Physicians have until the end of March to submit performance data for 2017 participation in the Quality Payment Program's (QPP) Merit-Based Incentive Payment System (MIPS), but it is important to begin working on 2018 as soon as possible. A full year of quality data will be required for 2018, which will represent 50% of the total MIPS score.
Among the changes for 2018, the four components of MIPS will result in 100 points, of which Quality Reporting is worth 50%, Advancing Care Information (ACI) 25%, Improvement Activities 15%, and Cost 10%. If, however, the ACI category is not possible due to hardship, such as no reliable internet or no access to a certified electronic health record (EHR), the 25% from the ACI transfers to the Quality category.
To remain neutral in 2018, a physician or group must score 15 points across all categories. For any given quality measure, with some exceptions, the individual or group must report on at least 60% of all patients across all payers (although if the individual or group is reporting using claims, then it must be 60% of only Medicare Part B). Quality reporting must be for a full year, while ACI and Improvement Activities only need to be based on 90 days.
Practices can still use 2014 or 2015 certified EHR technology (CEHRT), but using 2015 CEHRT will earn 10 bonus points. For groups, only one MIPS-eligible clinician in the tax identification number (TIN) has to do an Improvement Activity to get credit. Patient-centered medical homes (PCMHs) or patient-centered specialty practices (PCSPs) earn automatic full credit for Improvement Activities. At least 50% of sites in a TIN must be PCMHs or PCSPs to get credit.
The Cost category will count for 10% of the total composite MIPS score in 2018, based on Medicare Spending per Beneficiary (MSPB) (which is based on Part A and B costs from three days prior through 30 days after an inpatient hospitalization) and total per capita (for beneficiaries attributed to the practice). Practices need not do anything for this category; CMS will calculate it based on claims.
In addition, other ways to earn bonus points include the following:
- Clinicians and groups can earn up to five bonus points for complex patients. Patient complexity will be based on a combination of Hierarchical Condition Categories (HCCs) and the number of dual-eligibles treated.
- Individuals or groups have to report six measures, including at least one outcome measure. Clinicians and groups can earn extra points by reporting additional outcome measures or high-priority measures. Individuals or groups with a composite score of 70 points or higher will be eligible for an “exceptional performer” bonus.
- In ACI, up to five bonus points can be earned for using a Qualified Clinical Data Registry (such as Genesis) or extra public health or clinical data registries.
- Using CEHRT to complete one Improvement Activity earns 10 bonus ACI points.
- If an individual or group Quality or Cost score improves from the previous year, bonus points can be earned that way.
Small practices (<15 eligible clinicians) have other opportunities to earn bonuses:
- Small practices automatically earn five bonus points in their final score by submitting data for at least one performance category.
- Improvement Activities earn double points, so small practices can complete one high-weighted or two medium-weighted activities.
- Three points are automatically given for quality measures that don't have a benchmark or don't meet the data completeness requirements.
- Small practices can submit for a hardship exception for the ACI category and transfer the weight to Quality.
- Free help is available for clinicians in small, rural, and underserved areas.
More detailed information about 2018 QPP changes is online.