Payment & Delivery Models

How to avoid a payment penalty in 2018 MIPS

Physicians have several options for fulfilling the minimum reporting requirements Medicare Quality Payment Program’s Merit-based Incentive Payment System (MIPS) to avoid a penalty that would lower their Medicare payment in 2020. The AMA offers resources to help you learn how to avoid a MIPS penalty.

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The requirements have been raised since last year when physicians only had to report one measure on one patient one time. For 2018, physicians must earn a minimum of 15 points in MIPS scoring. It helps that practices with 15 or fewer clinicians are eligible to begin their scoring with a five-point small-practice bonus.

The AMA has developed a resource, “How to Avoid a Penalty in 2018 MIPS Program,” that outlines different ways that physicians in both small and large practices can meet that 15-point threshold.

The resource is formatted as a score sheet that maps out the quickest routes to 15 MIPS points. These include either loading up in one of three performance categories—Quality, Improvement Activities (IAs), and Promoting Interoperability (PI, formerly “Advancing Care Information”)—or splitting the number between two of them.

Physicians who do not report or score lower than 15 points face a Medicare pay cut of up to 5 percent in 2020.

“The bar isn’t real high to avoid a penalty,” AMA Immediate Past President David O. Barbe, MD, MHA, said in a ReachMD podcast earlier this year. “If physicians report on one IA and one Quality measure, they should be able to hit 15 points, particularly if you’re a small practice because you’ve got five bonus points coming in.”

Quality measures require 365 days of data, while the IA and PI categories require 90 consecutive days of data. The current deadline to submit data is March 31, 2019. The Centers for Medicare & Medicaid Services (CMS) automatically collects data for a fourth category—Cost— using claims physicians submitted for payment.

The first step in the process is for physicians to check whether they are exempt from MIPS reporting by entering their National Provider Identifier number into the CMS Quality Payment Program Participation Status lookup tool and then proceed from there depending on exemption status.

113 Improvement Activities to choose from

To achieve a possible 100-point MIPS score, practices can earn 50 points from Quality measures, 25 points from PI, 15 from IAs, and 10 from Cost measures.

CMS has a library (ZIP file) of 113 IAs to choose from. They are weighted either “high” or “medium.” They are divided into categories such as expanded practice access, population management, care coordination, and beneficiary engagement. Practices operating as a certified patient-centered medical home earn full credit in the IA category.

For both small and large practices, engaging in a high-weight IA will earn the 15 minimum points needed to avoid a penalty.

Practices can report IA data via attestation, a Qualified Clinical Data Registry, their electronic health record, or—for groups or virtual groups of 25 or more—the CMS Web Interface.

Follow paths to be penalty-free

The other roads on the AMA map to 15 points for small practices are:

  • Report one medium-weight IA (7.5 points), one Quality measure 2.5 points, plus the 5-point small-practice bonus.
  • Report six Quality measures (15 points) plus the 5-point small practice bonus.
  • Report information on topics such as prevention of information blocking or security-risk analysis to get the PI base score (12.5 points), report on one quality measure (2.5 points), plus the 5-point small practice bonus.

There are two other options for large practices:

  • Report four Quality measures (8.5 points) and two medium-weight IAs (7.5 points).
  • Report information for the PI base score (12.5 points) and two Quality measures (4.2 points).

Another AMA resource, the “2018 MIPS Strategic Scoring Guide,” offers more tips on successfully navigating the new Medicare payment system, now in its second year.