Go Big or Go Home? Taking MIPS to The Max
Part three in a three-part series on the MIPS “pick-your-pace” transition.
By now, most dermatologists are aware that the Merit-based Incentive System (MIPS) is here, and that we have choices on how, or even if, we wish to participate. In essence, we can dip our feet in to test the waters and avoid penalty or dive right in headfirst and earn the maximum bonus in 2019.
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: MIPS or Advanced Alternative Payment Models (APM). Most dermatologists will not participate in the APM pathway; MIPS is the way forward.
There are three approaches to MIPS reporting. This final article in a three-part series, focuses on option No. 3. Here’s the deal in a nutshell: If you submit 90 days worth of 2017 data to Medicare across a series of measures, you may earn a “moderate” bonus in 2019. This bonus may be as much as four percent in 2019 (with a chance for even more). The last day to start this process would be October 2, 2017. Since 2017 is a transition year, going all in requires at least 90 days worth of data.
This may sound onerous but it is significantly less so than the original MIPS proposed rule, which called for a full year’s worth of data. Going forward, a practice will have to submit a full year’s worth of data across four categories to qualify for the maximum incentive.
As stated in our March and April 2017 issues (online at PracticalDermatology.com), there are essentially four categories in which you can submit data and avoid penalty and/or earn a bonus.
QUALITY (WHICH REPLACES PQRS)
To earn a bonus, a practice must report six quality measures for at least 90 days. The American Academy of Dermatology DataDerm registry allows dermatologists to choose from dermatology-specific or dermatology-applicable measures that satisfy this requirement: http://bit.ly/2pmAha1
In this all-new category, a practice must report one to four improvement activities (based on activity and practice location and size) to earn a bonus. Examples may include achieving health equity, behavioral and mental health, beneficiary engagement, care coordination, and/or emergency response and preparedness.
ADVANCING CARE INFORMATION (REPLACES MEDICARE EHR INCENTIVE PROGRAM, AKA, MEANINGFUL USE)
This category focuses on the secure exchange of health data, use of a certified EHR, and quality improvement. You must report on five required measures (security risk analysis, e-prescribing, patient access, send a summary of care record, and request/accept a summary of care record) for at least 90 days.
COST (REPLACES THE VBM)
No data submission required. This is calculated from adjudicated claims, but does not count in 2017.
The Bottom Line
It’s go big or go home with MIPS option No.3. This pace gives a practice the most measures to choose from and will best prepare it for what’s to come. It represents the way to get the max out of MIPS. In fact, you may be eligible for additional positive payment adjustment on top of the four percent. Remember that the only physicians who will experience negative payment adjustments (-4 percent) in 2019 are those who report no data in 2017. For more information, visit 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. Digital Practice, runs in every issue of Practical Dermatology® magazine.