How does the Quality Payment Program work? (Part 2 of 2)
Merit-based Incentive Payment System (MIPS) rewards
exceptional performers by giving them a positive adjustment in their payment
from Medicare. If the practice is a low performer then they will receive a
lower payment, or a penalty. For exceptional performance a practice can receive
additional payments from 4% in 2019 to 9% in 2022 and forward. For a poor
performing practice they can be penalized anywhere from 4% in 2019 to 9% in
2022 and forward. Each practice can choose how much they wish to participate.
They can go from a “Test Pace” where they submit some data after January 1,
2017 and receive a neutral adjustment to a small pay adjustment. They can
choose a “Partial Year” option where they can report for a 90 day period after
January 1, 2017 and before October 2, 2017 and they can receive a small positive
payment adjustment. Keep in mind that whenever a practice chooses to start,
they will need to send in their performance data by March 31, 2018. Lastly,
they can choose a “Full Year” option where they can fully participate starting
January 1, 2017 and receive a modest positive payment adjustment. The best way
for a practice to realize the positive impact from the Full Participation
option is to submit data on all the MIPS performance categories.
Now to avoid any downward payment adjustment a practice can
submit a minimum amount of data in 2017 to Medicare that can be one quality
measure or one improvement activity, and they can avoid any downward payment
adjustment. A key factor for positive adjustments is that these are based on
the performance data on the performance information submitted, and not the
total amount of information submitted or the length of time that the practice
is reporting on during the year.
The Bonus Payments and Reporting Periods are as follows. To
receive the MIPS payment adjustment it will be based on the data submitted. The
best way to get the most out of the program is to participate for a full year.
This type of participation gives the practice the most measures to pick from.
CMS is encouraging clinicians to pick the option that best fits their practice
needs and abilities. The categories are Quality, Cost, Improvement Activities,
and Advancing Care Information. The default weights for each category are Quality
(60%), Cost (0%), Improvement Activities (15%), and Advancing Information
(25%). These default weights can be adjusted in certain circumstances. Quality
has approximately 300 different quality measures and the practice needs only to
select about 6. For Advancing Care Information there are 2 measure sets for EHR.
The nice thing here is that if a clinician faces a significant hardship and are
unable to report on the Advancing Care Information measures, they can apply to
have their performance category reduced to a weight of 0%. If this category is
not applicable to the clinician, then the 25% weight will be added to a
different category.
