MIPS (Merit-Based Incentive Payment System)
The MIPS is a new program that combines parts of the Physician Quality Reporting System (PQRS), the Value Modifier (VM or Value-based Payment Modifier), and the Medicare Electronic Health Record (EHR) incentive program into one single program in which eligible professionals (EPs) will be measured on:
- Resource use
- Clinical practice improvement
- Advancing Care Information
MIPS consolidates current Medicare quality programs (Physician Quality Reporting System, EHR Meaningful Use, and Value-Based Payment Modifier) and adds a new category for “clinical practice improvement.” MIPS also offers the first substantial rewards for achieving high-quality care. Each “eligible clinician” or group will receive a “composite performance score” for performance in four categories—quality, resource use, use of certified electronic health records under “Advancing Care Information,” and clinical practice improvement activities—compared against the average of all MIPS clinicians. Those scoring above average receive a bonus, while those scoring below average receive a penalty. Scoring is somewhat flexible, but here are some general guidelines:
|Advancing Care Information||25%||25%||25%|
Performance in each category is weighted and used to calculate a final score from 0-100.
Payment adjustments, based on the final score, are budget neutral and based on performance from two year prior (e.g., performance in 2017 determines payment adjusments in 2019). Adjustments are made on the following sliding scale:
|PERFORMANCE YEAR||PAYMENT YEAR||POSITIVE/NEGATIVE PAYMENT ADJUSTMENT|
Additional positive adjustments are possible due to budget neutrality.
Practitioners are exempt from MIPS reporting and payment adjustments for a particular year if (1) this is their first year of Medicare enrollment; (2) they meet the “low volume threshold” of no more than $10,000 in Medicare billings and 100 Medicare patients; (3) they qualify for the MACRA bonus for “advanced” alternative payment models (APMs); or (4) they meet the definition of a partial qualifying APM participant and choose not to report under MIPS.
Practitioners will no longer be required to report nine quality measures across three National Quality Strategy “domains.” They will have to report only six quality measures, including one cross-cutting measure and one outcome measure. If no outcome measure is available, they must report one measure related to appropriate use, patient safety, efficiency, patient experience, or care coordination.
The Society will post a list of MIPS quality measures relevant to PA/LTC after the final rule is issued.
CPIA options include “Integrated Behavioral and Mental Health” activities such as providing integrated care consistent with the collaborative care model.
MACRA includes $100 million for technical assistance to small and rural practices, plus those in health professional shortage areas, for MIPS reporting and transitioning to new models of care.
MIPS does not apply to Medicare Advantage payments or programs.
MACRA preserves current reporting methods but also encourages reporting via qualified clinical data registries (QCDRs) by individuals and group practices. In addition to being less burdensome, registry reporting counts toward the ACI and CPIA categories, potentially leading to higher MIPS scores and bonuses. QCDR measures can also be directly approved by CMS, avoiding longer review by the National Quality Forum—the only organization designated by Congress to endorse quality measures.
MIPS will continue most valid PQRS quality measures and add measures used by private payers and for different settings. MACRA includes $75 million in development funding of new measures. CMS has issued a final Quality Measure Development Plan to address measure gaps. The Society submitted comments on the draft plan in February. Click here for the CMS Plan.