First things first, let’s get a few acronyms straight. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) created the Quality Payment Program, which addresses two tracks: Advanced Alternative Payment Models (AAPMs) and the focus of this post, the Merit-based Incentive Payment System (MIPS). When you hear MACRA, MIPS or Quality Payment Program, know that they are all connected and often used interchangeably.
When talking to providers, we’re surprised by how many false theories are floating around, so we thought it would be beneficial to debunk a few of those myths.
Myth #1: I was eligible for the Physician Quality Reporting System (PQRS), so I must be eligible for Quality Payment Program.
Eligibility requirements for PQRS are different from Quality Payment Program. Participation for 2017 MIPS requires you to have received $30,000 or more in part B receivables AND had at least 100 Medicare patient-facing encounters over a 12-month review period (10/1/15 – 9/30/16 for 2017 eligibility). You must meet both requirements. If you billed Medicare for $50,000, but only had 80 Medicare patient-facing encounters, you are exempt from MIPS. In addition, you must also be a Physician (which includes doctors of medicine, doctors of osteopathy, doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors), Nurse Practitioner, Physician Assistant, Clinical Nurse Specialist or Certified Registered Nurse Anesthetist to participate in MIPS. Providers such as therapists, social workers and dieticians received a pass until 2019.
Myth #2: I have to register for MIPS.
You may be confused by the fact that you do have to register as a group to report via a web interface or Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey, however, this date has already passed. Those are the only two submission method options that require registration. For the rest, you do not have to tell CMS how you plan to participate. Just keep the following dates in mind:
- October 2, 2017: The last day to start a 90-day consecutive reporting period
- March 31, 2018: The last day to report or attest to CMS
Myth #3: I have to submit a full year of data to CMS.
Although submitting a full year’s data is possibly the best way to maximize your MIPS payment adjustment, it’s not the only way to participate. There are two other options: (1) Test by submitting only some data, such as one quality measure or one improvement activity or (2) Submit data for a consecutive 90-day period. The test option will allow you to avoid the 4% negative adjustment in 2019, while the 90-day option avoids the penalty AND has the potential to earn a small positive adjustment in 2019. Pick the pace that’s most realistic for your practice and then aim to improve next year.
Myth #4: I don’t have an Electronic Health Record (EHR), so I can’t participate.
While using an EHR is one way to submit data, you can also participate using a registry, Qualified Clinical Data Registry, or through claims. Without an EHR, you can choose to simply test with a claims-based quality measure. There are over 70 measures that offer claims data submission. However, if you are aiming for 90 days or a full year, you will need an EHR to meet the Advancing Care Information measures.
Myth #5: Participating is extremely time-consuming.
Many providers assume they are going to have to change their entire workflow in order to comply with MIPS, but often, you are already doing many of the quality measures on your own. Most EHRs utilize a dashboard that can help you decide what measures you do best and report those. Plus, like we mentioned above, there is also the test option which requires submitting only ONE quality measure for ONE Medicare Part B patient. An example would be Documentation of Current Medication in the Medical Record. You’re probably already doing that!
Myth #6: I have to hire someone to help me figure this out.
Lucky for you, this one’s not true either. CMS has specialized programs offering technical assistance across the country, whether you are a large practice with 16+ providers or a small practice with 15 or fewer providers. Technical assistance does not cost you anything and is available immediately by emailing TechAssist@Qsource.org or calling toll-free Monday through Friday at 1-844-205-5540 from 8:30 a.m. to 5 p.m. CT.
Julia Alton Tubbs is a recent graduate of Auburn University’s Health Services Administration program and currently works for AQAF, a partner of Qsource, as a Quality Improvement Advisor. Previously, she interned for GlaxoSmithKline’s Vaccines Department in the Czech Republic. Her current focus as a part of the atom Alliance is to work with physicians to ensure regulatory compliance is attained and patient health disparities are reduced.
Daniel Day is a Hospital and Physician Office Quality Improvement Advisor for AQAF, a partner of Qsource. He has been in the healthcare industry for over six years, working for several EHR companies as a project manager and consultant. He is currently working with physicians, assisting them with compliance needs. He also works with other advisors to reduce health disparities in Alabama.