MIPS Demystified: Things You May Not Know About MIPS

June 2017 – Vol. 36, No. 5

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) will affect nearly every physician in the United States, requiring them to collect and report data on quality of care, practice activities, and technology. With all of the changes taking place, and despite the final rule being released in October 2016, some misconceptions have arisen. To avoid further confusion and to better assist AAO-HNS members, here are answers to  questions membership has raised over the last few weeks.

Q: Does MIPS eliminate the Physician Quality Reporting System (PQRS), Meaningful Use (MU), and Value-Based Modifier (VBM) programs?

A: While the MIPS program sunsets PQRS, MU, and VBM programs for 2017, physicians will still receive payment adjustments under all three programs in 2017 and 2018, based on 2015 and 2016 reporting, respectively. Additionally, MIPS consolidates and “rebrands” these three programs into four categories: quality, advancing care information (ACI), improvement activities (IA), and cost. Quality replaces PQRS and includes many of the same required metrics; ACI replaces MU, also borrowing measures from its legacy program; IA is a new component addressing care coordination and patient engagement and safety; and cost replaces the VBM program (in 2018).

Q: I participate in an Accountable Care Organization (ACO), do I need to be concerned about MIPS?

A: Yes. As long as you meet the minimum reporting threshold under MIPS or do not participate under and meet the Advanced APM thresholds for a CMS designated Advanced Alternative Payment Model (APM), you will be scored under MIPS in 2017. However, many ACOs count as a “MIPS APM,” and participants in MIPS APMs receive special MIPS scoring under the “APM scoring standard.” Under the APM scoring standard, groups will not need to report MIPS quality measures, and CMS will assign scores to MIPS eligible clinicians (ECs) in the improvement activity performance category.

Q: Do I need a Certified Electronic Health Record (EHR) to report under MIPS?

A: In 2017, you do not need to use an EHR to report under MIPS to avoid a penalty. Under the test pace, ECs can report on one quality measure or one improvement activity via claims, a registry, such as Reg-ent℠ (see page 25), web interface, attestation, and other means. In order to potentially qualify for a bonus payment, use of EHR is required for the ACI category. However, in 2018, ECs will need to report the Advancing Care Information performance category, which requires the use of a Certified EHR.

Q: I am currently using 2014 Certified EHR for MIPS, do I need a 2015 Certified EHR?

A: For 2017 reporting, ECs and groups can use 2014 Certified EHR technology (CEHRT) to report under MIPS. However, CMS has indicated in future years, 2015 CEHRT will be required to successfully report under MIPS. Physicians face administrative challenges when transitioning and implementing new EHR systems. We recommend preparing earlier rather than later to learn a new system that will ensure you meet the MIPS requirements.

Q: If the Affordable Care Act (ACA or Obamacare) gets repealed, will MIPS end?

A: No. The Affordable Care Act and the MIPS program were passed under different legislation. The MIPS and Advanced APM programs were passed as part of MACRA, which replaced the flawed Sustainable Growth Rate (SGR) for Medicare payment. Even if the ACA is repealed, the AAO-HNS expects the MIPS and Advanced APM programs to continue.

See MIPS for ENTs