Every year Medical practices scramble for answers and end up with more questions when it comes to the reporting requirement under Affordable Care Act (ACA). MIPS is an acronym for Merit Based Incentive Payment System and CMS has been changing the instructions & requirements for reporting clinical data every year. This leads to confusion and questions, this is my attempt to help you understand more about MIPS/MACRA for 2018 in a summarized form.
Most of the providers are not aware that they might NOT be qualifying to report MIPS data this year. First thing a practice / physician should do is confirm if they qualify. This information can be confirmed at CMS website https://qpp.cms.gov/participation-lookup
Clinicians Included in MIPS
- Physicians (including Doctor of Medicine, doctors of osteopathy, osteopathic practitioners, Doctor of Dental Surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors)
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Groups or virtual groups that include one or more of the clinician types above
- Groups and clinicians should only report MIPS data if they qualify
Basic qualifying criteria for any clinician:
- Joined Medicare before 2018
- Has seen more than 200 Medicare patients
- Billed Medicare for more than $90,0000
To avoid a penalty in 2018, you must submit MIPS measures that total at least 15 MIPS points from one category, or a combination of categories. You’ll receive a negative reduction of up to -5% for not reporting or not reporting at least enough data to earn 15 MIPS points.
|To Avoid A Penalty In 2018, You’ll Need to Earn At Least 15 Points|
You can report as an individual, or group. You are required to report on 6 measures. Reporting more than 6 measures will not get you more points. The key is to report the best performing measures to get most points. The formulas and weightage of points is a complex labyrinth and time consuming to get a handle on. A good way to solve for it is to know if you have a plan on what method you would be using to report this data.
Check if your EHR has an option or dashboard for you to choose measures, track performance and report MIPS to CMS. If yes, your job is much easier, just pay the fees and get the reporting done.
If not than you would need to find a CMS approved Registry (paid service). The registry will provide step by step instructions to report MIPS. They will be able to help with options on reporting, report for minimum 15 points to avoid penalty or report more.
Always remember to report genuine data with enough supporting documentation available, in case your practice or provider is audited. MIPS is auditable by CMS for up to 6 years after the associated data submission. Annually, CMS will selectively audit clinicians and groups and require them to share primary source documents, such as patient medical records, within 45 days of request.
Don’t forget the deadline to submit MIPS 2018 claims-based data is March 31st 2019. You still have enough time to collect data, choose measures and source of reporting to avoid penalty or adjusted payments from Medicare in 2020, Well if you qualify to report in 2018. Contact Neolytix to guide you for 2018 MIPS or any other compliance needs.