Earlier this month, the Department of Health & Human Service (HHS) issued the final rule for the Merit-based Incentive Payment System under the Quality Payment Program.
The final rule allows for numerous paths for eligible clinicians to participate and avoid negative payment adjustments during the first reporting period, which begins on Jan. 1, 2017, and will affect 2019 Medicare payments.
For the first reporting period, HHS is taking an iterative approach, allowing eligible clinicians to smoothly transition into the program. This transition period allows clinicians to “pick their pace,” offering them the opportunity to ease into the new payment system based upon their level of readiness.
In order to avoid negative payment adjustments in 2019, eligible clinicians must choose one of three paths. Should they not choose any of those three paths, they will receive a negative four-percent Medicare payment adjustment.
The first option is to enroll in a test period. During test periods, eligible clinicians must submit some form of data for a period of time during the calendar year reporting period.
HHS states that the minimum amount of data is at least one performance measure.
“Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment,” the agency said in an executive summary of the final rule.
Eligible clinicians who participate in a test period will not receive a positive payment adjustment, but they will avoid a negative payment adjustment, making their payment adjustment neutral.
The second option is partial-year reporting. Clinicians participating in a partial year reporting period must submit 90 days’ worth of data to Medicare. These clinicians must also report more than the minimum amount of data to Medicare.
“Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment,” the rule states.
Eligible clinicians reporting for a partial year may be eligible for a modest positive payment adjustment while also avoiding the negative payment penalty.
The third path for clinicians to avoid a negative payment adjustment is to report more than the minimum data for more than a 90-day reporting period. These eligible clinicians may receive a higher positive payment adjustment.
“Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment,” the final rule explains. “In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.”
To recap, eligible clinicians choosing the second or third paths will need to submit more than the minimum amount of data. For the second path, this means reporting more than one required measure under each of the three categories. For the third path, this means reporting to all of the measures under each of the categories.
MIPS has three categories for the first reporting period – quality measures, improvement activities, and advancing care information. The cost category does not go into effect until after the 2017 reporting period.
For the quality category, participants must report up to six quality measures and one outcomes measure.
For improvement activities, participants must attest that they have completed at least four improvement activities for a 90-day period.
For advancing care information, participants must fulfill five required measures. These measures are security risk analysis, e-prescribing, providing patient data access, sending summaries of care, and requesting and accepting summaries of care. Clinicians may also earn bonus credit by reporting public health and clinical data registry data or using certified EHR technology.
Image credit: The Department of Health & Human Services