FAQ

Merit-Based Incentive Program (MIPS) (12)

What is a TIN?

TIN stands for Tax Identification Number.

What is an NPI?

NPI stands for National Provider Identifier.

How do I submit for MIPS?

As a qualified registry by CMS,  ReportingMD can report for you.

Who needs to report for the Merit-based Incentive Payment System (MIPS)?

MIPS Years 1 & 2 (2017, 2018) – Physicians (MD/DO and DMD/DDS), PAs, NPs, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists (CRNAs).

MIPS Year 3 and beyond (2019) – Physical or Occupational Therapists (PT/OT), speech-language Pathologists, Audiologists, Nurse Midwives, Clinical Psychologists, Dieticians/Nutritional professionals.

Go to the CMS QPP website to check the MIPS eligibility by NPI.   https://qpp.cms.gov/learn/eligibility

 

What are other criteria establishing MIPS eligibility and/or MIPS ineligibility?

  • First year of Medicare Part B participation: If an eligible clinician is newly enrolled in Medicare in 2017, they are not considered a MIPS eligible clinician. In 2018, they would be considered a MIPS eligible clinician and would need to report to avoid downward payment adjustments.
  • Low patient/volume threshold: If an eligible clinician bills Medicare for ≤ $30,000 OR Provides care for ≤ 100 Medicare Part B patients in a year then they are not considered a MIPS eligible clinician.
  • Certain participants in Advanced APMs: Certain participants in Advanced Alternative Payment Models (APMs) if considered a Qualifying Participant (QP) are not considered MIPS eligible clinicians. Partial QPs will have the option to elect whether or not to report under MIPS, which determines whether or not they will be subject to the MIPS adjustments.

What happens if a MIPS eligible clinician does not report anything under MIPS for 2017?

If a MIPS eligible clinician does NOT report anything for the MIPS program for the 2017 reporting year, they will be subject to a 4% downward payment adjustment in 2019.

This number increases in 2018 and beyond:

  • 2018: +/- 5% payment adjustment
  • 2019: +/- 7% payment adjustment
  • 2020: +/- 9% payment adjustment

What reporting options are available for the 2017 MIPS transition year?

Per the final rule, 2017 has been classified as a “transition year” under MIPS. For the 2017 transition year, CMS is offering “Pick Your Pace,” which allows MIPS eligible clinicians the ability to transition to MIPS reporting at their desired pace. MIPS eligible clinicians can choose to report a level to just avoid a penalty or can report at a level to receive an incentive.

What is the MIPS performance category weighting for 2017?

MIPS Quality – worth 60%

MIPS Improvement Activities – worth 15%

MIPS Advancing Care Information – worth 25%

If a MIPS EC (eligible clinician) or group practice is interested in some incentive eligibility through MIPS Quality reporting, what are the criteria for reporting?

To be eligible for any incentive through reporting on the MIPS Quality category, a provider or group practice would report 6 individual measures and at least 1 of the 6 measures must be an Outcome measure. If no Outcome measure is applicable then a High Priority measure would need to be reported in lieu of an Outcome measure. The measures would need to be reported for a period of 90 days or more. If the provider or practice chooses to report just a 90-day window, ReportingMD encourages to report on 100% of each measure’s all payer eligible events.

Group Reporting vs. Individual Reporting?

ReportingMD can help you decide which method of reporting works better for your practice.

Individual reporting happens when a provider or group of providers reports for pay-for-performance programs at an individual level. The providers would report all eligible events that they billed for according to the measure specifications. For example, for measures that are once per patient per reporting period, if a patient saw 5 different clinicians at a practice, each of the 5 clinicians would need to report on that patient.

Group reporting occurs when a group of clinicians report at the Tax ID Number (TIN) level. In the case of once per patient per reporting period measures, even if a patient saw 5 difference clinicians at a practice, that patient would only be reported once when reporting at the group aggregated level.

How do I read the CMS Individual Measure Specifications Manual?

Use the following outline to determine how to read the specifications.

Denominator Data

Eligible Instances: The number of instances (patients, visits, episodes, etc.) that meet all eligibility criteria for a specific measure of interest, as explained in the 2017 Measure Specifications Manual for Individual Measures.

Example of a measure denominator description, from the 2017 MIPS Registry Measure Spec Manual:

  • Measure #12 (NQF 0086): Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation

Numerator Data

The numerator must detail the clinical quality action expected that satisfies the condition(s) and is the focus of the measurement for each patient, procedure or event established by the denominator. The numerator options are “MET” and “NOT MET” for all measures with some measures having the additional option of “EXCLUDED”. Under “Numerator” in the 2017 Measure Spec Manual, the options will be separated by “OR”.

Performance Met: The number of eligible instances that meet the “MET” criteria.

Performance Exclusion: The number of eligible instances that meet the “EXCLUDED” criteria. *This does not apply to every measure.

Performance Not Met: The number of eligible instances that meet the “NOT MET” criteria.

What is an inverted measure?

Inverted Measures:

  • Desired Performance Rate: 0.00%
  • A lower calculated performance rate for an inverse measure indicates better clinical care or control. The “Performance Not Met” numerator option for this measure is the representation of the better clinical quality or control. Reporting that numerator option will produce a performance rate that trends closer to 0%, as quality increases. For inverse measures, a rate of 100% means all of the denominator eligible patients did not receive the appropriate care or were not in proper control.

Non-inverted Measures:

  • Desired Performance Rate: 100.00%
  • A higher calculated performance rate for a non-inverted measure indicates better clinical care or control. The “Performance Met” numerator option for this measure is the representation of the better clinical quality or control. Reporting that numerator option will produce a performance rate that trends closer to 100%, as quality increases. For non-inverted measures, a rate of 0.00% means all of the denominator eligible patients did not receive the appropriate care or were not in proper control.