Even Practitioners Exempt from MIPS Should Consider Reporting – Why?

I’m going to review the latest info on the 2019 MIPS payment adjustments that will be based on your 2017 MIPS scores.  You only needed 3 points to keep from losing any of your Medicare part B payments- which was successfully reporting ONE quality measure or one clinical practice improvement activity (IA). So, as an aside, if you are going to experience a negative payment adjustment (penalty) in 2019 because you didn’t report in 2017, for goodness sake don’t lose money again in 2018. There is no reason to lose money under MIPS.

More clinicians are exempt from MIPS reporting in 2018, but you may want to report anyway. Why? Because if you become subject to MIPS the following year, you can get extra points for having improved in a category where your performance was not so great.

Eligibility for MIPS

The Social Security Act defined something called an “eligible professional,” (e.g. physicians, nurse practitioners, physician assistants, etc.). CMS decided to call those “eligible clinicians,” (ECs) as identified by a unique tax ID number (TIN) and National Provider Identifier (NPI) combination. However, whether an EC is subject to MIPS is determined by factors that include how many Medicare patients they see. Thus, not all ECs are “MIPS eligible clinicians.” If you were not a MIPS eligible clinician in 2017, then you won’t experience a “payment adjustment” in 2019, which means that CMS will not take any of your Medicare Part B payments away.

The best way to figure out if you are subject to MIPS in 2018 is to look yourself up using your NPI. See below for a screen capture of what that looks like.

The best way to figure out if you are subject to MIPS in 2018 is to look yourself up using your NPI.

Performance Thresholds

The “performance threshold” is the number against which your final score is compared in order to determine whether you get a bonus, a penalty, or no change to your Medicare Part B payments. The performance threshold is the minimum number of points are earned before you can get any bonus money. The performance threshold for the 2019 MIPS payment year (meaning, for the data you reported in 2017) was 3 points—this means a 2017 MIPS final score of at least 3 is required to avoid a negative payment adjustment in CY 2019. This means, for example, that a clinician who successfully reported one quality measure avoided a negative payment adjustment because that was enough to earn 3 points. The 2019 exceptional performance threshold was 70 points. If you get a score of 70 or higher, you got the “exceptional performance bonus”.

MIPS Payment Adjustment Factors

Each MIPS eligible clinician receives a MIPS payment adjustment factor (and an accompanying payment adjustment) based on their MIPS final score. Payment adjustment factors are assigned on a linear sliding scale and are defined by law. In 2019, it is 4%.  The higher a MIPS-eligible clinician’s final score, the larger the positive payment adjustment. Well, the sliding scale thing is mostly true, with the exception being that any clinician with a score of 0.75 or less will have the maximum negative adjustment of -4%, so you really fall, rather than slide down the lowest score. There’s some more fine print about the bonus payments. This is a zero sum game. The money to pay the top performers comes from the money taken away from the bottom performers. That’s why as more doctors successfully lobby to get exempted, it becomes less likely that anyone will get a significant bonus because there won’t be any money to hand out.

MIPS payment adjustment factors are increased or decreased (“scaled”) by an amount called a “scaling factor.” The scaling factor depends on the distribution of final scores across all MIPS eligible clinicians. For the 2019 MIPS payment year, the scaling factor must be greater than 0 and cannot exceed 3. If the scaling factor is less than 1.0, then a physician will get less than the percentage they expect. If the scaling factor is >1.0, then they will get some amount more than the applicable percentage. If 3 is the maximum in 2019, then the highest bonus you can make is (max%) x 3. Clinicians with a score >70 get an additional adjustment of 0.5% (on top of the adjustment they were going to get). In case you haven’t noticed, that is a lot less than they indicated the exceptional performance bonus might be (which was originally billed at a possible 10% additional). The exceptional performance bonus is not part of the budget neutral money (Congress set aside money for these bonus payments), but the aggregate payments can’t be more than $500 million in 2019.

Get Help and Information

You can reach the Quality Payment Program at 1-866-288-8292 (TTY 1-877-715- 6222), Monday through Friday, 8:00 AM-8:00 PM ET or by e-mail at: QPP@cms.hhs.gov.

Last time I called, I waited more than half an hour on hold but when I did finally get a live person, they were incredibly kind and helpful and I got all my questions answered.

Drumroll . . . .

I am going to share my 2017 MIPS results in an upcoming post.