Insights17 MIPS Proposed Rule
Download as PPTX, PDF0 likes84 views
The proposed MIPS rule enhances flexibility for healthcare practices, aiming to reduce regulatory burdens and allow clinicians to focus on patient care. Exemptions will increase, with 63% of Medicare clinicians exempt in 2018, while several provisions aim to ease participation for small practices, including 90-day reporting periods and options for different participation models. The quality category will account for 60% of the MIPS score in 2018, with scoring mechanisms allowing for multiple submission options to facilitate participation.
Insights17 MIPS Proposed Rule
- 2. Proposed MIPS Rule Restates MIPS is a benefit to practices with greater flexibility for participation.
- 3. Major Aim “We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork.” Seema Verma, CMS Adminstrator
- 4. Exemptions Increased 63% of all Medicare clinicians will be exempt from MIPS in 2018.
- 5. Remember: There will be more money for those who do full MIPS and qualify for exceptional performance bonus.
- 6. Increased Medicare Threshold Projected: New rule will exclude 585,560 clinicians Other exclusions affect 390,000 clinicians Will leave 37% eligible CMS has increased the low-volume threshold exclusion. Individuals or groups < $90,000 in Part B charges Or 200 Part B patients
- 7. Regulatory Burdens Eased Aim: To reduce the regulatory burden on physicians while continuing the transition to value-based reimbursement • The impact of MACRA will be mitigated for many smaller practices, despite the increased complexity of the program. • However, there will be a smaller pool of penalty dollars to fund the incentives for high performers, which could discourage participation across the market by practices of all sizes. Several wins for small practices
- 8. Use of 2015 Certified EHR Optional for MIPS in 2018 CMS also proposed a 90-day reporting period for ACI for both 2018 and 2019. Providers can delay moving to the 2015 Edition until October 2019. NOTE: Providers who do use the 2015 Edition would receive a 10% ACI bonus.
- 9. Still required for certain APM participants in 2018 • Those in the CPC+ program are still required to use 2015 CEHRT in 2018 for a full year, starting 1/1/2018. • No change for participants in the Medicaid MU program, but that might change if CMS aligns the MIPS ACI and MU requirements. Use of 2015 Certified EHR
- 10. Hospital-based Physicians • Can be assessed on quality and cost in the context of the facilities where they work. • Can submit their facility's inpatient value-based score to help calculate an individual score.
- 11. Pick Your Pace Important Revisions • Scoring for the quality category retains the three-point floor imposed in 2017 (out of 10 possible points). • Overall MIPS performance threshold, or benchmark, will increase from three to fifteen (out of a possible 100 points). Will Continue in 2018
- 12. Cost Category in 2018 MIPS clinicians should continue to gather knowledge and develop a strategy for future success in the cost category. 0%of the overall MIPS score in 2018 (30% of the overall MIPS score in 2020.)
- 13. Quality Category in 2018 Quality Category will account for 60%
- 14. Submission Mechanism CMS will allow multiple submission mechanisms within the ACI, Quality, and Improvement Activities categories. One submission mechanism per performance category • EHR • Claims • Registry • etc. Measures and activities can be submitted through multiple submission mechanisms within a performance category. 2017 2018
- 15. Providers can Choose Providers can now participate in MIPS as • Individuals • Groups • Virtual groups* *Virtual Groups Solo practitioners and groups with 10 or fewer eligible clinicians, who join together “virtually” to participate. Providers can elect to participate in a virtual group prior to the start of the 2018 performance period and are not restricted by size or geography.
- 16. Hardship Exception Starting in 2018 – • Practices with 15 or fewer clinicians are offered a “significant hardship” exception to opt out of MIPS ACI. • ACI performance category is reweighted to zero, shifting the ACI scoring weight of 25% to the quality category. • A clinician could apply for the exception if “there are overwhelming barriers that prevent the MIPS-eligible clinician from complying with the requirements” for ACI (details still pending).
- 17. Advanced APMs Regulations would largely remain unchanged in 2018. • Exemption: CPC+ participants with more than 50 clinicians in their parent organization can remain as an Advanced APM in 2018 and beyond. • For the first time, CMS outlined critical details regarding the 2019 implementation of the All-Payer Combination Option.