Medicare's Merit-based Incentive Payment System and Why You Need to Take Action NOW
Written by Edito   
Tuesday, May 16, 2017 12:08 PM

MIPs is now in effect and in this first year you have a number of options.  You have until October to begin collecting data, or a penalty will be imposed. Everyone will be affected in the next 2-3 years.

On April 16, 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 to:

  • Permanently repeal the fatally flawed Medicare Sustainable Growth Rate (SGR) methodology, avoiding annual double digit payment cuts;
  • Provide stable, annual updates for services paid under the Medicare Physician Fee Schedule (PFS);
  • Transition Medicare payments from a volume based program to one that rewards performance based on value and improvement;
  • Establish new priorities and provide funding for the development of quality measures; and more.

MACRA was designed to offer providers two new Medicare payment model pathways that incentivize the delivery of value-based, high-quality, efficient patient care versus volume-based care. On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released a final rule that detailed the regulations for creation and implementation of these new payment system pathways, collectively referred to as the Quality Payment Program (QPP).

Under the QPP, clinicians have two payment model pathway options for reporting quality data to CMS: the Merit-based Incentive Payment System (MIPS) and Advanced Alternate Payment Models (APMs).  DCs are not eligible to participate in Advanced APMs in 2017.

Eligible clinicians defined for years one and two include Doctors of Chiropractic, and additional categories of clinicians may be added in year three, including physical therapists, occupational therapists, and speech language pathologists.

While DCs are included in the definition of eligible clinician you may be exempt from participating in MIPS during the 2017 performance year if you enroll in Medicare for the first time in 2017, and you have not previously submitted claims under Medicare; or if, over a 12-month, you bill Medicare Part B for no more than $30,000 and/or provide care for no more than 100 Medicare Part B beneficiaries.

To be eligible for the QPP and participate in MIPS, a DC must bill more than $30,000 AND see more than 100 Medicare beneficiaries. For example, if you see 101 Medicare beneficiaries during the performance period, but only bill $29,000 then you would be exempt from MIPS.

It is important to note that the low volume threshold is only required to be in place for the first year (2017), and eventually the reporting requirements will apply to all physicians. Therefore, it is better to participate now and test the waters when you are not subject to any negative impact.

MIPS low-volume threshold exemptions for the 2017 performance year will be determined by CMS through the review of past claims from two qualifying periods (September 2015-August 2016, or September 2016-August 2017). They will then offer an “NPI level lookup feature” that will allow providers to determine if they are below the low-volume threshold and therefore excluded from MIPS. This tool should be available in the near future on the CMS Quality Payment Program website.

During 2017, you can “Pick Your Pace of Participation” and there are three (3) options for participation:

  1. Test the Quality Payment Program - As long as you can submit some data, i.e. one quality measure or one improvement activity, you can avoid the downward payment adjustment - you must submit data prior to October 2, 2017.

  2. Participate for the Full Year - Start collecting on January 1, 2017 and submit for the full year and earn a moderate positive payment adjustment.

  3. Participate for the full year but submit data for 90 day period - This option will earn a neutral or small payment adjustment; you must submit data no later than October 2, 2017.

Regardless of the option chosen, DCs must submit data by March 31, 2018.

MIPS will replace and consolidate into a single reporting program three Medicare programs that you are probably familiar with: the Physician Quality Reporting System (PQRS), Meaningful Use (MU), and the Value- Based Payment Modifier. You will receive Medicare payment adjustments based on performance data that you submit. MIPS scoring considers four weighted performance categories:

  • Quality (60%)
  • Advancing care information (25%)
  • Improvement activities (15%)
  • Cost (calculated from adjudicated claims, no data submission required).

The MIPS performance period for 2017 began January 1 and closes December 31, 2017. During this first year of MIPS, eligible clinicians must submit at least 90 days worth of data to avoid a downward payment adjustment. Clinicians who are not yet collecting data have until October 2, 2017 to get started. All clinicians reporting for 2017 will have until March 31, 2018 to deliver performance data in order to avoid the first downward payment adjustment which will go into effect on January 1, 2019.