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).
Most emergency physicians are exempt from this category (formally the “Meaningful Use” program) because they are “hospital-based” and use their hospital’s EHR. However, if you report as part of a group, you might not be exempt.
ACEP has created an action alert to help you understand your options if you are not classified as “hospital-based.” Please review these documents immediately, as there is a deadline of December 31, 2018 to apply for a category exemption.
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.
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.
The MIPS 2018 data submission period is now open.
There are important dates to consider for the program:
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.
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.