September 05, 2017
Happy Labor Day! It's a day where you can take things easy and try to let the worries of the world pass you by! On the flipside, it also marks the 28-day countdown to October 2nd. For most clinicians, October 2, 2017, is the last day to start a 90-day reporting period under the Merit-Based Incentive Payment System (MIPS). If you have no clue what MIPS is, or if you still do not have a plan, you are not alone and it's not too late! There's an easy, cheap, quick way to avoid a penalty! That kind of sounds like a late-night infomercial, but seriously, do not give up and get a 4% haircut on your part B book of business. If you aren't playing on the MIPS offense, play strong on the defense!
Are you eligible? Before you read ahead, double-check to see if you even need to participate in MIPS.
Every TIN should have received a MIPS status letter from the Centers for Medicare and Medicaid Services (CMS) earlier this year regarding the MIPS eligibility of each provider.
If the letter got lost in the mail, the QPP website has a spot to enter in your national provider identifier (NPI) to determine if you should participate in MIPS in 2017.
If you are an eligible clinician who practices at more than one NPI/TIN combination, you need to make sure you understand your MIPS status for each combination. Just because you are exempt from one combo, doesn't make you exempt from the other! Also, if one NPI/TIN combo is reporting as a group (and you are individually exempt), you unfortunately are back on the bus and need to report MIPS!
The only caveat to this is if you are a qualifying participant under the advanced alternative payment model (AAPM) path of MACRA. Then you are exempt from MIPS altogether.
Also, don't forget about those mid-level providers! Your nurse practitioners, physician assistants, or anyone else deemed an "eligible clinician" will need to understand their MIPS eligibility status.
Do one of these two things-ASAP! We are only a few short months away from the end of the first-ever MIPS performance period. Some of you (avid blog readers) are probably 9 months into a rock-solid MIPS strategy. Others, however, may find themselves still trying to figure out what MIPS is and what to do! Afterall, of the 750 practices surveyed by the MGMA, 70% of respondents find the MIPS scoring system to be very or extremely complex, and about the same (69%) are very or extremely concerned the unclear program guidance will impact their ability to successfully participate in MIPS. Due to this, over 50% of respondents did not know what reporting path they will take.
If you are clueless on what to do, don't fret! It's not too late for you! There are a couple things you can do right away to avoid a 4% penalty in 2019!
1. Start a 90-day reporting period by October 2, 2017
For those who still want a fighting chance at some bonus dollars, this would be the path for you. Eligible clinicians seeking a bonus of up to 4% have until October 2 to start reporting on more than 1 quality measure, more than 1 improvement activity, or 4 Advancing Care Information measures for at least 90 days.
If you don't know where to start, there are a few great resources out there.
The QPP website: There are plenty of webinars, videos, and PDFs to keep you busy for years!
Because MIPS is new, CMS gave an "easy button" option for those who need more time to plan.
By submitting something, you will not be subject to a payment penalty in 2019, but you won't be raking in any bonus dollars either. To submit the minimum amount, report one of the following:
Option 1: Report 1 Quality Measure (only one patient is required, performance score doesn't matter) Option 2: Report 1 Improvement Activity, either high or medium weight (depending on practice size) Option 3: Report 4 or 5 base score Advancing Care Information measures (depending on whether you have a 2014 or 2015 certified EHR, respectively)
Of the three options above, the first two would probably be the path of least resistance because they do not require a certified EHR and tracking multiple measures.
If option 1 is your choice, keep reading ahead!
"One patient, one measure, no penalty"
The AMA has recently launched an education campaign entitled, "One patient, one measure, no penalty." The premise is to avoid a 4% penalty by doing the easiest, quickest, cheapest thing possible-report one quality measure for one patient via claims.
The AMA urges those without a MIPS plan to report quality via the claims path as a safety net to avoid a penalty.
In a nutshell, you need to choose a patient, choose a quality measure that is applicable to both your scope of practice and the patient, and then report the data via your CMS 1500 form.
The most time spent here would be finding the claims-based quality measure and code needed to report on the 1500 form. The rest should be pretty simple.
Fill out a 1500 billing form as you normally would in boxes 1 through 20.
Enter the patient's diagnoses and procedure codes in box 21.
Visit to qpp.cms.gov/measures/quality find the Quality Measure search tool.
Filter by "claims" and select a measure. Make sure to note its three-digit quality ID number.
Go to qpp.cms.gov/resources/education to find a ZIP file named "Quality Measure Specifications." Download this file and unzip it on your computer.
In the file you unzipped, open the "QPP_quality_measure_specifications" folder.
Use the quality ID code (from step 4) to find the claims document for the measure you're reporting.
In this document, find the Quality Data Code (QDC) for that measure.
Go back to your 1500 billing form and enter the QDC code in box 24D.
In box 24F, list a line-item charge of one cent ($0.01) for the QDC codes you entered in box 24D. Otherwise your claim could be rejected!
Finish entering the information requested in boxes 25 through 33.
Submit your 1500 billing form to your Medicare Administrative Contractor.
Voila! You just avoided a penalty!
The AMA also posted a video walking you through the steps above along with an example claim form.
"Nothing worth having comes easy"
This will probably be the only time MACRA reporting will be this easy. And as most of us know, doing the easy thing may not always be the best thing to do. Next year's performance period is right around the corner, and although CMS has not finalized the 2018 MACRA rule, we do know that it isn't going away. You will need to be more strategic as the years go on-otherwise you will be handing over your hard-earned money and planting it in someone else's pocket.
Diana Strubler, Policy and Standards Senior Manager, joined Acumen in 2010 as an EHR trainer then quickly moved into the role of certification and health IT standards subject matter expert. She has successfully led Acumen through three certifications while also guiding our company and customers through the world of Meaningful Use, ICD-10 and PQRS.