Easing Further Down The Road: Getting Comfortable with MIPS
Part two of a three-part series on the MIPS “pick-your-pace” transition.
Love it or hate it, the Merit-based Incentive System (MIPS) is here, and dermatologists need to at least test the waters to avoid getting penalized in 2019.
By way of background, the Medicare Access and CHIP Reauthorization Act (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 is the way forward.
There are three approaches to MIPS reporting. Number 1 is all about avoiding a penalty. Number 2 allows a practice to avoid any penalty and potentially earn a small bonus. And option Number 3 allows a practice to avoid the penalty and potentially earn the full bonus.
In this article, we will focus on option Number 2. If you submit 90 days of 2017 data to Medicare, you will do more than avoid a penalty in 2019, you may even earn a bonus (possibly a big one). You can start your reporting anytime between January 1 and October 2, 2017.
But exactly what does this entail, and do you have the bandwidth?
As stated in our March 2017 issue, there are essentially four buckets or categories in which you can submit data and avoid penalty and/or earn a bonus.
Quality (Which replaces PQRS)
To avoid penalties and possibly earn a bonus, a practice must report more than one quality measure for 90 days in 2017. The more data, the greater the chance of a bonus—especially in this category.
In this all-new category, a practice must report more than one improvement activity for 90 days to avoid penalty and earn a bonus. Examples include achieving health equity, behavioral and mental health, beneficiary engagement, care coordination, and/or emergency response and preparedness.
Advancing Care Information
This 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 more than these five measures for a minimum of 90 days during the 2017 reporting year to avoid a penalty and earn a bonus.
Cost (Replaces the VBM)
No data submission required. Calculated from adjudicated claims, but does not count in 2017.
Watch Dr. Kaufmann discuss MIPS as part of DermTube.com’s coverage of Maui Derm for Dermatologists 2017.
A Relatively Easy Option
It is relatively simple to take advantage of MIPS option 2. Report more than one quality measure; or more than one improvement activity; or more than the required measures in the advancing care information performance category for 90 days to avoid penalties and earn a bonus. Such successful “partial participation” provides a small payment increase on all Medicare Part B claims in 2019, but exactly how much is still unknown.
Remember, the only physicians who will experience negative payment adjustments (-4 percent) in 2019 are those who report no data in 2017. To learn how to avoid the penalty, see last month’s article. The final article in this series will guide dermatology practices through MIPS option Number 3.
For more information on all of these measures and how to report data, visit https://qpp.cms.gov/
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.