With less than a month left in the 2018 MIPS performance year, it may feel like it’s too late to start working on MIPS. However, there is still a lot providers and practices can do to meet the minimum threshold score and avoid a negative payment adjustment in 2020.

If you’re new to MIPS (or just want a refresher!), please refer to the article here for an overview and explanation of how the MIPS program and scoring works.

It’s important to remember that payment adjustments under the Merit-based Incentive Payment System (MIPS) are based on an aggregate score across four performance categories. The program is no longer “pass/fail” like Meaningful Use, so even performing a few activities now or reporting on activities you are already doing may be enough to avoid the cut.

Before reading further, be sure to check your MIPS participation status. If you are part of certain payment models, called APMs (Alternative Payment Models), you may be exempt from MIPS or may have different reporting requirements. You may also be exempt if you are below a minimum threshold of patients or Medicare allowed charges (in 2018 for non-APM participants, 200 patients AND $90,000 in allowed charges). Enter your NPI at this link to find out if you need to report MIPS: https://qpp.cms.gov/participation-lookup

For those who need to report MIPS outside of an APM, let’s look at the three reporting categories and a few December possibilities for avoiding the cut.

To avoid a payment cut in 2020 based on 2018 performance, you need to earn 15 points overall out of a possible 100 points. Those in small practices (less than 15 MIPS-eligible clinicians) are automatically awarded 5 overall bonus points, so these clinicians only need to find 10 points total to avoid the cut.

Improvement Activities

  • Attesting to having completed certain Improvement Activities for a minimum of 90 days can award up to 15 overall MIPS points.
    • Many activities are things you may already be doing, like participating in your state’s Prescription Drug Monitoring Program (OARRS in Ohio), providing specialist reports back to referring providers, or providing 24/7 on-call coverage with remote EHR access.
    • Medium-weighted activities are worth 3.75 overall MIPS points.
    • High-weighted activities are worth 7.5 overall MIPS points.
    • Clinicians in small practices receive double points, so one high-weighted activity or two medium-weighted activities will earn 15 overall points for these clinicians.
  •  Download the .zip file with a PDF and Excel list of all 2018 activities by clicking here.
  • Since these measures are based only on attestation, be sure you can meet the suggested documentation requirements here in case of audit.

Promoting Interoperability (PI)

  • If you use a 2014 or 2015 Certified EHR, you can check your system reports to see your performance on the measures. Even if you weren’t actively working on the measures, you may have achieved some points.
    • For example, meeting these four measures earns 12.5 overall MIPS points:
      1.  Conduct the required annual Security Risk Analysis
      2.  Send one e-prescription or write less than 100 prescriptions in 90 days
      3.  Provide at least one patient access to your portal
      4.  Send an electronic summary of care for one outgoing referral or makes less than 100 referrals in 90 days
    • If you meet these four measures, you are also eligible for additional points in the PI category, up to a max of 25 overall MIPS points.
  • If you are in a practice of 15 or fewer eligible clinicians or fit one of several other circumstances, you can apply for a Hardship Exception here to re-weight this category’s points to the Quality category. This increases the overall points you can earn from the Quality category.

Quality

  • Reporting even a little quality data for a measure, such as one reporting code on an eligible Part B claim, guarantees a minimum measure score of 3 quality category points for clinicians in small practices or 1 quality category point for clinicians in large practices.
  • Reporting any amount of data correctly for 6 quality measures (including one high-priority measure) corresponds to 15 overall MIPS points for small practices or 5 overall MIPS points for large practices.
  • If a practice claimed a PI hardship exception, the 15 overall MIPS points becomes 22.5 points and the 5 overall MIPS points becomes 7.5 points.