CMS Reporting and Submission

MACRA – MIPS, APMs

CMS Reporting and SubmissionReportingMD is a qualified registry and Qualified Clinical Data Registry (QCDR) and has a certified EHR application for CMS Reporting and Submission.  This makes ReportingMD uniquely positioned to report on all aspects of MACRA.

Within MACRA, the Quality Payment Program (QPP) streamlines several pay-for-performance programs in the Merit-based Incentive Payments System (MIPS) and provides incentive payments for participation in Advanced Alternative Payment Models (APMs) like the Medicare Shared Savings Program ACO.

As a QCDR with a certified EHR technology module, ReportingMD is ready to accept data as a specialized registry and will use that data to improve population health outcomes. ReportingMD can receive data generated from Certified EHR Technology (CEHRT) through any appropriate secure mechanism. Manual data entry into a web portal would not qualify for submission to a specialized registry.

Merit-based Incentive Payment System (MIPS) 

MIPS pulls activities and requirements from 3 past pay-for-performance programs and reassembles them into 1 cohesive program made up of 4 categories, which are: Quality, Promoting Interoperability (PI), Improvement Activities (IA), and Cost. Below is the payment adjustments schedule for MIPS as well as a summary of each MIPS performance category.

MIPS Performance Categories

Quality (formerly Physician Quality Reporting System, PQRS)

  • Quality makes up 50% of the MIPS Composite Performance Score (CPS)
  • Submission mechanisms include: qualified registry, QCDR, EHR, Part B Claims, CMS Web-interface, CAHPS for MIPS survey
  • There is an All-cause Hospital Readmissions measure, which will be automatically calculated using administrative claims and requiring no submission by the clinician
  • Each MIPS eligible clinician or group will select 6 measures to report on:
    • 1 of the 6 measures must be an outcome measure
    • If no outcome measure is available for a provider or practice, they must pick a high priority measure (from appropriate use, patient safety, efficiency, patient experience or care coordination) in lieu of an outcome measure
    • MIPS eligible clinicians or groups can choose to report on individual measures or they can report on a specialty measures set
      • If they choose to report on a specialty measures set, they must still meet the requirements to report on an outcome measure (or other high priority measure)
    • MIPS eligible clinicians can choose to report individually or as a group. Reporting as a group is similar to reporting under the Group Practice Reporting Option (GPRO)

Improvement Activities

  • Improvement Activities (IA) makes up 15% of the MIPS Composite Performance Score (CPS)
  • Submission mechanisms include: qualified registry, QCDR, EHR, attestation, and Part B Claims
  • MIPS eligible clinicians or groups choose from an inventory of over 100 proposed activities, each of which is categorized as high or medium
    • For full credit under this category, MIPS eligible clinicians must choose either sufficient activities to reach 40 points. High weighted activities are worth 20 points, whereas medium weighted activities are worth 10 points each.
      • Fewer activities would result in partial credit for the category
    • MIPS eligible clinicians in small groups (≤ 15 clinicians), in rural areas or geographic Health Professional Shortage Areas (HPSAs), or non-patient-facing would only need to reach 20 points to achieve full credit under the category
  • Full category credit for those MIPS eligible clinicians in a certified patient-centered medical home
  • MIPS eligible clinicians or groups must perform an activity for at least 90 days during the performance period
  • MIPS eligible clinicians or groups will designate a yes/no response for activities performed for the IA category

Promoting Interoperability (PI)

  • Promoting Interoperability (PI) makes up 25% of the MIPS Composite Performance Score (CPS)
  • Submission mechanisms include: qualified registry, QCDR, EHR, Attestation, and Part B Claims
  • Scoring for the PI category will be comprised of a score for participation and reporting, which is the “base score” (up to 50 points) and a score for performance, which is the “performance score”.
    • For 2018, MIPS ECs would be able to use CEHRT certified to either the 2014 or 2015 edition certification criteria
    • PI has a performance period of 90 days
    • Can report as individuals or as a group
    • To earn points for the base score, MIPS eligible clinicians or groups must report the numerator and denominator for measures that are based on measures adopted by the MU Stage 3

Cost (formerly Value-based Payment Modified, VM) 

  • Cost makes up 10% of the MIPS Composite Performance Score (CPS)
  • The measures used for the Cost category will be calculated based on administrative claims so there will be no reporting requirements by eligible clinicians or groups.
  • The following measures will be used to assess performance on the Resource Use category:
    • Total per capital cost for all attributed beneficiaries
    • Medicare Spending Per Beneficiary (MSPB) measure

MIPS Composite Performance Score (CPS) 

  • The MIPS CPS will be compared to the MIPS performance threshold to determine the adjustment percentage the MIPS eligible clinician or group will receive
  • A CPS below the performance threshold will yield a negative payment adjustment down to – 5%
  • A CPS at or above the performance threshold will receive an upward payment adjustment of 0 to 5% for the 2018 performance period.  CMS has made $500 million available for exceptional performers for each of the first 5 years of the program.

Advanced Alternative Payment Model (Advanced APM)

Qualifying Participants (QPs) in Advanced APMs like the Medicare Shared Savings Program (MSSP) ACO will not be considered MIPS eligible clinicians and therefore will not be subject to any MIPS payment adjustment. QPs will be rewarded with a 5% lump sum bonus for their participation in an Advanced APM.