MIPS 2018: 90 Day vs. Calendar Year Reporting

We have received many questions about MIPS reporting for 2017, specifically about reporting periods and confusion caused by the “Pick Your Pace” plan. The CMS “Pick Your Pace” program with its 3 “paces” was the source of misinformation as it does not properly summarize the actual regulations, and caused many participants to mistakenly believe that “full participation” would earn a higher score than “partial participation.” Your score is not weighted according to the length of the reporting period, so a full calendar year of reporting is not necessary. A 90-day reporting period will allow you to achieve the highest possible payment adjustment.

For 2017 Reporting here are the facts:

  • Each of the 3 applicable performance categories (Quality, Improvement Activities, and ACI) have a minimum reporting period of 90 days.
  • These don’t have to be the same 90 days.
  • Reporting periods longer than 90 days are not awarded a higher score and there is no scoring disadvantage to reporting only 90 days.
    • For those using the IRIS Registry, due to their guidelines you can report the full year, just one quarter, or consecutive combinations of quarters such as Q1+Q2 or Q2+Q3+Q4.

Looking ahead to 2018, CMS is again giving you the option of reporting periods to allow you time to upgrade to a CEHRT to 2015 Edition CEHRT and become familiar with new workflows. The reporting period for MIPS Quality and Cost is required to be the full calendar year; however, Improvement Activities and ACI will each only require a minimum 90-day reporting period.

For 2018 Reporting here are the facts:

  • MIPS ACI for 2018 only requires a 90-day reporting period, and there is no scoring advantage to reporting MIPS ACI for the full calendar year. You are still eligible to receive the 10-point 2018 MIPS ACI bonus if you use the fully 2015 Edition certified software during a 90-day period. In fact, using a hybrid of 2014 Edition and 2015 Edition to report for a full year will cause you to lose the 10-point MIPS ACI bonus for use of 2015 Edition CEHRT.
  • A full calendar year of reporting is also not necessary for MIPS Improvement Activities relying on use of EHR in 2018 MIPS. The Improvement activities may be performed for 90 days, or may be performed for the entire performance year using the 2014 Edition version of software for the first part of the year and the 2015 Edition version for the remainder of the year. You will not miss out on any bonus points as there is no 2015 Edition bonus applicable to MIPS Improvement Activities scoring. You may use the same activities as the prior year, aiming for continuous quality improvement or switch to a different set of Improvement Activities.
  • While the Quality performance category does require a full calendar year of reporting those using the IRIS registry for reporting will have no issue as the registry has an electronic integration with your EHR and will continue through to the 2015 Edition version of Software. Information will be captured by IRIS before and after the upgrade.

It is our recommendation that you should only plan to report your 2018 MIPS ACI performance after upgrading to 2015 Edition CEHRT because you will earn a 10-point bonus for use of 2015 Edition CEHRT that is not available if using a mix of 2014 Edition and 2015 Edition CEHRT during the performance period.

Still confused?

To help with MIPS in 2017, 2018 and beyond Eye Care Leaders has created the MIPS Assurance Program. Our MIPS consultants will work with your practice to create and execute a plan tailored to maximize your MIPS performance score and positive MIPS payment adjustments. When it is time your MIPS consultant will assist you with attestation and electronic submissions, including the quality measure calculations mentioned above. Learn more about MIPS Assurance today.

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