Preparing your practice for MIPS Year Two

For 2018, the Centers for Medicare and Medicaid Services (CMS) raised the bar for physicians and practices participating in the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program (QPP), which was established under the Medicare Access and CHIP Reauthorization Act (MACRA). It will now be more difficult to earn the increasing number of points necessary to avoid a payment penalty, which has been raised to a maximum of 5 percent for year two and will impact your 2020 payments.

Luckily, meeting the requirements doesn’t have to be difficult. Use one of two simple strategies to avoid penalties and maximize incentives by taking a proactive approach to meeting the requirements.

Do you need to participate?

First, determine your eligibility. CMS expanded MIPS exemptions for 2018, so providers who were MIPS eligible in 2017 may be exempt this year. Confirm your exemption status by entering your NPI number in the participation look up tool on qpp.cms.gov. Eligible clinicians, read on to learn about two strategies to meet your MIPS requirements for calendar year (CY) 2018.

Strategy #1: Meet the 2018 MIPS requirements using only the quality performance category.

Reporting at least 60 percent of your data for six quality measures in 2018 is enough to avoid a payment penalty in 2020. Identify the submission method you will use and the six quality measures you will report in 2018. Gastroenterologists participating in MIPS as individuals may submit quality data via a qualified clinical data registry (QCDR), qualified registry, electronic health record (EHR) system or claims.

Groups may report quality data via QCDR, qualified registry, EHR or via a web interface implemented by CMS. The web interface is available only to groups of 25 or more.

If submitting quality data via claims, make sure the appropriate Quality Data Code (QDC) is being added to claims related to each measure. QDCs are Current Procedure Terminology (CPT) II codes and G-codes used for submission of quality data for MIPS. When these codes are included on your claims form, it identifies your selected quality measures for CMS.

Strategy #2: Meet the 2018 MIPS requirements using only the improvement activities category

Performing improvement activities for 90 days in CY 2018 is also enough to avoid a payment penalty in 2020. Performance activities are categorized as either medium- or high-weighted. MIPS requirements for 2018 may be met (and a penalty avoided) by performing either four medium-weighted activities, two high-weighted activities, or one high-weighted and two medium-weighted activities.

Three medium-weighted improvement activities are specific to gastroenterology or were developed by gastroenterologists, including the AGA Clinical Guidelines Mobile App, Manage My Surgery, and SonarMD™. High-weighted improvement activities for 2018 include Centers for Disease Control and Prevention (CDC) training on CDC Guidelines for Prescribing Opioids for Chronic Pain and CDC training on antibiotic stewardship.

AGA will continue to provide additional information and resources to help gastroenterologists and their practices thrive under the Quality Payment Program. The AGA QPP Resource Center offers advice based on your practice situation. Visit www.gastro.org/QPP for more information.

Caution:

  • Not all measures are available under each submission method. Make sure to select measures available under your chosen method.
  • At least one reported measure must be identified as a high priority or outcome measure.
  • Select measures for which you or your practice have 20 or more cases to ensure that all selected measures will be scored.

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