January 1, 2018
Begin recording data on how you provide quality care, and use technology to support and improve your practice to deliver cost-effective care.
You also have the option to join a MIPS APM or an Advanced APM and provide care through that model.
Februrary 9, 2018
MIPS transition years extended till 2021 (3 additional years). The key elements associated with the post-tranisition period (performance threshold to be established at median performance rate and Cost category weight of 30%) also postponed till 2022.
Only the Medicare Part B eligible services will be considered for MIPS eligibility determination and payment adjustment calculation.
Cost Improvement Scoring will not be considered for MIPS score calculations in 2018.
June 29, 2018
The 2017 Performance Feedback Reports became available to the providers which can be accessed by logging in to the QPP portal using the EIDM account.
For any discrepency, Targeted Review could be submitted till October 15, 2018.
Dec 31, 2018
The 2018 performance year ends on Dec 31, 2018. For MIPS participants, data for entire year will be assessed for Quality and Cost categories. While minimum 90 continous days of performance data will need to be submitted for PI and IA categories.
This is also the deadline to claim ACI hardship exception for 2018 and to submit Virtual Group election to CMS for performance year 2019.
January 1, 2019
Based on 2017 performance, clinicians may earn a neutral, positive, or negative MIPS payment adjustment as communicated in the Performance Feedback Report.
2017 Advanced APM participants may earn a 5% incentive payment in 2019.
March 31, 2019
Last day to submit performance data for 2018 performance year to CMS to earn a neutral or positive payment adjustment.
Failure to submit by the deadline will result in negative payment adjustment of 5%.
Based on the data submitted, MIPS score and the payment adjustments will be calculated for all MIPS and MIPS-APM participants.
The clinician types who were eligible in 2017, are also eligible in 2018. No additional eligible clinician types have been added. The eligible clinicians for 2018 are:
• Doctors of Medicine (MD)
• Doctors of Osteopathy (DO)
• Doctors of Dental Surgery/Dental Medicine (DMD/DDS)
• Doctors of Podiatry (DPM)
• Doctors of Optometry (OD)
• Chiropractors (DC)
• Physician Assistants (PA)
• Nurse Practitioners (NP)
• Clinical Nurse Specialists (CNS)
• Certified Registered Nurse Anesthetists (CNA)
Low Volume Threshold
All the above-mentioned clinician types would be covered under MIPS provided they exceed the Low Volume Threshold ($90,000 in Medicare Part B services only AND provide care to 200 Medicare Part B beneficiaries) at the individual or group level, are not new Medicare-enrolled (been enrolled in Medicare for less than one performance year), and do not qualify as QP or partial QP under an Advanced APM.
There are four performance categories under MIPS. Each of these categories have been assigned weights that total up to 100. Points can be earned for each of the categories.
The maximum points for each category are different.
Maximum Points for Quality Category: Depends on the number of measures that need to be reported. (60 points if 6 measures required)
Maximum Points for Cost Category: 10 Points
The category score is determined as:
Category Score = (Earned Points/Maximum Points) Category Weight
The Composite Performance Score (CPS) or MIPS Score is:
Sum total of all the category scores + Complex Patient Bonus + Small Practice Bonus (if applicable)
|Low Volume Threshold to Exceed to be Eligible||$30,000 in Medicare Part B allowed |
charges (services and drugs) AND provide care to 100 Medicare Part B beneficiaries
|$90,000 in Medicare Part B allowed |
charges for covered professional services only
AND provide care to atleast 200 Medicare Part B beneficiaries
|Payment Adjustment Range||+/- 4%||+/- 5%|
|Payment Adjustment Applicable to||Medicare Part B allowed
charges for services and drugs
|Medicare Part B allowed
charges for services only
|Performance Threshold||3 points||15 points|
|Additional Performance Threshold||70 points||70 points|
|Reporting Options||Individual, Group||Individual, Group, and Virtual Group|
|Cost Category Weight||0%||10%|
|Data Completeness for Quality Category||50%||60%|
|Quality Reporting Period||90 days||Full Calendar Year (12 months) |
|New Bonus Options||Not available||• Small Practice Bonus
• Complex Patient Bonus
• 2015 EHR Certified Edition Bonus
• Performance Improvement Bonus Points for Quality category only
|Small Practices Scoring Considerations||Double points for IA category||• Double points for IA category
• Will receive 3 points even if data completeness falls below 60% for a quality measure for measures that do have a benchmark and meet the case minimum requirement. The other clinicians will receive only 1 point.
• Can apply for Hardship Exception for PI category if facing overwhelming barriers to adopting a certified EHR.
SMALL PRACTICE BONUS
Small practices (practices consisting of 1-15 eligible clinicians) will be awarded 5 additional points towards the final MIPS score E.g. For a small practice, a MIPS score of 65 will become 70 (65+5). This bonus will be awarded only if the MIPS eligible clinician submits data for at least 1 performance category for the performance year 2018. (No submission required for the Cost category)
COMPLEX PATIENT BONUS
MIPS eligible clinicians can earn up to 5 bonus points for the treatment of complex patients. This would be determined based on a combination of the Hierarchical Condition Categories (HCCs) and the number of dually eligible patients treated. To earn this bonus, MIPS eligible clinicians must submit data for at least 1 performance category.
2015 CERTIFIED EHR BONUS and EHR Decertification Exception
Providers can still use 2014 edition CEHRT to capture and report the data for MIPS 2018; but a bonus of 10% will be awarded towards Promoting Interoperability (PI) category score for exclusively using the 2015 certified edition to report for performance year 2018. Additionally, MIPS eligible clinicians whose EHR was decertified could also apply for exception from reporting PI category.
PERFORMANCE IMPROVEMENT BONUS POINTS FOR QUALITY CATEGORY
Improvement scoring bonus points will be awarded for the first time in 2018 for showing an improvement in performance in Quality as compared to 2017 peerformance. The improvement scoring will be measured at the performance category level. Up to 10 percentage points could be earned for the Quality performance category .
PERFORMANCE IMPROVEMENT BONUS POINTS FOR COST CATEGORY
Following the Bipartisan Budget Act of 2018 (HR 1892) enacted on Feb 9, 2018, the performance improvement for Cost category will not be considered for 2018 MIPS score calculations.
Option to report as a Virtual Group has been introduced from 2018.
A Virtual Group is a combination of two or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (irrespective of specialty or location) to participate in MIPS for a performance period of a year.
The election deadline to participate in 2018 was Dec 31, 2017.
2014 EDITION CERTIFIED EHR ALLOWED
Providers can still use 2014 edition CEHRT to capture and report the data for MIPS 2018. However, a bonus of 10% will be awarded towards PI score for exclusively using the 2015 certified edition for PI reporting in 2018.
MIPS eligible clinicians with decertified EHRs could also apply for exception from reporting under PI performance category.
EXTREME AND UNCONTROLLABLE CIRCUMSTANCES
Beginning 2018 performance year, the clinicians impacted by natural disasters can claim the hardship exception for all the performance categories - Quality, Cost, Improvement Activities, and Advancing Care Information.
The deadline for the hardship exception application is December 31, 2018.