A Quick Guide to MIPS in 2018: 5 Things You Should Know

All eligible clinicians must report MIPS to avoid a negative adjustment. Eligible clinicians are Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists and Certified Registered Nurse Anesthetists who billed over $30,000 in Medicare allowable charges or saw over 100 unique Medicare patients in calendar year 2017. Eligible physicians are Doctors of Medicine, Osteopathy, Dental Surgery, Dental Medicine, Podiatric Medicine, Optometry, and Chiropractic Medicine.

Medicare allows providers to report 1 patient (worth 3 points) in order to avoid the 4% penalty to complete their participation. Eligible clinicians who do not report will be assessed a 4% penalty. If you submit only 1 patient’s data, there will be no impact on your Medicare payments in 2019. Final reporting must be completed by March 31, 2018 and scores will be released by November 2018.

Yes. The Final Rule for 2018 included an addendum for 2017 reporting. The addendum included the Extreme and Uncontrollable Circumstances Policy which exempts some eligible clinicians. Providers affected by Hurricanes Harvey, Irma, and/or Maria or the California Wildfires are automatically exempt from reporting. Exempt providers will have a neutral adjustment that will not affect their payments.

No action is required to avoid the penalty. Providers do not need a letter from Medicare or to apply for this exception. If you are in a county identified by Medicare as one adversely affected by the previously listed events, then you are exempt from Performance Year 2017 reporting. This includes all counties in Florida and a number of counties in Texas. Providers exempted under this policy can still choose to report and will then be scored like everyone else.

All eligible clinicians must report MIPS in 2018. Performance Year 2018 includes dates of services January 1, 2018 through December 31, 2018. MIPS reporting is due March 31, 2019 and will affect Medicare payments in 2020. The possible penalty has been raised to 5% while the incentive is ~2%, up from 1% in Performance Year 2017. Eligible providers are physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists who will bill over $90,000 in Medicare allowable charges or who will see over 200 unique Medicare patients in calendar year 2018. This second transition year requires slightly more data than 2017 to simply avoid an impact on your 2020 payments.

To avoid a 5% penalty in your 2020 payments, providers will have to earn 15 points in the Quality Performance category (replacement for PQRS). Providers will need to report enough Medicare patients to earn 15 points in that category. Currently, the Quality Performance category requires providers to submit data for 6 measures. Submitting data in a measure gives a provider at least 3 points. Therefore, it is possible that providers will be able to report 1 Medicare patient that meets the criteria in each of the 6 measures to complete their 2018 reporting. This would correlate to 1 per measure or 1 patient across all 6 measures.