The Merit-based incentive Payment System (MIPS) introduces 4 measure categories to the Medicare incentive program space. As we have mentioned in previous posts, MIPS is the new law of the land, replacing Medicare’s Meaningful Use, PQRS and Value Modifier incentive programs. Reporting for MIPS starts in 2017 so it is important to start learning what you need to do now. The Quality Performance Category replaces the PQRS.
Similarities and Good News
At least in the first several years, PQRS and the Quality Performance Category are very similar. Clinicians will choose measures from a similar list of measures that has existed for PQRS. For the most part, they aren’t taking away current measures. CMS is making changes to some of the measures and additional measures to choose from to report. Submission options will also be the same for Clinicians and Groups as in PQRS.
The best news of the change, is that practices will only be required to submit data on 6 measures. Reporting still requires 1 cross cutting measures, but the other 5 do not have to be across 3 domains. The other change is that practices will be required to report on at least one applicable outcome measure.
The Differences
Unfortunately, the changes from PQRS are a little more complicated to navigate. The first and perhaps most substantial change from PQRS is the penalty. Avoiding the penalty in PQRS was easy. All a practice had to do was report on the measures. The penalty for poor quality/poor reporting was realized in the Value-based Payment Modifier (VM). This change means that even if you report your data for the Quality Performance Category, it doesn’t mean that you will avoid a penalty for MIPS. Furthermore, your Quality Performance Category score is not entirely based on reporting. Each performance measure will offer Clinicians up to 10 points based on the percentile distribution of reported scores for that measure. HUH? This means that if the measure you pick is an easy measure to report a high percentage, you won’t earn the maximum Quality score. In fact, if a measure is topped out, meaning that more that half of clinicians report 95% or better for that measure, the quality score will be at least 15% less than more difficult measures. This means that the best way to score highly in this category is to pick quality measures that others find difficult, but your practice is successful at.
Don’t worry though if you your specialty has limited quality measures, there is an opportunity to boost your score with additional points. If the clinician reports on additional high priority measures, as deemed by CMS, they will receive an additional bonus point for that quality measure. If you participate in what’s called end-to-end electronic reporting, you will receive an additional bonus point. Finally, if you report on additional outcome measures, you will also receive bonuses.
There are also 2-3 population based measures that will be determined from your claims and not from reporting. These include hospital readmission and emergency department visits. You don’t need to worry about reporting on these.
Context within MIPS
Each Performance category is weighted differently within MIPS. In the first year the Quality Category is 50% of the total MIPS composite performance score. MIPS also sets guidelines for how new measures may be suggested and added to the pool in additional years. CMS has also said that if a measure is found to be topped out, it will be removed from the measures list.
Please see our other posts related to MIPS for more information!
Editor’s Note: Subsequent to the publication of this article, CMS has renamed the “Meaningful Use” programs and MIPS “Advancing Care Information” category to “Promoting Interoperability”.