MIPS, of course, is the Merit-based Incentive Payment System, which will unify Medicare’s four largest existing quality reporting programs into a single entity. We’ve been looking at the proposed rule since April, and there was a lot of concern among providers about the time frame and the reporting requirements.

The final rule came out about a week ago, and the Centers for Medicare & Medicaid Services (CMS) has responded to feedback from providers and advocacy groups with some pretty aggressive changes.

First of all, the time frame was the single biggest concern, and under the proposed rule, you’d be under the gun for performance reporting starting on Jan. 1, 2017. The way it works is this: 2017 performance data is used to adjust 2019 Medicare payments, 2018 performance for 2020 payments, and so on. 

Now in the final rule, you’ve got several options to report in 2017, including the option to report data for a 90-day period instead of year-round. That can be any 90 consecutive days in 2017, so the latest start date is Oct. 1, 2017.

MIPS adjustments for the first year range from minus 4 percent to plus 4 percent. So the bare minimum you need to do in 2017 to avoid a negative adjustment is reporting one quality measure under the quality performance category (which replaces PQRS), or one clinical improvement activity (such as beneficiary engagement or care coordination). So 90 days of reporting for either of those elements will guarantee that you avoid a negative adjustment in 2019, but it also means you won’t be eligible for a positive adjustment. 

The next step up is to report two or more measures for either of those categories, or all of the quality measures under the advancing care information category (which replaces meaningful use) for 90 days. This gives you a shot at a potential positive update, depending on how many other providers are going above and beyond the minimum.

A few other significant changes in the final rule, and these are all concessions CMS is making to make MIPS easier, include the advancing care information quality (MU) going from 11 measures required to five. Also, the cost performance category (which replaces the value-based modifier) won’t be counted in 2017. It had accounted for 10 percent of the MIPS score in the proposed rule, but won’t be used in the final rule. 

Finally, CMS is making it easier for very small practices to be exempt entirely from MIPS reporting by raising its low-volume threshold. Under the proposed rule, this threshold allowed providers with $10,000 or less in Part B billed charges to be exempt. Now the bar is $30,000 or less in Part B billed charges, which will allow many more small or solo-practitioner practices to be exempt. 

To give you an example of the ballpark for $30,000 or less in charges, for an internist billing E/M codes, you’d need about 5-10 Medicare patients per week for a year, with some variation for E/M code level.

This threshold is also considered reached if a provider sees 100 or fewer Part B beneficiaries over a certain period, though this was applied in both the proposed and final rule. CMS will automatically determine which providers are exempt under this threshold by analyzing claims data from two distinct 12-month periods, one from before MIPS takes effect and one during 2017, the first MIPS reporting year.

About the Author

Grant Huang is the director of content at DoctorsManagement. He produces educational products that help ensure that auditors, coders, practice managers and administrators optimize their organization’s revenue cycle while improving their compliance in today’s complex regulatory environment. Grant is an AAPC-certified coder and medical auditor, and holds a Bachelor of Science degree in Political Science and Government from the University of Maryland, Baltimore County. 

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