The Merit-based Incentive Payment System, called MIPS, streamlines three previous pay-for-performance programs and also adds a fourth component to promote the ongoing improvement and innovation to clinical activities. The four categories are as follows:
Unlike the current (2016) one-size-fits-all payment programs, MIPS gives clinicians the flexibility to report on the activities and measures that most accurately demonstrate the performance of their practice.
CMS estimates that about 90% of eligible clinicians will be in the MIPS reporting camp for 2017, including both individual providers and provider groups. (To be assessed as a group practice under Group Practice Reporting Option (GPRO), providers under the same taxpayer identification number (TIN) would have to have registered their group by June 30th.)
MIPS Eligible Clinicians
For 2017, the following Medicare Part B eligible clinicians are deemed eligible for the MIPS:
1. A provider must be a physician, physician assistant, nurse practitioner, clinical nurse specialist, certified registered nurse, or anesthetist.
2. A provider must not be in the FIRST year of Medicare Part B participation.
3. A provider’s Medicare billing charges must be more than $10,000 and s/he must provide care for more than 100 Medicare patients in one year.
4. A provider cannot be a hospital or facility.
5. A provider is in a non-advanced APM.
6. A provider can be in an advanced APM but must not have enough payments or patients through the advanced APM to be a Qualified Provider.
Beginning year three, provider eligibility is scheduled to expand to include physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, or dietitians/nutritional professionals.
All eligible Medicare Part B clinicians should plan to report to CMS beginning January 1, 2017, as this is slated to be the first performance year.
MIPS Performance Categories
Under the MIPS, eligible clinicians will be measured and assigned a single MIPS composite performance score (CPS). The CPS will be based on the clinician’s performance in the following four, weighted performance categories. For year one, the scores are weighted on a 0-100-point scale.
1. Quality Performance Score – MIPS CPS impact: 50%
- Providers will select from individual measures or a specialty measure set. When selecting individual measures, six quality measures are required and must include at least one cross-cutting measure and one outcome measure (or another high priority measure, if outcome is unavailable.) Each measure can earn up to 10 points for a maximum quality measure score of 60.
- If submitting via claims, at least 80% of eligible cases are required for score determination. If submitting via a registry, EHR, or QCDR then 90% of eligible cases are required.
- The maximum score for this category is 80 or 90 points, depending on group size – less than 10 members or more than 10 respectively.
- Two or three additional population measures, depending on group size, will be automatically calculated as part of one’s overall Quality score.
2. Resource Use Performance Category (RU) – MIPS CPS impact: 10%
- The RU category evaluates clinicians by comparing resources used to treat similar care episodes and clinical condition groups across practices. CMS generates calculations based on claims so there are no reporting requirements for clinicians.
- The risk can be adjusted to reflect external factors.
- Unlike the prior value modifier assessment, the new resource use category adds 40 plus episode specific measures to address specialty care concerns.
3. Clinical Practice Improvement Activity Performance Category (CPIA) – MIPS CPS impact: 15%
- CPIA category rewards points for clinical practice improvement activities that improve care coordination, beneficiary engagement, patient safety, and expanding practice access.
- Clinicians must select at least one activity from 90 plus proposed activities to achieve at least a partial score. Depending on the measure, 10 to 20 points can be earned from each activity towards a total maximum score of 60. (Patient-centered medical homes, medical homes, and comparable specialty practices “automatically” receive full credit in this category.)
- A minimum of half credit is awarded for APM participation.
4. Advancing Care Information Performance Category (ACI) – MIPS CPS impact: 25%
- The ACI category assesses clinicians on key measures of health IT interoperability, information exchange, and data security. Insecure data cannot be scored and will result in 0 points in this category, even if many of the other measures in this category earn points.
- The maximum score of 100 is a composite of a base score (up to 50 points), a performance score (up to 80 points) and a bonus point. Earned scores above 100 are capped at 100 and will earn 25 points towards the MIPS CPS.
- The three performance objectives: Patient Electronic Access, Coordination of Care through Patient Engagement, and Health Information Exchange are highly patient-centric and place great emphasis on data access and the patient’s active participation in his/her care.
- Unlike the previous EHR incentive, the “all or nothing” threshold for measurement has been dropped. The redundant measures have also been removed to alleviate the reporting burden. The Clinical Provider Order Entry and Clinical Decision Support objective have also been removed. Additionally, the number of required public health registries to which clinicians must report has been reduced.
For more detailed information, check out the CMS Fact Sheet here: (https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Advancing-Care-Information-Fact-Sheet.pdf)