MIPS

Were payment adjustments scaled for negative adjustments?
  • MIPS

Yes, the negative adjustment is scaled.

How many APM models exist?
  • MIPS

Here is a 2018 list of APMs: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Comprehensive-List-of-APMs.pdf

Will the transition from Advancing Care Information (ACI) to Promoting Interoperability (PI) cause any modifications to the measures contained within that part of the program?
  • MIPS

No, not for the 2018 performance period.

In 2019, are you going to expand the definitions of who is eligible for MACRA (such as social workers, dieticians, etc.) or will it continue to be MD/DO/PA/NP?
  • MIPS

CMS will address this in their notice of proposed rule-making to be released summer 2018.

Can an eligible clinician change from group to individual each reporting year?
  • MIPS

Yes.

Are Nurse Practitioners, Physician Assistants, and CRNAs exempt from Promoting Interoperability (PI) performance category for the 2018 performance year?
  • MIPS

They are MIPS eligible clinicians but for the Promoting Interoperability performance category their performance score is automatically re-weighted to the quality performance category. The exception to this statement is if they report as part of a group, then their PI data would be included in the group submission.

When will the clinician performance reports be available for the 2017 reporting year? Where would they be on the CMS website?
  • MIPS

You can log in at https://qpp.cms.gov/login to see the clinician's preliminary feedback for the 2017 performance year.  Please note that the information displayed is not final.  Final feedback will be available summer 2018.

Is the negative adjustment a flat 5% for 2020 payments if the EC/group doesn't meet the 15 performance points threshold?
  • MIPS

No, 0-3.75 points would receive a -5% adjustment, the maximum adjustment. Anywhere from 3.76 to 14.99 is scaled from -5% to 0%.

Is a physician in an inpatient rehab facility considered a hospital base physician?
  • MIPS

Hospital-based clinicians are determined based on services performed in POS 21, 22, 23, and 19. With 75% or more of the services must be performed in those settings.

Even though the IPPS proposed rule proposes changing MU to PI and has not been finalized, QPP is adopting the proposed rule for 2018 already? So for MIPS, ACI is now gone and this year will report on PI measures?
  • MIPS

The name Advancing Care Information (ACI) has been changed to Promoting Interoperability (PI) but the measures for 2018 are unchanged. The IPPS proposal is for hospitals starting in 2019.

What is the required reporting data date range for 2018?
  • MIPS

For 2018 MIPS eligible clinicians are required to report 12 months of data for Quality and Cost and at least 90 days for the Promoting Interoperability and Improvement Activities performance categories.

Does CMS know when the information is going to be released to know what providers may be added to participate in QPP for 2019?
  • MIPS

CMS will have proposals for the 2019 performance period in their notice of proposed rulemaking to be released in early summer.

Are the low volume thresholds determined by performance during 2017?
  • MIPS

Initial inclusion in Year 2 for MIPS is based on historical claims data from 9/1/16 to 8/31/17.

Are ACI categories different for 2014 vs 2015 CEHRT? Can they be combined?
  • MIPS

For the Promoting Interoperability (PI) performance category, there are 2 measure sets for 2018 (just like there were for 2017). You can choose which set you wish to submit and may submit a combination.

When will hardship applications for 2018 be made available on this link? (https://qpp.cms.gov/mips/advancing-care-information/hardship-exception)
  • MIPS

These will be available Summer 2018 at https://qpp.cms.gov/mips/advancing-care-information/hardship-exception.

 

Are NPs still exempt from Promoting Interoperability?
  • MIPS

Yes, for the 2018 performance period.

CMS will provide Performance Year 2017 score info to TINs July 1st. Will CMS just be providing the 'score' received or additional information?
  • MIPS

Yes. Clinician's final performance and score will be available.

If a facility has clinicians that were found exempt in the first determination and then found eligible in the second, will they receive payment adjustments if they attest?
  • MIPS

If a clinician is exempt, he/she may still voluntarily report, but he/she will not receive a payment adjustment positive or negative.

Hospital based physicians will have an automatic reweighting of the ACI category. Can small practices apply to have the ACI category reweighted based on the special status?
  • MIPS

There will be a category called "small practice" on the hardship application on the Promoting Interoperability hardship form.

When will the 2018 ACI exemption application going to be released?
  • MIPS

The Promoting Interoperability application will be available summer 2018.

For 2017 reporting, when do we receive information on where clinicians finished and their payment adjustments?
  • MIPS

Preliminary feedback is available now.  However, final feedback and scores will be available summer 2018.  You are required to use your EIDM credentials for access.

What is the benefit of participating as a virtual group?
  • MIPS

Virtual groups allow MIPS eligible clinicians to join forces without geographical boundaries to maximize their participation.

For PI reporting, how should we handle reporting as a group if we use multiple EMRs within the same TIN? (The TIN is also a part of MSSP track 1).
  • MIPS

You sum the data across the CEHRT to submit.

Are Behavioral Health clinicians included in the provider types?
  • MIPS

Yes, if they are a physician or nurse practitioner. LCSW and therapists are not eligible clinician types at this time.

How can small practices apply for the exclusion for Promoting Interoperability?
  • MIPS

They apply on the QPP site when the application portal opens later in the summer 2018.

If clinicians are exempt and decide to voluntarily participate in the MIPS program as a group, I understand they will not receive a negative adjustment. However, can they receive a positive adjustment if meeting or exceeding MIPS criteria?
  • MIPS

Voluntary reporters do not receive a payment adjustment neither positive nor negative. However, beware that you could be considered eligible as a group, if your group exceeds the low volume threshold. If clinicians do not exceed the low volume threshold, individually, you can participate voluntarily that way.

How will a clinician know if they are exempt?
  • MIPS

First, determine if you're an eligible clinician type. Then, use the MIPS participation look up tool to determine if you exceed the low volume threshold: https://qpp.cms.gov/participation-lookup.

If small practices apply/receive a PI/ACI exemption, is that % reweighted to the quality category?
  • MIPS

Yes.

Clarification is needed with the promoting interoperability and group submission for hospital based providers. If all of the claims the providers submit are POS 21 or 23, would they have the quality reweighted and be exempt from promoting interoperability?
  • MIPS

If the group is 100% hospital-based, then the PI category will be re-weighted to quality.

Does MIPS year 2 participation thresholds for Medicare apply to both Stage 3 and Transitional Stage 2 measure?
  • MIPS

Yes.

Is QPP full credit participation given for Improvement Activities, for MSSP Track 1 MIPS APM?
  • MIPS

Yes, MIPS ECs in a MSSP Track 1 ACO will get full credit for the Improvement Activities (IA) category. More information on the 2018 IA points assigned to Shared Savings Program ACOs can be found in this guide: 

https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Scores-for-Improvement-Activities-in-MIPS-APMs-in-the-2018-Performance-Period.pdf