Reporting and Submission

MACRA – MIPS, APMs

Within MACRA, the Quality Payment Program (QPP) streamlines several pay-for-performance programs in the new 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.

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

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 is the newly structured program that pulls activities and requirements from 3 known pay-for-performance programs and reassembles them into 1 cohesive program made up of 4 categories, which are: Quality, Advancing Care Information (ACI), new 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 60% 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 (New under MIPS)

  • Improvement Activities (IA) makes up 15% of the MIPS Composite Performance Score (CPS)
  • Submission mechanisms include: qualified registry, QCDR, EHR, and Part B Claims
  • MIPS eligible clinicians or groups choose from an inventory of over 90 proposed activities, each of which is categorized as high or medium
    • MIPS eligible clinicians must choose either 3 high (high activities = 20 points each) or 6 medium (medium activities = 10 points each) or a combination of high or medium that results in a score of 60 points in order to achieve the highest potential score for the category
      • 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 perform 2 IAs (either high or medium categorization) in order to receive full credit
  • Full category credit for those MIPS eligible clinicians in a certified patient-centered medical home
  • A minimum of half credit for those MIPS eligible clinicians who participate in any Alternate Payment Model (APM)
  • MIPS eligible clinicians or groups must perform an activity for at least 90 days during the performance period
  • For the 1st year of MIPS (2017), MIPS eligible clinicians or groups will designate a yes/no response for activities performed for the IA category

Advancing Care Information (formerly Meaningful Use, MU) 

  • Advancing Care Information (ACI) 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 ACI 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”. There is also a 1 point bonus for public health reporting beyond the 1 required immunization registry reporting measure.
    • For 2017, the 1st MIPS performance period, MIPS ECs would be able to use CEHRT certified to either the 2014 or 2015 edition certification criteria
    • ACI will have a performance period of from 90 days to 1 full calendar year
    • 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 in 2015 final
      • There is a primary and an alternate methodology to reporting on the Advancing Care Information objectives and measures for the base score

Cost (formerly Value-based Payment Modified, VM) 

  • Cost is not included in the Composite Performance Score for 2017 reporting.
  • 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
    • Several episode-based measures

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 – 4%
  • A CPS at or above the performance threshold will receive an upward payment adjustment of 0 to 4% for the 2017 performance period.  CMS has made $500 million available for exceptional performers in 2017.

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.