CMS Issues Final Rule for Medicare Quality Reporting in 2018
Abstract
Many psychiatrists will still be exempt from reporting if they do not meet the low-volume threshold for reporting.
Physicians who report quality performance measures next year under the Centers for Medicare and Medicaid Services’ (CMS) Medicare Quality Payment Program can receive up to a 5 percent incentive increase in payments in 2020 and an additional 10 percent “exceptional performance” bonus, according to the final rule issued last month by CMS for the 2018 Merit-Based Incentive Payment System (MIPS).
That’s good news. But not all physicians are required to report under MIPS, and for those who are, they are faced with a confusing array of terms, acronyms, and requirements. Following in question and answer format is some information that may be helpful:
Q. What is MIPS?
A. MIPS is part of the new Quality Payment Program devised by Congress as part of the Medicare Access and CHIP Reauthorization Act of 2015 to move toward “value-based payment”—
reimbursement of physicians on the basis of quality and cost, as opposed to volume of services provided.
MIPS affects, but is separate from, the annual Medicare Physician Fee Schedule issued by CMS, which establishes the base rate for Medicare reimbursement and new policies affecting various kinds of services (see story below). MIPS is a system in which participating physicians and other clinicians can receive incentive payments over and above the base rate for meeting certain quality standards (or be penalized for failing to do so).
Importantly, not all physicians who treat Medicare patients are required to report. As many as 60 percent of participating physicians will be exempt for various reasons; for instance, many psychiatrists will be exempt from MIPS unless they meet or exceed the “low-volume threshold” in terms of the number of Medicare patients they treat or Part B payments they receive. For 2018, that threshold was raised to 200 Part B patients or $90,000 Part B allowable charges per year (from 100 patients or $30,000 for 2017). The 600,000 clinicians who are still subject to MIPS reporting and adjustments include about 11,500 psychiatrists.
Q. What kinds of data does MIPS require physicians to report?
A. MIPS requires physicians to report data in three categories representing different kinds of value indicators. Those areas are Quality, Improvement Activities, and Advancing Care Information. Additionally, CMS will also calculate the cost of services provided by reporting physicians.
Together, those elements—Quality, Improvement Activities, and Advancing Care Information, along with Costs as calculated by CMS—comprise a “composite score” that determines a physician’s incentive payment. Bonus points can be added to the composite score under various scenarios.
Q. What is the Quality category?
A. The MIPS Quality category accounts for 50 percent of the MIPS composite score for 2018. Generally, to earn points in this category requires reporting at least six Quality measures, including one outcome measure (if available). Those reporting fewer measures may avoid penalties if no other measures are available that are relevant to their practice and/or patients. Improvement in the Quality category can earn up to 10 additional percentage points.
Q. What is the Advancing Care Information category?
A. The MIPS Advancing Care Information category refers to the use of electronic health records and accounts for 25 percent of the MIPS composite score. Bonus points are given for using the 2015 (versus 2014) version of certified electronic health record technology (CEHRT) and reporting to public health agency or clinical data registries. Hospital-based clinicians can apply for a hardship exception from this category.
Q. What is the Improvement Activities category?
A. MIPS Improvement Activities refers to a variety of activities related to continuous lifelong learning and clinical improvement and account for 15 percent of the MIPS composite score. There are 112 activities from which to choose in 2018. Some continuing medical education activities may qualify.
Q. How much does the Cost category, as calculated by CMS, contribute to the MIPS composite score?
A. Cost is 10 percent of the MIPS composite score. Improvement in the Cost category can earn up to 10 additional percentage points.
Q. What is the easiest way to do MIPS reporting?
A. The easiest way to do MIPS reporting is to join APA’s national mental health registry, PsychPRO, which CMS has approved as a qualified clinical data registry. PsychPRO will provide tools and reports to help members maximize reporting through enhanced data collection and access to more relevant quality measures. APA members can sign up for free by going to the portal on the APA website. Once connected, PsychPRO does your MIPS reporting for you. Nonmembers can participate free this year but will incur a charge starting in 2018.
Q. What is the length of time for which one needs to report?
A. The “performance period”—or the amount of time on which a physician must report—is 90 days for Advancing Care Information and Improvement Activities and 12 months for the Quality and Cost categories.
Q. What’s new this year?
A. On the basis of 2018 performance, in 2020 clinicians can conceivably receive incentive payments over and above the base rate of as much as 5 percent. Clinicians with a composite score of 70 percent or higher will get an extra “exceptional performance” bonus of up to 10 percent. Psychiatrists and other clinicians can earn up to 5 bonus points on their composite score for treating complex patients with multiple conditions or patients dually eligible for Medicare and Medicaid.
In areas impacted by hurricanes or other disasters, individual clinicians will avoid penalties for 2017 and can apply for a hardship exception for 2018. These exemptions are not available to groups.
Individual clinicians and small practices (up to 10 clinicians) that exceed the low-volume threshold can apply by December 31 to report as a “virtual group” for 2018. A virtual group consists of solo or small-group-practice physicians who band together to report with other solo practitioners or small-group-practice physicians that form a larger group to report MIPS data together; one benefit of doing so is that a virtual group can share information and resources, including possibly hiring someone to help with the reporting.
Small practices (up to 15 clinicians) can also apply for a hardship exception from the MIPS Advancing Care Information category, which would increase the weight of their score in the Quality category to 75 percent. They can also receive some points for partial reporting of MIPS Quality measures, can report fewer Improvement Activities and still get full credit, and can earn 5 bonus points on their final MIPS composite score. ■
The final rule is posted here. APA’s comments on the proposed rule are available here. APA’s Payment Reform Toolkit is located here. A CMS fact sheet about year two of the Quality Payment Program is posted here. APA members may also consult with APA experts by sending an email to [email protected] or calling (800) 343-4671. To learn about participating in MIPS reporting through the APA qualified clinical data registry (QCDR), PsychPRO, click here, sign up on the Sign-up Portal, or send an email to [email protected].
