MIPS evaluates physicians on how they score in four areas compared to their peers.
The Merit-Based Incentive Payment System (MIPS) is an enhanced Medicare fee-for-service payment system. It combines CMS’ Meaningful Use of Electronic Health Records (MU), the Physician Quality Reporting System (PQRS) and the Value-Based Payment Modifier (VBPM), and adds a fourth new performance category for Clinical Practice Improvement Activities (CPIA).
All physicians must report for MIPS, even if they are participating in an advanced Alternative Payment Model (APM). If you're part of an APM, CMS will use your reported data to determine whether you qualify for the 5% APM bonus for 2017.
Physicians can report as part of a group or as individuals and will receive scores for each performance category to determine their MIPS composite performance score. Starting in 2018, small and solo practices will be able to report as part of "virtual groups" to help them hold their own in the comparison against larger practices. Your composite score will be compared to your peers’ scores, and you’ll receive bonuses or penalties based on where you fall in this comparison.
Scoring will be based on four weighted categories:
Quality – 50% (based on PQRS). Clinicians choose six measures to report on from a range of options that accommodate differences among specialties and practices. Replaces the physician quality reporting system (PQRS).
Resource Use –10% (based on VBPM). This category's score will be based on Medicare claims, so there will be no reporting requirements for clinicians.
Advancing Care Information– 25% (based on EHR MU Incentive Program). Choose from a menu of measures to report to. Unlike the EHR MU Incentive Program, this category won't use all-or-nothing scoring.
Clinical Practice Improvement Activities–15% (new category). Choose from among 90 clinical practice improvement activities to attest to, such as care coordination, beneficiary engagement, and patient safety.
2017: Flexible reporting paths
While MACRA begins Jan. 1, 2017, CMS is offering physicians flexibility in how quickly they participate in the first year of the program. Physicians can choose from four different paths depending on their level of readiness:
- Option 1: Test the program by submitting some data to CMS anytime in 2017. If you choose this option, you'll avoid all penalties.
- Option 2: Partial year reporting. Submit full data for a reduced number of days after Jan. 1, 2017. In this option, you'll avoid all penalties and you may qualify for a small incentive payment based on your performance.
- Option 3: Full-year reporting. Submit full data for the full calendar year starting on Jan. 1, 2017. In this option, you'll avoid all penalties and may qualify for a modest incentive payment based on your performance.
- Option 4: Participate in an advanced APM. For 2017, if you participate in an advanced APM, you will avoid penalties and will not need to submit MIPS data. If you receive enough of your Medicare payments or see enough of your Medicare patients through the advanced APM, you'll qualify for a 5% incentive bonus.
If one of these three scenarios applies to you, you won't be subject to MIPS:
- It's your first year participating in Medicare Part B.
- Your Medicare billing charges are $10,000 or less and you care for 100 or fewer Medicare patients per year.
- You're a qualifying participant in an advanced Alternative Payment Model (APM).
Each year, CMS will define a performance threshold based on the scores of all participating physicians and groups. If your composite performance score is above the threshold, you'll get a bonus; if it's below the threshold, you'll get a penalty. If you don't report at all, you'll get the lowest possible score. Penalties and bonuses will be capped at amounts that initially increase in the first years of the program.
- 2019: Will depend on how you reported in 2017's flexible reporting paths (above)
- 2020: Up to a 5% penalty; up to a 5% bonus, based on your 2018 performance
- 2021: Up to a 7% penalty; up to a 7% bonus, based on your 2019 performance
- 2022 and onward: Up to a 9% penalty; up to a 9% bonus, based on your 2020 (and on) performance
CMS will also set a threshold for exceptional performance, which will allow some high-performing physicians to earn an extra bonus on top of the MIPS performance bonus.