MIPS 2017: Pick Your Pace

Th Merit Based Incentive Payment System (MIPS) is in place for 2017 and is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This program is designed to replace Meaningful Use and the Physician Quality Reporting System (PQRS). MIPS in 2017 is often referred to as a “Pick Your Pace” program. If the pace you pick is the test participation all you have to do is submit one measure. If you do nothing you will be penalized in 2019 based on 2017 performance.

During 2017 eligible professionals have multiple options for successfully participating in MIPS.

These include:

• No Participation: Failure to report any data in 2017 will result in a negative 4% payment adjustment in 2019 on Medicare Part B claims.
• Test Participation: Reporting data for one quality measure or one improvement activity or the required base measures in the Advancing Care Information (ACI) category.
• Partial/Full Participation: Reporting data for a minimum 90-day period for all the required quality measures and required improvement activities and required ACI measures.
• Advanced Alternative Payment Model: Receive a 5% bonus in 2019 if you see 20% of your Medicare Part B patients through an Advanced APM in 2017 or if you receive 25% of Medicare Part B payments.

Advancing Care InformationOverview

Advancing Care Information (ACI) replaces the Meaningful Use (MU) category. Unlike years past in MU reporting, this new category can be reported on as a group or individually and does not require all or nothing electronic health record (EHR) measurement. In the past, as long as physicians were meeting thresholds under MU they passed. Now with ACI measures, performance does matter.

ACI has expanded from participating physicians only to include nurse practitioners, physician assistants, certified registered nurse anesthetists and clinical nurse specialists. Data can be submitted through several reporting methods including attestation, EHR, qualified registry, Qualified Clinical Data Registries (QCDR) and the federal CMS web interface. Please note that if you choose to report under the CMS web interface you had to declare that to CMS by June 30, 2017.

Advancing Care Information Reporting Requirements

There are two measure sets to report on in 2017. The measure set you use is based on your EHR edition year. If you’re using 2015 edition EHR technology, you must report all base measures to obtain performance and bonus scores. If you do not report the minimum base measures you will receive zero points in the ACI category. You must obtain at least 100 points to receive the full 25% ACI score. Please refer to https://qpp.cms.gov/ mips/advancing-care-information to identify which measure set you should be reporting based on your EHR edition.

What’s Next?

By now everyone understands the importance and urgency of MIPS. Since 2017 is a flexible year with reporting options, now is the time to figure out your future Alternative Payment Model (APM) participation strategy, if that’s an option for you. Otherwise MIPS participation is required moving forward. Although we don’t know the future reporting requirement, it’s likely not to be a “Test Year.” You should be prepared to submit and comply with all MIPS components to avoid future penalties.

Christine O’Malley is a consultant at PBC Advisors, LLC, in Oak Brook. The company provides business and management consulting and accounting services to physician practices and hospital systems. PBC has a combined 300 client medical practices and hospitals. Visit the website at www.pbcgroup.com.