- Providers participating in the Merit-based Incentive Payment System (MIPS) are voicing concern over continued delays regarding notifications meant to offer guidance on how eligible clinicians can comply with the program’s requirements for 2017.
The Medical Group Management Association (MGMA) recently submitted a letter to newly confirmed CMS Administrator Seema Verma, MPH, requesting the immediate implementation of provider notification provisions necessary for satisfying 2017 MIPS requirements.
“Transitioning to MIPS is a challenge involving upgrades to electronic health record software, reengineering clinical workflows to meet data capture and reporting requirements, contracting with data registries, and training clinical and administrative staff,” wrote Anders M. Gilberg, Senior Vice President of Government. “Without basic information about eligibility, physicians and medical groups are significantly disadvantaged from positioning themselves for success in the program.”
MGMA is taking issue with a delay in provider notifications regarding low-volume threshold exemptions, status as hospital-based or non-patient facing clinicians, and lists of registry vendors for the 2017 MIPS performance period.
MGMA called attention to a CMS pledge to deliver these notifications in regulatory provisions by December of 2016. The three-month delay is causing distress among healthcare providers looking for as much guidance as possible during the first performance year of the Quality Payment Program.
Confusion surrounding MIPS remains an issue for providers since the program’s inception. CMS has made attempts to explicitly address various aspects of the program including through a presentation covering the four performance categories and scoring metrics at HIMSS17.
EHR technology is one of the four mechanisms for reporting MIPS data on quality, advancing care information, and improvement activities. No data submission is necessary to fulfill the cost performance category during the first performance year.
"You may report using different mechanisms between categories, but only one method of reporting can be used within each category,” said AAFP in an online MIPS overview.
Apart from certified EHR technology, providers may report data using Medicare Part B claims-based reporting, qualified registries, qualified clinical data registries, or the CMS web interface for groups of 25 or more eligible clinicians.
Apprehension over the first year transitioning to MIPS reporting is compounded by uncertainty regarding exemptions, status, and registry vendors. Because many providers do not know which reporting mechanism is best suited to their practices, their reporting processes are on hold until further notice.
”By CMS’ own estimate, 32.5 percent of Medicare providers are exempt from MIPS in 2017 under the low volume threshold and, as such, at least 32.5 percent of Medicare providers are currently unsure whether they qualify for participation in MIPS,” MGMA stated. “Further hindering group practices’ success in MIPS is the absence of a final list of approved 2017 qualified registries and qualified clinical data registries. Group practices planning to utilize these reporting mechanisms must either delay engagement or partner with vendors without a guarantee they meet CMS’ qualifications.”
According to the association, pending status notifications bars clinicians from properly fulfilling program requirements because they are unsure which rules apply to them.
“To succeed in MIPS, clinicians and group practices require certainty as to their eligibility, as well as the eligibility of their vendor partners. We urge CMS to expeditiously release these long overdue MIPS eligibility notices and approved vendor lists,” MGMA concluded.
Surmounting challenges posed by the first year of MIPS will allow regulators and providers alike to make the necessary adjustments to ensure following years under the program run smoothly after a rocky initial transition.