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Regs & Eggs - December 12, 2019

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MIPS: Upcoming Changes You Should Know About

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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:

  • CMS increased the performance threshold—which a clinician must exceed to be eligible for a payment bonus—from 30 points in 2019 to 45 points in 2020 and 60 points in 2021.
  • CMS raised the data completeness threshold for the Quality Category of MIPS. So for every quality measure you choose to report on, you must report on 70 percent (rather than 60 percent) of all the patients that fall under that measure.
  • CMS adjusted the Improvement Activities category requirement to only allow groups to attest to an improvement activity if at least 50 percent of clinicians in the group participate in the activity during a continuous 90-day period within the same performance year. Currently, a group can attest to an improvement activity if at least one clinician in the group participates in the activity.

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:

  • You can check whether you are eligible for MIPS and must report by going here. You'll need your National Provider Identifier (NPI) number to determine your eligibility. You may be exempt if you:
    • See a minimum number of Medicare patients;
    • Have a small amount of Medicare charges;
    • Provide a limited number of services to Medicare beneficiaries; or
    • Participate in an Advanced Alternative Payment Model (APM).
  • Most of you are eligible for the facility-based scoring option for the Quality and Cost categories of MIPS. Under this 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. Clinicians who qualify for the option can still report quality measures through another submission mechanism 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.

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!

jeff headshot.PNGIf you have any questions or want to weigh in on other regulatory items, feel free to email me: jdavis@acep.org.

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.

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