For the past several years, Corrona has offered a mechanism for sites participating in the Rheumatoid Arthritis Registry to fulfill their Medicare Physician Quality Reporting System (PQRS) reporting obligations.
Beginning this year, CMS has launched the Merit-Based Incentive Payment System (MIPS). MIPS combines PQRS with other CMS quality initiatives into one program. Provider performance in 2017 will be measured using the new MIPS scoring model and will impact providers’ 2019 reimbursements or penalties.
The new program no longer allows satisfactory reporting using only a 20-patient sample, which is how Corrona has reported for its providers in the past. Eligible providers must not report on at least 50% of their denominator-eligible patients for each measure selected. This change has restricted Corrona’s ability to adequately support the program for its participating providers and ensure that the reporting sample size is met for those who use data exclusively from the Corrona RA Registry. Due to these changes in the program, Corrona will be unable to offer MIPS reporting for the 2017 performance year.
To support Corrona sites in this transition, the web content below provides a foundation to build upon for successful MIPS reporting in 2017 and beyond.
What is MIPS?
MIPS is the Merit-based Incentive Payment System. It is one of two tracks within the Quality Payment Program (QPP), the program by which the Centers for Medicare and Medicaid Services (CMS) determines and distributes value-based payments to Medicare providers.
MIPS went into effect on January 1, 2017. It combines and replaces the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VBPM), and Meaningful Use (MU).
The goal of MIPS is to tie payment to performance, and specifically to reward providers who deliver high-quality care and penalize those who deliver low-quality care.
Conceptually, MIPS is simple: providers must submit clinical data to CMS once annually, and these data are used to generate a Composite Performance Score. This score determines the amount of any financial incentive or penalty.
MIPS performance affects Medicare payments two years into the future. For example, a provider's 2017 MIPS score will impact his or her payments in 2019.
Who is Evaluated Under MIPS?
A physician, physician assistant, nurse practitioner, certified registered nurse anesthetist (CRNA), or other clinical nurse specialist will be evaluated under MIPS if she or he:
- Provides care to over 100 Medicare Part B-enrolled beneficiaries in the calendar year, and
- Bills Medicare Part B for over $30,000 in the calendar year.
There are a few exceptions:
- A provider who enrolls in Medicare for the first time is exempt from MIPS evaluation for that year only.
- A provider who participates in an advanced Alternative Payment Model (APM) may qualify for the APM track of the Quality Payment Program if (1) a minimum percentage of Part B payments are made through the advanced APM or (2) if a minimum percentage of patients are empaneled in the advanced APM. However, there are presently very few advanced APMs that qualify for this track.
In 2017, nearly all rheumatology providers will be subject to MIPS evaluation.
How Does MIPS Work?
For a given calendar year, each provider will receive a MIPS Composite Performance Score (CPS) ranging from 0 (worst) to 100 (best), where the score is determined from the data submitted for the corresponding year. In general, performance data for a given calendar year must be submitted to CMS by March 31 of the following year.
There are four distinct performance categories that contribute to the Composite Performance Score. They are called Quality, Cost, Advancing Care Information (ACI), and Clinical Performance Improvement Activities (CPIA). The four performance categories and the requirements that must be met for each are described in detail below.
The relative weighting of the four performance categories changes over time. For example, in 2017 the Quality performance category accounts for 60% of the Composite Performance Score, Advancing Care Information accounts for 25%, Clinical Performance Improvement Activities accounts for 15%, and Cost accounts for 0% (zero percent). The weightings change in subsequent years, as shown below, with Quality becoming relatively less important and Cost becoming relatively more important.
Relative weights of the four MIPS performance categories for performance years 2017, 2018, and 2019 and beyond.
What Do I Need to Do Now?
The Bare Minimum
For 2017, CMS has made it difficult to “fail” MIPS. The performance threshold for the 2017 program year is only 3 points, meaning a provider must earn 3 or more CPS points to avoid a downward (negative) payment adjustment. In 2017 there are two minimally viable MIPS strategies:
- A provider can earn 3 or more CPS points by successfully reporting just one quality measure. Even if the provider failed to meet the data completeness criteria for the measure, he or she would still receive 3 Quality category points for that measure, which translates (in 2017) to 3 CPS points.
- Alternatively, a provider can earn 3 or more CPS points by completing just one improvement activity. Successful attestation of one medium-weight activity earns a minimum of 10 CPIA category points, which translates to 6.25 CPS points.
By doing the bare minimum, a provider will avoid the 4% penalty for non-compliance with MIPS reporting. However, before deciding to pursue a minimally viable strategy, providers should consider that their MIPS scores will be made public, that this approach will not be feasible beyond the 2017 program year, and that much better performance may be possible with little incremental effort.
Rheumatology providers should be cautious about selecting Quality measures based upon what is reportable through their EHR. Most EHRs offer only certain measures, typically those easiest to support algorithmically, and these may not be relevant to rheumatology. Instead, providers should take a strategic approach to measure selection by considering their own clinical practice and process of care. The rheumatology Specialty Measure Set is an excellent starting point, but rheumatologists involved in pain management, osteoporosis care, etc. may find measures outside this set that will be better suited to them.
In general, providers should decide what Quality measures they want to pursue before deciding how they will report them. This is because not all measures are available through all reporting options.
Cost does not factor into a provider’s CPS for 2017, but that does not mean it should be ignored. In fact, rheumatology providers should be particularly attuned to cost given their high utilization of expensive biologics. Beginning in 2018, cost becomes an important determinant of a provider’s CPS.
There are many strategies to reduce drug cost, such as clinically appropriate tapering or selection of less expensive treatment options. But rheumatology providers can also shift the attribution of drug costs by ensuring that their patients, especially those on biologics, receive timely annual visits with a primary care provider.
Minimal effort is needed for providers to successfully complete the ACI base measures, which generally require performance of the measure for only one patient during the attestation period.
Providers can minimize the burden of performing improvement activities by identifying approved activities in which they are already engaged. For example, Consultation of the Prescription Drug Monitoring Program is a high-weight performance activity that many rheumatologists already do.
What’s the Bottom Line?
MIPS is the most recent step in the evolution of Medicare from fee-for-service to value-based payment. It is a complex program. However, with forethought and attention, providers can minimize the burden of complying while simultaneously improving care delivery and potentially realizing a financial incentive.
For 2017, CMS has set a low bar for complying with MIPS. The minimum Composite Performance Score needed to avoid a downward adjustment to the Medicare Part B fee schedule in 2019 is three (3) out of 100. There are minimally viable strategies to achieve this threshold. However, providers may be able to achieve a much higher score with little incremental effort.
Ideally, providers should aim for a CPS of 70, which is the additional performance threshold. Providers achieving or exceeding this mark will share in a $500 million incentive pool above and beyond the cost-neutral component of the program.
Finally, although MIPS is specifically a CMS program, it is fundamentally about using data to evidence value in the health care marketplace. Similar programs are emerging in the private sector, and data will ultimately be needed to support value-based reimbursement across all payers. Therefore, providers are advised to use MIPS as motivation to prepare for a data-driven future.