Ease On Down The Road: Getting Started with MIPS
Part one of a three-part series on the MIPS “pick-your-pace” transition.
No one can blame dermatologists for feeling fatigued at the mere mention of the Medicare Access and CHIP Reauthorization Act (MACRA) and the Merit-based Incentive Payment System (MIPS).
The details and rhetoric associated with these programs can be dizzying, but don’t let this noise stop you from protecting your practice from penalties. It’s relatively simple to avoid penalties and test the waters in 2017.
By way of background, MACRA shifts physician payment so that it rewards value and quality over volume via the creation of the Quality Payment Program (QPP). The QPP offers two pathways for reimbursement: The Merit-based Incentive System (MIPS) and Advanced Alternative Payment Models (APM). (MIPS comprises the Physician-Value Based Payment Modifier [VBM], Physician Quality Reporting System [PQRS], and the Medicare EHR Incentive Program). Most dermatologists will NOT participate in the APM pathway, so MIPS represents the way forward for our specialty.
There are three approaches to MIPS reporting. No. 1 is all about avoiding a penalty, No. 2 allows a practice to avoid any penalty and potentially earn a small bonus, and option No. 3 allows a practice to avoid the penalty and potentially earn the full bonus.
Path of Least Resistance
For the purposes of this article, we are focusing on option No. 1. If you submit one—just one—quality measure in 2017, you will avoid the four percent penalty in 2019. Put another way: Failure to correctly report one measure or activity in 2017 will result in a four percent penalty applied in 2019.
And now for the how.
There are essentially four buckets or categories in which you can submit data and avoid penalty.
Quality (which replaces PQRS)
To avoid penalties, a practice must report one quality measure in one patient for one time in 2017. This may include a number of dermatology relevant measures (see box).
I strongly recommend that practices report more than one measure as an insurance policy in case there is an issue with your one and only.
This is an all-new category. To avoid penalties, a practice must report one improvement activity for any point in 2017. Examples include achieving health equity, behavioral and mental health, beneficiary engagement, care coordination, and/or emergency response and preparedness.
Advancing Care Information (which replaces the Medicare EHR Incentive Program also known as Meaningful Use)
The five required Advancing Care Information measures in 2017 are:
- Security Risk Analysis
- Provide Patient Access
- Send a Summary of Care Record
- Request/Accept a Summary of Care Record
We would need to fulfill these five measures for a minimum of 90 days during the 2017 reporting year to avoid a penalty.
Cost (replaces the VBM)
No data submission required. Calculated from adjudicated claims. Even better news for some dermatologists is that you can test the system without investing in an electronic health record or registry. Visit https://qpp.cms.gov/measures/quality and filter measures by “data submission method” and choose claims.
It Only Takes One
To sum it all up, I quote the source, the US Centers for Medicare & Medicaid Services: “Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment,” they write. “Alternatively, if MIPS eligible clinicians choose to not report even one measure or activity, they will receive the full negative four percent adjustment.”
It’s relatively simple to avoid getting penalized this year. Take my advice and test the waters before it is too late. You’ll thank me, I promise. The upcoming articles in this series will guide dermatology practices through MIPS options two and three.
Mark D. Kaufmann, MD is an associate Clinical Professor of Dermatology, Dept. of Dermatology at the Icahn School of Medicine at Mount Sinai in New York City. His column, Digital Practice, runs in every issue of Practical Dermatology® magazine.