By now, you know the eligibility requirements, know you are an “eligible clinician”, and know you have a certified EHR (2014 edition or later). All you have to do now is to commit to participating in MACRA’s MIPS program on some level in 2017.
Qualifacts subject matter experts, Mary Givens and Rachel Clemens, share six (6) tips to help get you started. Taking action may be easier than you think.
TIP 1: Commit to Participate!
The Centers for Medicare and Medicaid Services (CMS) have called 2017 a transition year. They are making it very easy for eligible clinicians to participate by creating what they call “Pick your Pace”. Pick your Pace essentially means you get to choose the level of participation that is right for you:
- Minimal level (test level) – by submitting some data, just enough to avoid the payment penalties
- Partial level (less than a full calendar year) – by submitting data not only to avoid the penalties but also to possibly earn bonus payments
- Full level (a full calendar year) – by submitting data not only to avoid the penalties but also to possibly earn bonus payments.
Our recommendation: Participate at the Full level. By being proactive today, you maximize your opportunity to earn positive payment adjustments in 2018.
Our MACRA MIPs Fact Sheet illustrates the eligibility requirements and offers 6 tips to help you start participating. Getting started may be easier than you think.
TIP 2: Attest as a Group or an Individual?
Eligible clinicians have the option of attesting and being rated as either a Group or as an Individual. Individuals are defined as having an individual National Provider Identification (NPI) and Tax Identification Number (TIN). A Group is defined as many NPIs that bill under one TIN.
To determine which option is best for your agency, you will need to conduct some analysis of your agency’s performance based on the quality of care. The question to be answered is: “Is the total (i.e., the performance of the group) greater than the sum of its parts (i.e., the performance of the individuals)?” If overall, your agency would fare better attesting as a group on quality outcome measures, then the Group option is right for you. Otherwise, choose the Individual option.
Our recommendation: Once you determine your attestation option, the methods differ. Take the time to conduct the analysis. This is an important strategic business decision that could have cost, revenue and scheduling implications.
TIP 3: Select Quality Measures that Best Showcase Your Practice
There are 271 Quality Measures available for the Quality Category of MIPS. With a wide variety of quality measures from which to choose, you must attest to six (6) total measures, one (1) of which must be an outcome measure. In choosing your measures, select those that best showcase the quality of services you provide. You also have an additional option to attest to speciality measure groups. There are thirty distinct specialty measure groups including one for mental/behavioral health.
When committing to the measures you will collect and report on, keep in mind you can earn:
- Two (2) bonus points for each additional outcome or patient experience measure that you report
- One (1) bonus point for each additional high priority measure that you report.
This is good news! Quality Measures are an excellent category where you can earn bonus points. Why? Your eligible clinicians are probably already carrying out many of the workflows required to capture the data for the measures.
Our recommendation: Get credit for what you are probably already doing.
TIP 4: Operationalize Your Clinical Improvement Activities (CIA)
The Improvement Activities Category is a new initiative included in MACRA MIPS that was not part of the previous Physician Quality Reporting System (PQRS) quality program. This new performance category will reward your eligible clinicians for services they deliver that focus on these key areas:
- Care coordination
- Engagement of the patient (or their representative)
- Patient safety.
When you look through the list of 93 Improvement Activities, you should look for activities that reflect some of the processes you already have in place. You should also identify activities you want to add to your practices that will bring true value to your agency and your consumers.
Most participating eligible clinicians will need to attest that they have completed up to four (4) of the improvement activities for a minimum of 90 days. As an example, below are four (4) improvement activities that support integrated care and care coordination practices:
- Care coordination agreements that promote improvements in patient tracking across settings
- Care transition documentation practice improvements
- Care transition standard operational improvements
- Implementation of use of specialist reports back to referring clinician or group to close the referral loop.
Our recommendation: Select activities that both reflect your current practices and will expand your clinical improvement program. And if you do not have a formalized improvement program, no problem. You now have an ideal opportunity to start organizing your current efforts into a formal clinical improvement program. Win-win!
TIP 5: Go Beyond the Advancing Care Information (ACI) Category Base Score
If you are a provider who previously participated in the EHR Incentive Program for Meaningful Use (MU), you are already practicing and likely have been attesting to more than twice the number of measures now required for ACI. This is good news! You should definitely plan to attest to more than just the base levels for the ACI category.
The eligible clinician must attest to only four (4) or five (5) measures depending on which version (2014 or 2015) of CEHRT (Certified Electronic Health Record Technology) you are using to meet the base level requirements of ACI. Here is more good news for eligible clinicians:
- Earn extra credit for reporting up to nine (9) measures for 90 consecutive days (performance score).
- Earn bonus points for reporting public health and clinical data registry measures (bonus score).
- Earn bonus points for using a CEHRT to complete the Improvement Activities referenced in Tip 4 above (bonus score).
Our recommendation: At a minimum, participate at the performance level and earn extra points by attesting to more measures than what is required for base level participation.
TIP 6: Know Your Costs Now
Now is the time to get your Medicare Part B costs under control. Starting in 2020, your payments will be positively or negatively adjusted in part based on the way you have managed costs in 2018. The eligible clinician needs to know what it costs to deliver care to his/her Medicare Part B recipients now and take action to control those costs.
The Cost Category assesses costs in two distinct ways: Medicare spending per beneficiary and total Medicare spending per capita. Although neither penalties or bonuses will be assessed in the Cost Category of MIPS in 2017, the eligible clinicians’ cost performance will be measured and feedback provided.
This category replaces the previous Physician Value-Based Modifier program or what had been reported in the Quality and Resource Use Report (QRUR). CMS is calculating the Cost Category in 2017 to prepare the eligible clinician for 2018 when cost will be used as part of calculating their neutral, positive or negative payment adjustment.
Our recommendation: Do not wait – start now. Analyze your cost per individual and per capita making any needed changes in 2017 in order to affect greater value for each Medicare dollar spent in delivering care to your consumer.
Want to learn more?
View our on-demand webinar: Navigating MACRA MIPS: 6 Tips to Succeed with MIPS, where Qualifacts subject matter experts Mary Givens, Compliance Product Manager, and Rachel Clemens, System Consultant Manager, elaborate on each of the tips above to provide you practical ways to be successful in the MACRA Quality Payment Program, MIPS track.
Preparing for MIPS now to receive its benefits in the future may be easier than you think!
- Centers for Medicare and Medicaid Services, www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-MIPS-and-APMs.html
- Centers for Medicare and Medicaid Services, Quality Payment Program, qpp.cms.gov/measures/quality
- Centers for Medicare and Medicaid Services, Quality Payment Program, qpp.cms.gov/measures/ia