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Date: Nov. 7, 2016

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MIPS 101 for 2017

On October 14, 2016 CMS released the final rule for the Quality Payment Program (QPP). The QPP for 2017 includes two payment tracks: Advanced Alternative Payment Models (APM) and Merit Based Incentive Program (MIPS).

Currently, Medicare measures the value and quality of care provided by doctors and other clinicians through a mixture of programs, including the Physician Quality Reporting System (PQRS), the Value Modifier Program, and Meaningful Use. Through the law, Congress streamlined and improved these programs into one new Merit-Based Incentive Payment System (MIPS). CMS projects the majority of participants will be embracing the QPP via MIPS.

MIPS has three categories for 2017:

Clinical Practice Improvement Activities (CPIA) = 15%

  • CMS has reduced the number of activities on which most clinicians must report from six to four.  Groups with 15 or fewer participants and clinicians practicing in rural and health professional shortage areas only will have to report on two activities.

Advancing Care Information (ACI) (formerly Meaningful Use) = 25%

  • Under this component CMS had proposed requiring reporting on 11 measures, but now has reduced that number to 5.

Quality (formerly PQRS/VBM) = 60%

  • CMS had proposed to require clinicians and groups to report on (1) six quality measures, including one cross-cutting measure (except for non-patient-facing clinicians) and one outcome measure (or an additional high-priority measure if no outcome measure is available); or (2) one specialty-specific or subspecialty-specific measure set.

Please keep in mind that every point counts in MIPS. Increase your participation in each category by selecting extra measures and exceeding thresholds. If you are currently meeting the 2016 PQRS and Meaningful Use requirements, continue to do so. MIPS participation in these categories for 2017 are much lower than 2016. You can do it!

If you were familiar with the proposed rule, there was a fourth category called Cost/Resource that was weighted at 10%. The final rule has removed this category for 2017 and increased Quality from 50% to 60%. The cost/resource category will be back in 2018.

Pick Your Pace:

Under the final rule, 2017 will be a transition year for the program. The rule finalizes a period during which clinicians and CMS will build capabilities to report and gain experience with the program. Clinicians can choose their course of participation in 2017 with four options:

1.  Don't report anything

  • -4% penalty, No Bonus Potential

2.  Report one measure in Quality, one measure in CPIA, OR all required measures for ACI

  • No Penalty, No Bonus Potential

3.  90 day reporting on most measures

  • No Penalty, + Bonus Potential

4.  Report 90 days+ on all measures (Aim for full year reporting to get the most bonus potential)

  • +Bonus Potential, Exceptional Performance Bonus Potential up to 10%

Who is Eligible to Participate under MIPS?

YEARS 1 and 2 (2017 & 2018)

  • Physicians – MD/DO, DC/DPM, DMD/DDS
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists

Who is NOT Eligible to Participate under MIPS?

  • First year of Medicare Part B Participation
  • Below low patient volume threshold
    • Medicare billing charges less than or equal to $30,000 OR provides care for 100 or fewer Medicare patients in one year
    • Certain participants in Advanced Alternative Payment Models

CMS also has changed the definition of “hospital-based” clinicians (who are not required to submit data under the ACI component) to include those clinicians who perform at least 75% of covered professional services in a hospital inpatient, on-campus hospital outpatient, or emergency department setting.  CMS will make this determination based on claims for a specified period prior to the performance year.

Additionally, non-physician practitioners – regardless of where they practice – may elect not to submit data under the ACI component, in which case it will be re-weighted as 0%.  CMS has recognized these clinicians may require additional time to meet the requirements of the ACI component, given they were not subject to the Meaningful Use program.

MIPS Scoring and Payments:

Depending on the “Pick Your Pace” option you choose to participate - the Composite Performance Score (CPS) would be used to determine whether a MIPS Eligible Clinician receives:

  • Upward Payment Adjustment
  • No Payment Adjustment
  • Downward Payment Adjustment as appropriate
  • Payment adjustments would be scaled for budget neutrality, as required by the statute. For example: For every “winner” (that receives a bonus), there will be a “loser” (that receives a penalty)
  • The CPS would also be used to determine whether a MIPS Eligible Clinician qualifies for an additional positive adjustment factor for exceptional performance
  • Ranks peers nationally and reports scores publicly. Aim HIGH. Your patients want to see the Quality they see in you reflected in the numbers!

Need guidance on success? Ask yourself these questions:

  •  Do you have an EMR? Is it Certified?
  •  Are you successfully participating in PQRS? Meaningful Use?
  •  Have you completed a Security Risk Analysis?

For more information on MIPS, contact us by email: or phone: 800-288-2818

You can also reference the CMS website: QPP.CMS.GOV