It's Easy - Just Follow the Steps
The Merit based Incentive Payment System (MIPS) came into effect on Jan 1st, 2017. Eligible clinicians, who decide to participate in MIPS this year onward, will earn a performance based payment adjustment for their Medicare payments starting in 2019. This payment adjustment will be based on Composite Performance Score (aka MIPS Score) earned by the clinician on the measures reported. MIPS is designed to be a budget-neutral program, but there is $500 million allocated to provide additional incentive to exceptional performers.
MyMipsScore ™ breaks down this complex process of MIPS Score calculation into 10 simple steps. These steps aim at not only to help you understand how MIPS score is calculated, but also to enable you to calculate this score for your practice, monitor it on a regular basis and help you maximize it.
These steps are arranged in the order of information flow. Choices made in one step influence the options and requirements in the subsequent steps.
STEP 0: WHAT ARE MIPS SCORE CATEGORIES?
The MIPS Score, also known as Composite Performance Score (CPS) will be calculated from data provided by practices to CMS under four performance categories. The weights assigned for 2017 performance year are:
- Quality - 60%
- Advancing Care Information (ACI) - 25%
- Improvement Activities (IA) - 15%
- Cost - 0%
Each category has an assigned weight value. The sum of all weights adds up to 100. MIPS score is calculated based on the points under each category AND the weight for that category.
As the cost category will NOT be used to determine the payment adjustments in 2017, it is not included in the 10 steps at this time.
STEP 1: REPORTING AS AN INDIVIDUAL OR GROUP
An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number (TIN). A group is defined as a set of clinicians (identified by their NPIs) sharing a common TIN, irrespective of specialty or practice site.
FOR INDIVIDUAL PROVIDERS
- You will need to report individual data for each of the MIPS categories
- Payment adjustment will be based on individual performance (determined by MIPS Score)
- Data reporting can be done through EHR, Registry or a Qualified Clinical Data Registry
- You also have the option of reporting through Medicare Claims
- You will need to report group-level data for each of the MIPS categories
- The group will get one payment adjustment based on the group’s performance
- Data reporting can be done through EHR, Registry or a Qualified Clinical Data Registry
- Groups of 25 or more have the option to report through CMS Web Interface.
For groups of 16 or more an additional quality measure - 30 Day All-Cause Hospital Readmission Measure might be included in the final MIPS score. However, the group would NOT have to report this; it would be calculated by CMS from the Administrative Claims data pertaining to the group.
STEP 2: SPECIALTY
MIPS requirements are pretty much same for all specialties. However, requirements under the quality category might be affected based on your specialty. Most providers will be required to report 6 quality measures unless you are a groups of 25 or more and decide to use the web interface for reporting. CMS has defined specialty specific quality measure sets to make it convenient to find quality measures most relevant to specialties. You may pick 6 measures from this set or outside this set. More importantly, if your specialty specific measure set has less than 6 measures, you can choose to report only those measures without being penalized.
STEP 3: IMPROVEMENT ACTIVITIES (IA) - SPECIAL CONSIDERATIONS
Let us start with the easiest performance category. Clinical Performance Improvement Activities is a new performance category that rewards clinicians for delivering care that emphasizes care coordination, patient engagement, and patient safety. You may be eligible to receive special considerations for this category if your practice meets certain criteria:
• Your practice is in a rural area or a health professional shortage area (HPSA)
• Your group has 15 or fewer participants
• You are a non-patient-facing clinician
If any of the above situations apply to you, you will be awarded double the points for all the activities to make it easier for you to achieve the max score.
Also, if you choose to participate in the Improvement Activities Study conducted by CMS in 2017 and do so successfully, you will earn 40 points (max score) towards IA category at the completion of the study.
STEP 4: IMPROVEMENT ACTIVITIES SCORING
You have to attest that you completed one or more out of more than 90 available improvement activities. You can earn a max score of 40 Points for this category (which is 15 points in the final MIPS score). Improvement Activities are divided into Medium weight and High weight activities. High weight activities carry twice the weight of medium weight activities, and thus count twice as much towards your final score (marked with H icon).
Certain Improvement Activities are reportable via EHR and can earn you a bonus of 10 points for the ACI category. These activities are marked with an E icon in the MyMipsScore (MM#) app.
STEP 5: ADVANCING CARE INFORMATION (ACI) EXCLUSION
ACI performance category replaces the Meaningful Use Incentive Program. Similar to exclusion for the Meaningful Use program, you may be eligible to claim exclusion from ACI category reporting. If you are eligible for the exclusion, AND you claim it, your ACI Category weight will be assigned to Quality Category.
You can claim the exclusion if:
- You are a Hospital Based MIPS Eligible Clinician, or a MIPS Eligible (NP, PA, CRNA, CNS)
- You are a MIPS Eligible Clinician facing significant hardship defined as:
- Have insufficient internet connectivity
- Extreme and uncontrollable circumstances (e.g. Natural Disasters)
- Lack of control over the availability of certified EHR technology
- Lack of face-to-face patient interaction
- Have insufficient internet connectivity
STEP 6: ACI MEASURE SET SELECTION
An ACI measure set is the group of objectives and measures similar to the Meaningful Use program that you will have to report for MIPS. In 2017, there are two measure set options available for reporting. The option you can use is based on the EHR edition you will be using in 2017.
- Option 1 - Advancing Care Information Objectives and Measures – You need to have a 2015 Edition, or a combination of 2014 and 2015 EHR editions to choose this option.
- Option 2 - 2017 Advancing Care Information Transition Objectives and Measures – If you have a 2014 edition EHR, this will be your only option.
The maximum points (and the contribution to final MIPS score) is the same for both options. Option 1 has some additional measures including registry reporting option. However, two of the measures in Option 2 have been assigned twice the maximum points to balance this out.
STEP 7: ACI SCORING
Although ACI replaces the Meaningful Use program, the scoring system is quite different. Unlike the “meet minimum requirement” approach of Meaningful Use, ACI rewards you for better performance.
The ACI score is divided into three categories:
a. BASE Points (MAX 50)
You are required to report on all the measures categorized as Base Measures to receive any credit for ACI. You can earn full 50 points for answering YES for the yes/no measures, and entering a Numerator and Denominator for the rest. This sub category of ACI does work similar to meaningful use requirements that it is not based on the actual performance.
B. PERFORMANCE Points (MAX 90)
The performance points are determined based on actual performance on the measures in your selected measure set. It is important to note that some of the measures included in the Base Points also count towards the Performance Points.
C. BONUS Points (MAX 15)
There are two types of bonus points available under ACI:
- Registry Bonus (5 points) – Reporting to at least one Public Health or Clinical Data Registry
- Improvement Activity Bonus (10 points) – For using certified EHR to report certain bonus eligible Improvement Activities (See Step 4)
Although the maximum scores for all the ACI score categories add up to 155 points (50 + 90+ 15 = 155), you can only earn a maximum of 100 points for this category. If you earn more than 100 points, you will receive the maximum possible 25 points for the ACI category in your final MIPS score.
STEP 8: QUALITY SUBMISSION METHODS
Quality Category carries the most weight towards your total MIPS score. For 2017, this has been set to 60% unless you apply for ACI exclusion (Step 5). In that case, the ACI category weight of 25% is assigned to Quality category making the Quality category weight 85%.
The quality category scoring under MIPS follows a new decile based benchmarking system. Under this new system, each quality measure is assigned a benchmark. Further, each measure has been assigned a separate benchmark for each submission method applicable. Thus, the score for a measure could be different depending on the submission method chosen. For instance, if a practice utilizes Registry submission method instead of EHR, the practice’s score could be different.
In addition to the final score, the required minimum number of quality measures also depend on your chosen submission method.
- Most of the providers will need to report 6 quality measures (or the Specialty Set as described before)
- If you pick CMS Web Interface submission method (only available to groups of 25 or more), you need to report all the 14 measures included in the CMS Web Interface.
If you choose to submit quality data via CMS Web Interface or CAHPS for MIPS survey, you would need to report data for the full calendar year 2017 (Jan 1, 2017 – Dec 31, 2017). The 90 days option is not available for these submission methods.
STEP 9: SELECTING QUALITY MEASURES
Quality measures under MIPS have been sub-categorized into Efficiency, Intermediate Outcome, Outcome, Patient Engagement/Experience, Process and Structure measures.
Some of these measures have been tagged as High Priority Measures (P), while some have been tagged as bonus eligible for CEHRT/end-to-end reporting (E).
Unless your specialty set has less than 6 measures (see step 2) or you select the CMS Web Interface option, you must report on a minimum of 6 measures out of which one measure must be an Outcome Measure. In case no outcome measure applicable to your practice is available, you must select a High Priority measure instead to receive a score for the Quality category. You will receive bonus points for selecting additional high priority or outcome measures.
THE QUALITY SCORE IS CALCULATED AS :
A. Determine the maximum points. If you are reporting a Specialty Measure Set that has less than 6 measures, your max points would be less than 60 (no. of measures x 10). Although there are a minimum 14 reportable measures for CMS Web Interface submission mechanism, the max score is NOT 140, but 110 as there are only 11 measures that have a benchmark. The 3 measures that don’t have a benchmark will not be scored if you report all the measures, but you would be penalized for not reporting all the measures. For all other providers, the maximum points will be 60 (based on 6 measures).
B. Calculate your base points: You can earn a maximum of 10 points for each of the six measures. The benchmark decile for a measure and submission method determines the points earned for each measure.
C. Calculate OPX Bonus Points
- 2 bonus points for each additional Outcome Measure (O) - The first outcome measure selected does not qualify.
- 1 bonus point for each additional High Priority Measure (P) - reported in addition to the one reported in lieu of the one required outcome measure.
- 2 bonus points for each Patient Experience Measure (X)
The OPX bonus points are capped at 10% of the maximum score. If Maximum Points is 60, you can only earn 6 bonus points.
Additionally, to earn these bonus points for a measure, the data must meet the 50% data completeness, 20 case minimum requirement, and have a numerator greater than one.
D. Calculate CEHRT Bonus Points
You can earn additional bonus points for the reported measures if you choose to do end-to-end electronic reporting via certified EHR, QCDR, Qualified Registries or CMS Web Interface. End-to-end means no manual intervention in any step from the point of data creation to submission to CMS. CEHRT bonus points are also capped at 10% of the maximum score.
E. Total Category points = Base Points + OPX Bonus Points + CEHRT Bonus Points
If the maximum points for you are 60, and your points total up to 62, your score is capped at 60 points. YOU DID A GREAT JOB! This means you get full credit for the Quality category towards calculation of your MIPS Score.
Note: If you are a group of 16 or more providers, CMS will calculate your performance in the All Cause Hospital Readmission Measure from the Administrative Claims data. If you meet the minimum case requirement of 200 for this measure, it will count towards your Quality score and will be added to your report by CMS to determine the final score.
STEP 10: ENTER DATA FOR QUALITY MEASURES
The last step to calculate your MIPS score is to enter the data for the quality measures. Most of this has already been covered in the previous two steps. There are a couple of things you need to remember before you start entering your data:
- Data Completeness Requirements: Minimum 50% Data completeness is required to achieve max points for each measure. That means that at least 50% of your total patients who meet the measure's denominator criteria, regardless of payer (Medicare and Non-Medicare) must be reported except for Claims for which only Medicare beneficiaries count. Less than 50% completeness will yield only 3 points for all other submission mechanisms except CMS Web Interface. For CMS Web Interface, less than required data completeness will yield ZERO points for that measure.
Note: MyMipsScore app assumes required data completeness for the chosen measures for score calculation.
- Minimum of 20 Cases: For all the Quality measures, you must at least report 20 cases, i.e., the denominator must be 20 or more for you to earn more than 3 points for that measure. For instance, a Numerator/Denominator of 18/18 will yield only 3 base points, but Numerator/Denominator of 18/20 could yield 10 points (based on the decile system). For CMS Web Interface, if you meet the Data Completeness Criteria, but don’t meet the Case minimum, the measure will not be scored (i.e., will not be counted towards max points).
Score for two different measures can vary even with the same performance based on the benchmark and available bonuses for the measures. In the MyMipsScore app, we encourage you to select as many measures as you can and enter data for all of them. The app automatically selects the 6 measures that yield you the highest score after taking into account all the criteria discussed in the 10 steps.
With so many rules to consider, how to maximize the MIPS score?
Keeping track of submission methods, measure benchmarks, topped-out measures, case minimums, and bonus requirements in addition to care delivery can be overwhelming. But it doesn't have to be.
Introducing MIPS Score Simulator
Now you can make informed MIPS decisions with the help of the patent pending MIPS Score Simulator feature of the MyMipsScore app. You run what-if scenarios, and see the financial impact of any change in any quality measure performance rate instantaneously.
Equipped with this capability, you can select the ideal measures for your practice, determine the ideal performance rate for those measures, and decide whether to report as a group or as individuals with confidence.