In my last blog
, I described the history of the Center for Medicare and Medicaid Services' (CMS) EHR Incentive Program and Merit-Based Incentive Payment System (MIPS). Here, we'll explore what the new mandate will mean in terms of requirements and options for participation.
In essence, MIPS, also commonly now referred to as the Quality Payment Program (QPP), aims to progressively pay providers based on quality and effectiveness ("value") as opposed to volume of services. Based on performance in four categories, three of which replace current incentive programs, Medicare providers will receive a score from 0-100, which is then compared to a national performance threshold that determines whether the physician receives a bonus or penalty. The penalty/bonus begins in 2019, based on data that is reported beginning in 2017, and increases from ±4% in 2019 to ±9% in 2022.
The four QPP categories are:
- Quality: The quality category replaces the PQRS program. Six quality measures must be reported, including one outcome measure, or if an outcome measure is not available, another high priority measure must be selected. The specific measures are defined on the QPP website.
- Advancing Care Information (ACI): ACI replaces the EHR Incentive program for eligible professionals. A provider uses certified EHR technology (CEHRT) to report on specific measures as published on the QPP website. Activities must be performed for a period of at least 90 continuous days.
- Improvement Activities: This new category requires providers to report on various clinical process improvement activities, as published on the QPP website.
- Cost: This category replaces the Value-Based Payer Modifier program, and will be calculated directly by CMS based on claims data. The cost factor requires no reporting and kicks in gradually with 0% in 2019, 10% in 2020, and 30% in 2021.
The QPP (remember, synonymous with MIPS) can be a complicated program to follow, and, unlike the EHR Incentive Program, there is no complete exemption for imaging specialists. You will need to participate! However, CMS has listened to providers in two areas that can simplify
- QPP does provide for reporting adjustments based on specialist practices. The first change is that there is a new category of physicians called "non-patient facing." This category is defined as:
- an individual MIPS-eligible clinician who bills 100 or fewer patient-facing encounters during determination period, or
- a group, provided that more than 75% of the National Provider Identifiers (NPIs) billing under the group's Tax Identification Number (TIN) meet the definition of a non-patient facing individual MIPS-eligible clinician.
It is likely that many imaging specialists will be categorized as non-patient facing. These providers have lower requirements for the Improvement Activity category and are exempt from reporting on the Advancing Care Information category if they so choose. The composite score is reweighted accordingly. In addition, some specialists can qualify as hospital-based providers. This also allows for adjusted reporting requirements.
- The reporting requirements for 2017 have been scaled back so that providers have time to build a plan for QPP participation and ensure they have the right resources in place.
There are four reporting options available:
—test the QPP to avoid a 4% 2019 penalty: Clinicians submitting just one measure from the quality, improvement performance or advancing care information performance categories after January 1, 2017 will avoid a negative payment adjustment. An eligible clinician or group does not need to meet data completeness standards, e.g. 50% reporting, nor meet a minimum case threshold, i.e. 20 cases, in order to avoid the negative adjustment.
—partial reporting to theoretically qualify for a small bonus: Submit data for part of the year (minimum of a continuous 90-day period) to theoretically still qualify for a small positive payment adjustment.
—participate for the full year. Submit data for the full year of 2017 to theoretically qualify for a positive payment adjustment.
—participate in an Advanced Alternative Payment Model. You may receive a 5% positive payment adjustment in 2019 if enough Medicare patients or payments are performed in an Advanced APM. Although the rules are still in flux, an Advanced APM requires: (1) use of CEHRT; (2) payment based on quality measures comparable to those in the quality performance category under MIPS; and (3) meeting a financial risk standard.
So, what can imaging specialists do today?
Each physician and practice will need to create a plan for QPP reporting. The first priority is understanding which 2017 options are viable. For example, Option 4 is likely not available to most providers, since advanced APMs are not yet that prevalent. Secondly, providers should clearly define potential exemptions available to individual providers and the practice and then map out a plan for who and how to report on each applicable category. Part of the "how" involves technology, and this is where Merge can play an important role. Our solutions, in conjunction with partner products, can help imaging specialists participate in QPP. We want to work with you to make sure we've built simple reporting solutions you can use — even from your mobile phone. Contact us today
, and let's partner on this effort to ensure imaging specialists are successful under this new mandate.