pathway (MVP) framework, that, once implemented, will hopefully provide a more cohesive and meaningful participation experience for clinicians. Further, CMS proposes modifications to the four performance categories and their associated weights, 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 rule, please click here.

For a CMS fact sheet highlighting proposed 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%) of eligible clinicians participated in MIPS.  93% earned a positive adjustment. 
• 99,076 were qualifying participants (QPs) in an Advanced APM.
• 54% of clinicians reported for MIPS as a group; 34% reported through a MIPS APM; and 12% reported as individuals
• 31.6% 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% did so through an MSSP track one ACO
• Overall, nearly 75% 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 2019 will impact Medicare payments in 2021).

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 2019 is found below. Also found below is a summary of the final policies CMS has adopted for 2019.

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.

What’s new in 2019?

One new scoring option available to emergency physicians starting in 2019 is called the facility-based scoring option for the Quality and Cost categories of MIPS.

With this new scoring option, clinicians who deliver 75 percent or more of their Medicare Part B services in an inpatient hospital, on-campus outpatient hospital, or emergency room setting will automatically receive the quality and cost performance score for their hospital through the Hospital Value-based Purchasing (HVBP) Program starting in 2019. CMS estimates that most emergency physicians would qualify for this option. Clinicians who qualify for the option can still report quality measures through another submission mechanism (such as a QCDR) and receive a “traditional” MIPS score for quality. If they do so, CMS will automatically take the highest of the HVBP score and the traditional MIPS score.

CMS plans to make information about the facility-based scoring option available to clinicians during the first quarter of 2019. At that time, you will be able to find out whether or not you are eligible for this option and what your possible HVPB score will be. That way, you can make an informed decision about how to participate in MIPS.

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.