The CMS has created new MIPS terminology that more accurately reflects how clinicians and vendors interact with the QPP, namely MIPS. The new MIPS terms include Collection Type, Submitter Type, and Submission Type.
- Collection type: a set of quality measures with comparable specifications and data completeness criteria including, as applicable, electronic clinical quality measures (eCQMs), MIPS clinical quality measures (CQMs), Qualified Clinical Data Registry (QCDR) measures, Medicare Part B claims measures, CMS Web Interface measures, the Consumer Assessment of Healthcare Providers and Systems for MIPS survey measure, and administrative claims measures.
- Submitter type: the MIPS eligible clinician (EC), group, or third-party intermediary acting on behalf of a MIPS EC or group, as applicable, that submits data on measures and activities.
- Submission type: the mechanism by which the submitter type submits data to CMS, including, as applicable, direct, log in and upload, log in and attest, Medicare Part B claims, and the CMS Web Interface. There is no submission type for cost data because the data are only submitted for payment purposes.
Each year, the CMS provides a list of providers that are required to participate in the QPP MIPS. This year, known as year 3, CMS expanded the definition of MIPS ECs to include new clinician types including physical therapists, occupational therapists, speech-language pathologists, audiologists, clinical psychologists, and registered dietitians or nutrition professionals. Providers from the previous year remain included: physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups or virtual groups that include one or more of the clinician types above.
Clinicians or groups have the ability to “opt in” to MIPS if they meet or exceed one or two, but not all, of the low-volume threshold criteria. Those clinicians who opt in to the MIPS program would be subject to neutral, negative, or positive payment adjustments based on their MIPS performance and final score.
MIPS Determination Period
The CMS stated that they have created a streamlined and consistent “MIPS Determination Period” that will be used to evaluate clinicians and groups for
- the low-volume threshold,
- non–patient-facing status,
- small practice status, and
- hospital-based and ambulatory surgical center–based statuses.3
This period includes two 12-month segments:
- first segment: October 1, 2017 to September 30, 2018 (including a 30-day claims run-out);
- second segment: October 1, 2018, to September 30, 2019 (does not include a 30-day claims run-out).
Note that these 12-month segments now align with the fiscal year and begin October 1st.
Performance Thresholds and Payment Adjustments
The CMS is doubling the MIPS performance threshold in 2019. All MIPS ECs and groups have to earn at least 30 MIPS points to ensure a neutral payment adjustment.
Further, the CMS is increasing the exceptional performance bonus in 2019 for the top MIPS performers. Clinicians and groups seeking an exceptional performance bonus would need to earn at least 75 MIPS points.
As required by statute, the maximum negative payment adjustment is -7%. Positive payment adjustments can be up to 7% (but they are multiplied by a scaling factor to achieve budget neutrality).
Read previous articles in “Advances in Skin & Wound Care” by Cathy Thomas Hess in the link.
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Cathy Thomas Hess is VP, Chief Clinical Officer for Wound Care at Net Health. She has over 30 years of experience in wound care, authored hundreds of journal articles, spoken at both national and international events, and has authored book chapters and the best-selling handbook titled Product Guide to Skin and Wound Care, 8th edition. She continues to be influential in the wound care community today and serves on the Editorial Advisory Boards for Advances in Skin and Wound Care, authoring a monthly column entitled Practice Points, and Today’s Wound Clinic.