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5 MIPS topics for a solid MIPS strategy – Part 2

How do you start to create a solid strategy?

When thinking about a solid MIPS strategy we narrow in on five topics… Read part two of our three-part series.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) replaced the Medicare Sustainable Growth Rate (SGR), which was how CMS previously controlled the cost of Medicare Payments to physicians. MACRA is aimed at strengthening Medicare access, improving physician payments, and encouraging better patient care among other improvements. Under MACRA, CMS is required to implement a Quality Payment Program (QPP), which offers clinicians and practices two separate tracks: (1) the Merit-Based Incentive Payment System (MIPS) track; and, (2) the Advanced Alternative Payment Model (Advanced APM) track. Both tracks can result in penalties for not meeting certain requirements/benchmarks or incentives for meeting and exceeding requirements/benchmarks.

When thinking about a solid MIPS strategy we narrow in on five topics:  eligibility, measure selection, penalties and incentives, and information availability. The 2019 proposed and final rulemaking as well as the information available on the QPP portal have revealed a great deal about these topics and how they should be considered within the scope of a practice’s MIPS strategy for 2019 and for years to come.

These five topics will be covered in a three-part series – welcome to part two. Parts one and three can be found here.

Measure Selection

Which measures are in and which measures are out? The Meaningful Measures Initiative causes several process-type measures to be retired to improve patient outcomes by focusing on outcome-based measures. 26 measures were retired after the 2018 Performance Year. The effect of this mass-measure retirement is that clinicians and practices will need to understand which, if any, of their chosen 2019 measures might be eliminated or topped-out. Only ten of the retired 26 measures were topped out so it is important to note that CMS is making decisions about which measures to maintain, outside of the topping-out schedule, which normally occurs over a four-year period.


As proposed, CMS raised the performance threshold (e.g. the minimum score needed to avoid penalty) from 15 points to 30 points for 2019, which effectively doubled the score a clinician or practice will need to achieve in order to avoid a MIPS penalty. This should have considerable bearing on your MIPS strategy if you have only sought to avoid penalty in past performance periods.

For MIPS eligible clinicians and practices who have previously reported just enough to meet the minimum performance threshold to avoid a penalty, reporting options in 2019 to meet this end are limited. Depending on size and category weighting, most clinicians and practices will need to report at least two performance categories to reach the 30 points required to avoid penalty. Reporting on Improvement Activities alone would achieve only 15 of the requisite 30 points. Reporting only the minimum of six Quality measures, which (in most cases) would only achieve 3 points per measure, which is only 18 points (equal to just 13.5 pts when weighted @ 45%). Reporting perfectly on the Promoting Interoperability category would only achieve 25 points. All three options alone would capture less than is required for the 30 point threshold needed to avoid penalty. Understanding how your MIPS strategy maps to the MIPS Composite Performance Score (CPS) and potential penalties is crucial for the 2019 reporting year.


Incentives are twofold under MIPS. There is the regular payment adjustment (for 2019, CMS touts +/-7%) and there is the exceptional performance adjustment of $500 million set aside by CMS each year for the first 5 years of the program (CMS touts 0.5% to 10% of that pie for exceptional performance).

Payment Adjustment

In a peculiar contrast, for MIPS ECs or practices who have focused on performance and maximum achievement the increase to 30 points to avoid penalty is good news. The higher minimum score means that more clinicians will be penalized for not achieving the performance threshold and therefore more money will fund the payout to the higher performance achievers.

Exceptional Performance Adjustment

In 2017, 71% of MIPS eligible clinicians achieved scores of 70 or higher for an additional exceptional performance adjustment. If fewer had reached the score of 70 for exceptional performance, there would have been more money to distribute between those that reached that level of performance. So, another piece of good news for exceptional performers in 2019 is that, by CMS raising the exceptional performance threshold from 70 to 75, it will make it more difficult for clinicians to reach that scoring level, which means a bigger piece of the $500 million dollar exceptional performance pie will be distributed to those who perform at that level. Had CMS kept the exceptional performance threshold at 80 for 2019, this would have been even better news for exceptional performing MIPS eligible clinicians.

The criteria which determine MIPS eligibility are multi-faceted and complex. ReportingMD understands these criteria’s and works with client organizations to optimize incentive performance in the MIPS (and other value-based care programs.)

With the proven experience of our client services team and Total Outcomes Management (TOM™) a powerful measure calculation solution, ReportingMD can help you navigate the complexities of the MIPS program.

We were invited by CMS to help develop the MIPS program, which provides our team with unique expertise and a depth of experience that’s unmatched.

Using TOM™, practices can gain operational visibility to the quality performance of their physicians and avoid CMS penalties for non-compliance. TOM™ aggregates data from multiple sources to identify and manage patient care gaps.

Learn why mid to large sized healthcare organizations turn to ReportingMD for powerful tools that help improve patient care, improve quality outcomes, and maximize reimbursements.

About the author

Molly Minehan is ReportingMD’s Vice President of Operations & Innovation

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