Merit-based Incentive Payment System (MIPS) reporting can earn your office thousands of dollars in incentive payments, or cost it thousands in penalties. Luckily, Healthcare Innovation Solutions (HCIS), the for-profit unit of the New Jersey Innovation Institute’s (NJII) Healthcare Division, has the expertise to guide practices on successful MIPS reporting.
HCIS MIPS Advisors Patrick Cordes and Madelin Hernandez recently expounded on tips and best practices to employ when gathering and submitting MIPS reporting for the 2019 calendar year. The Centers for Medicare and Medicaid Services’ (CMS) is only accepting submissions for 2019 through March 31st, so practices taking part in MIPS should act fast.
MIPS Tips for 2019 Reporting
- Save your final reports and other documents in a MIPS folder. To protect your practice in the event of a CMS audit, save a copy of all final reports for Quality and Promoting Interoperability, plus your 2019 Security Risk Analysis Assessment documents for improvement activities that you attest to. Finally, save copies of any material showing you enrolled in a clinical public health reporting registry for 2019.
- Get your Certified Electronic Health Record Technology (CEHRT) ID before submitting Promoting Interoperability (PI) data. CMS will not score the PI category unless the CEHRT ID is included. Go to the Certified Health IT Product List website to find the ID you need (click the yellow button on the far right side). If you need help finding the number, you can contact your EHR provider directly. HCIS’ MIPS clients can also contact us at (973) 642-4055 or qpp.njii.com for assistance.
- Review Final Clinical Quality Measure reports. You must report data for your practice’s patients and encounters for the entire 2019 calendar year – this means all payers, not just Medicare clients. Also, check reporting rates – a 60% reporting rate is required to exceed minimum points. Practices merely seeking to avoid a penalty must still ensure they earn enough points.
- Ensure you earn the maximum number of points for the Improvement Activity performance category. Small practices need to report on at least one high-weight or two medium-weighted categories to earn full credit. However, large practices need to report on two high-weighted activities, or one high-weighted category and two medium-weight categories, or four medium-weighted categories for full credit.
- Make sure you meet all minimum requirements for Promoting Interoperability, or are taking exclusions. This includes using a reporting period of at least 90 days, completing the Security Risk analysis, and meeting performance standards or exclusions on e-prescribing, supporting electronic referral loops by sending and receiving health information and selecting two separate public health agencies or clinical data registries.
These tips complement earlier guidance from our MIPS team, which addressed topics such as the benefits of using clinical data and public health registries, as well as selecting quality measures wisely to increase the opportunity to earn bonus points.
Our MIPS team holds monthly webinars to educate providers about the program as it evolves. At the beginning of the month, we covered the 2020 MIPS reporting rule changes they had tracked.
MIPS uses positive, negative and neutral payment adjustments to incentivize practices to use value-based care. It was created in 2017 by CMS based on earlier initiatives such as the Medicare EHR Incentive Program for Eligible Clinicians, the Value-Based Payment Modifier, and the Physician Quality Reporting System. MIPS measures performance in four areas – Quality, Improvement Activities, Promoting Interoperability, and Cost. CMS calculates a practice’s MIPS Final Score by adding points from each of these four categories, and determines if a practice should receive a positive, negative, or neutral payment adjustment. The maximum adjustment for the 2019 reporting year is 7% and adjustment payments or penalties will be distributed in 2021.
Who is eligible for MIPS in 2019?
Clinicians and practices have to meet a trio of annual volume thresholds to participate in MIPS. They are: (1) treating at least 200 Medicare Part B patients (2) billing a minimum of $90,000 for Medicare Part B, and (3) covering more than 200 professional services.
- Physician Assistants
- Nurse Practitioners
- Clinical Nurse Specialists
- Certified Registered Nurse Anesthetists
- Clinical Psychologists
- Physical Therapists
- Occupational Therapists
- Speech/Language Pathologists
- Nutrition Professionals
A MIPS-eligible clinician that does not meet the volume thresholds outlined above can choose to opt-in to the program and subject themselves to performance requirements in exchange for payment adjustments.
Practices that want help compiling, organizing and submitting their MIPS data should contact HCIS no later than March 16.
Prices (Per Clinician)
|Submission and Consulting||$898|
To register for submission and/or consulting services go here.
NJII’s Healthcare Division has been a qualified data registry since 2011, and has helped more than 10,000 clinicians across the country. Our experience includes small and large practices, health systems, and a wide variety of billing and EMR/EHR vendors. Practices that use our consulting services score 22% higher, on average, than those that do not.
Learn more by visiting our pricing and services page or get in touch with the HCIS MIPS team at (973) 642-4055. You can also email us at qpp.njii.com.