As discussed in a recent Medical Business Journal article, 2017 is the last year to sign up for the Merit-based Incentive Payment System, more commonly known as MIPS. This system, one of the two possible tracks implemented by MACRA, offers a performance-based payment adjustment for any practice that submits the proper documentation regarding the quality of care they provided during a certain period of time.
Practices can report these criteria at four different levels and receive commensurate reimbursement for each. For those who report nothing, they will receive a -4% payment adjustment for 2019. Those who report the bare minimum will keep their rates even with a neutral adjustment. Submitting 90 days of data will give a decent chance for a positive reimbursement, while submitting a full year will give a much higher chance.
However, there are still specific guidelines that must be followed. Practices reporting in the 90-day or year-long categories for MIPS must be sure to include a minimum of six quality measures with at least one of those being an outcome measure, as well as taking care to maintain 50% data completeness for each set. Given that there are a full 271 different quality measure to choose from, this task should prove far from difficult.
But if a practice doesn’t fulfill these requirements, CMS has no choice but to step in and investigate. Using their Eligibility Measure Applicability (EMA) system, CMS looks to see if there are any additional quality measures that could have been counted. If they cannot find anything else that should have been reported, than the original incomplete documentation is accepted and the practice is not penalized. If, however, they do discover additional criteria, then these measures will actually count against the practice’s final score, possibly leading to reduced reimbursement as if the practice had never reported any measures at all. Because of this catch, practices should be extremely careful when submitting the MIPS documentation to be sure that they do not skip any essential measures.