Now that most groups are wrapping up their 2017 Merit-based Incentive Payment System reporting, they now can turn their attention to … learning the requirements for 2018 MIPS reporting. Fortunately, there are very few significant changes from the inaugural MIPS year, especially if you’re a non-patient facing specialist like most pathologists.
Below is a rundown of the major changes you should take note of as you begin your quality reporting for the new year.
1) Significant increase of the low-volume exemption thresholds
• CMS is raising the low-volume MIPS exemption thresholds to $90,000 in annual Medicare payments or services to 200 or fewer Medicare beneficiaries, a significant increase from the $30,000 or 100 patient thresholds for 2017. Falling below either one of these thresholds as an individual clinician will exempt you from participation, which means those who were barely over the 2017 mark will most likely be exempt from the program next year.
Keep in mind, however, that the same thresholds are applied at the group level if your group elects to report collectively.
2) Penalties rising, category weights stay the same
• Penalties and bonuses for the 2018 MIPS reporting year will rise to +/-5 percent for the corresponding 2020 payment year.
• Quality: Still comprises 85 percent for non-patient facing (NPF) groups and 50 percent for patient-facing physicians.
• Improvement Activities: Still the remaining 15 percent for NPF groups.
• Advancing Care Information: 25 percent for regular participants.
• Cost: 10 percent for regular participants. (No reporting requirement regardless).
3) No requirements for the “Cost” category for non-patient facing clinicians
• While participants had originally been told to anticipate the introduction of a “Cost” category based on the old value modifier in 2018, CMS is now proposing to again give no weight to the fourth MIPS category next year for non-patient facing clinicians. That being said, patient-facing groups will see Cost comprise 10 percent of their total MIPS score for 2018.
CMS is tracking Cost progress in 2018 based on Medicare Spending per Beneficiary and total per capita cost measures, meaning groups do not have to do any additional reporting to be scored in this category.
4) Quality reporting data completeness rising to 60 percent
• Clinicians will now be required to submit quality data on at least 60 percent of their eligible patients if they’re seeking to achieve a strong quality score, as opposed to the traditional 50 percent requirement under PQRS and the initial MIPS performance period. Individuals reporting via claims are still only required to report on Medicare patients, while groups utilizing registries must report on data from all payers.
5) Slight threshold increase for penalty avoidance
• Clinicians who were happy with the extremely low bar set by CMS this year to avoid a Medicare penalty in the 2019 payment year should find relief in learning they won’t be asked to do much more next year to avoid a 2020 penalty. While the 2017 performance threshold of 3 (the total MIPS score required to receive a neutral adjustment) was able to be achieved by essentially submitting any quality data or completing at least one improvement activity, the 2018 threshold will be raised to just 15 points.
• AVOIDING A PENALTY IN 2018: 15 points
o Complete your improvement activity attestation: 15 points
o SMALL PRACTICE OF 15 OR FEWER: Submit incomplete data for at least four quality measures throughout the year, receiving three points for each measure. This practice would also receive five bonus points for its size: 17 points
o KEEP IN MIND: While the bar for penalty avoidance is still low, submitting just one claim per clinician is no longer enough to avoid the penalty!
6) Automatic bonuses for small practices
• Given the reporting hurdles faced by small practices (15 clinicians or fewer), CMS is proposing to award an automatic five points to these clinicians scores next year.
7) New measures through CAP’s registry
• Given its status as a Qualified Clinical Data Registry, CMS has approved nine new pathology measures for CAP to offer in 2018. KEEP IN MIND, these are only available if a group utilizes CAP’s registry. These cannot be reported on via claims or through other registries.
• CAP1: TURNAROUND TIME (TAT) – STANDARD BIOPSIES
• CAP2: CANCER PROTOCOL ELEMENTS FOR ENDOMETRIUM COMPLETED
• CAP3: CANCER PROTOCOL ELEMENTS FOR KIDNEY RESECTION COMPLETED
• CAP4: CANCER PROTOCOL ELEMENTS FOR INTRAHEPATIC BILE DUCT COMPLETED
• CAP5: CANCER PROTOCOL ELEMENTS FOR LIVER RESECTION COMPLETED
• CAP6: CANCER PROTOCOL ELEMENTS FOR PANCREAS RESECTION COMPLETED
• CAP7: HELICOBACTER PYLORI DOCUMENTATION RATE
• CAP8: TURNAROUND TIME (TAT) – LACTATE
• CAP9: TURNAROUND TIME (TAT) – TROPONIN
8) Option for small and solo practices to form “virtual group”
• Individuals and groups of 10 or fewer clinicians now have the options to participate together as a virtual group, regardless of specialty or location. While this may be a route to a bonus for some specialists who’d otherwise not have enough applicable quality measures to achieve one, there are currently too many questions surrounding this option to enthusiastically recommend it, especially considering how low the penalty avoidance threshold is again.