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Many of you are all too familiar with the Merit-based Incentive Payment System (MIPS), the major quality reporting program for physicians under Medicare. MIPS measures performance in four categories —Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use)—which roll up into a composite score that translates to a payment adjustment (i.e., a bonus, penalty, or no change) that you receive two years after the performance period. The payment adjustments under MIPS could have a significant impact on your revenue. Failing to report in 2019 would lead to a 9 percent reduction to your Medicare payments in 2021.
Each year the Centers for Medicare & Medicaid Services (CMS) revises requirements for MIPS, and, as I described in a previous blog, CMS recently finalized requirements for calendar year 2020—which is just around the corner.
CMS is raising the bar, making it more difficult over time to receive a bonus and avoid a penalty. In the 2020 reg:
In addition to making the MIPS requirements more challenging overall, CMS also finalized a policy ACEP supports that would ensure that most of you don’t have to focus your attention on the Promoting Interoperability category. Currently, clinicians who are considered “hospital-based” as individuals are exempt from this category. However, if individual clinicians decide to report as a group, they lose the exemption status if a single group member does not meet the definition of “hospital-based.” ACEP has repeatedly argued this unfair policy penalizes hospital-based clinicians who work in multi-specialty groups. In a victory for ACEP and our members, CMS altered this policy starting in 2020 by exempting groups from the Promoting Interoperability category as long as 75 percent of individuals in the group meet the definition of hospital-based.
With the Promoting Interoperability category out of the way, you can focus on meeting the Quality and Improvement Activities requirements so that you can exceed the new performance threshold of 45 points (note: there are no reporting requirements for the Cost category—CMS determines your score based on a set of claims-based cost measures).
Now that you know about the major changes, I also leave you with a few tips to help you be prepared going forward:
This program is complicated, and it’s a priority for ACEP to help you succeed and maximize your MIPS score. In addition to working with CMS to simplify the requirements, ACEP provides our members with resources to ease the reporting process. Thousands of emergency physicians are now using ACEP’s Clinical Emergency Data Registry (CEDR) to meet the Quality Reporting requirements and participating in the Emergency Quality Network (E-QUAL) to meet the Improvement Activities requirements. You can also visit CMS Quality Payment Program Help and Support page, which includes additional MIPS resources and contact information for CMS’ help desk.
Finally, you can always reach out to me directly if you have questions.
Until next week, this is Jeffrey saying, enjoy reading regs with your eggs!
If you have any questions or want to weigh in on other regulatory items, feel free to email me: email@example.com.
Jeffrey Davis is the Director of Regulatory Affairs at the American College of Emergency Physicians (ACEP). He manages ACEP’s formal response to federal policies and works with federal agencies and other stakeholders to help advance ACEP’s federal affairs agenda. Prior to that, Jeffrey worked in the Budget Office at the U.S. Department of Health and Human Services for nearly eight years. Jeffrey came to the Government as a Presidential Management Fellow, and in his position in the Budget Office, he advised top level officials on major budgetary and policy considerations within Medicare and prepared detailed analyses of Medicare regulations and legislation. Jeffrey has a Masters of Science in Health Policy and Management from the Harvard T.H. Chan School of Public Health and a Bachelors of Arts degree from Duke University.