Unlike previous incentive programs like PQRS and Meaningful Use, MIPS does not award fixed payment adjustments. The payments vary based on your performance. Read this blog post to familiarize yourself with MIPS scoring and what it means for your eye care practice.
Though 2020 is the fourth year of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP), there’s a lot of confusion surrounding what MIPS (Merit-Based Incentive Payment System) is and how it will be calculated, especially for eye care providers. Through this post, our experts are addressing some of the frequently asked questions on how to calculate MIPS.
What is MIPS?
MIPS combines and replaces the PQRS, Meaningful Use and the Value-Based Modifier incentive programs overseen by the Centers for Medicare and Medicaid Services (CMS), and changes the way Medicare reimburses healthcare providers, stressing the quality of care over volume.
MIPS is one of the two significant tracks under the QPP. The other track is Advanced Alternative Payment Models (APMs), a more customized payment approach. Most eye care providers will be required to report for one program or another.
The MIPS score, also known as Composite Performance Score (CPS), will be calculated based on your performance in the following four categories:
- This measure has replaced the Physician Quality Reporting System (PQRS).
- Eligible clinicians must report six quality measures, out of which one measure must be an outcome or a high-priority measure .
- In 2020, Eligible clinicians must report on 70% of their patients who qualify for each measure, or data completeness for the full calendar year.
- This measure has replaced the Value-Based Payment Modifier (VBM) program.
- CMS calculates cost using claims data, no additional submission is required.
- CMS uses the claims data to calculate total cost of care during the calendar year which is then used to determine achievement points based on comparisons to established benchmarks.
Promoting Interoperability (PI)
- This measure has replaced the Advancing Care Information (ACI).
- Eligible clinicians must submit data for applicable measures for the same continuous 90-day (or more) period within the calendar year, unless an exclusion is taken. You must also attest to satisfying certain conditions of the category, such as completing a Security Risk Analysis.
- This category requires the use of Certified Electronic Health Record Technology (CEHRT)
- This new category was introduced with the MIPS program. The number and type of activities you must perform will depend on the size of your practice.
- Improvement activities must be carried out for at least 90 consecutive days during the calendar year.
- It is important to document your chosen activities as thoroughly as possible. You must be able to provide evidence that you have performed an improvement activity in the event of a CMS audit.
- Documentation will vary according to the activity you have chosen.
MIPS payment adjustments
Each performance category carries a different weight that will shift as the program progresses. It may also be adjusted depending on any exclusions or hardships that become available throughout the year.
Performance in each category is weighted to calculate a final score (0-100). Each category’s final score is compared to a performance threshold to determine payment adjustments. For instance, the performance threshold for the 2020 performance period is 45 points. Then CMS uses a scaling factor to achieve budget neutrality.
Here’s how payments adjustments are determined:
|Your Final Score for the 2020 Performance Period||Payment Impact for MIPS Eligible Clinicians in the 2022 Payment Year|
|0.00 – 11.25 points||-9% payment adjustment|
|11.26 – 44.99 points||Negative payment adjustment (greater than -9% and less than 0%)|
|45.00 points||Neutral payment adjustment (0%)|
|45.01 – 84.99 points||Positive payment adjustment (scaling factor applied to meet statutory budget neutrality requirements)|
|85.00 – 100.00 points||Positive payment adjustment (scaling factor applied to meet statutory budget neutrality requirements)
Additional (positive) payment adjustment (scaling factor applied to account for funding pool)
Table 1. 2020 Payment Impact for Eligible Clinicians. Reprinted from 2020 QPP Final Rule.pdf
Payment adjustments are based on performance from the last two years. For instance, performance in 2020 will determine payment adjustments in 2022.
Eye care practices can achieve higher performance scores and positive MIPS payment adjustments by paying attention to these details and creating a strategic approach to meeting program requirements. And, let’s not forget that the financial and reputational impacts of the MIPS score are attached to clinicians. This means that even if the clinician changes practices, the new practice will inherit the clinician’s MIPS score from the previous practice. Also, every MIPS score earned by a clinician is a permanent part of a publicly released report maintained by CMS. This makes MIPS scores an even more significant part of your resumé.