MIPS will be the most likely pathway for dermatologists to participate in MACRA. MIPS combines CMS’s three existing reporting programs, PQRS, Value-based Modifier, and EHR Meaningful Use, under a single entity. Beginning in 2019 MIPS replaces penalties associated with these three programs with potential to earn a bonus or incur a penalty based on your overall MIPS performance score.
Do you need to participate in MIPS? How might it affect your revenue? Find out with AAD's interactive assessment tool.
In the MACRA Final Rule, CMS announced physicians will be able to "pick their pace of participation" for the first performance period beginning Jan. 1, 2017. To avoid a payment penalty in 2019, physicians choosing the MIPS pathway must choose one of the options outlined below:
- Test the Quality Payment Program: Physicians may choose to submit one of the following options beginning Jan. 1, 2017:
This option prevents physicians from incurring a negative payment adjustment.
- One measure in the quality performance category at least one time*
- One activity in the improvement activity category
- Five required measures making up the base score of the advancing care information (ACI) category
*The AAD strongly recommends practices report more than one measure or report at least one measure over a 90-day period as an insurance policy in the event of submission issues or inaccuracies. Failure to correctly report one measure or activity in 2017 will result in a 4% penalty in 2019.
- Participate for part of the calendar year: Physicians may choose to submit one of the following options for any 90-day period beginning Jan. 1, 2017 through Oct. 2, 2017:
- More than one quality measure in the quality performance category
- More than one improvement activity
- More than the five required measures in the ACI category
This option may allow for a "neutral or small positive payment adjustment".
- Report all MIPS measures for 90 days: Physicians may choose to submit all of the following Quality Payment Program information for 90 days or the full calendar year:
- Six quality measures in the quality performance category
- One high-weighted improvement activity or two medium-weighted improvement activities
- Five required measures making up the base score of the ACI category.
This option may allow for a "modest positive payment adjustment". Please note that there are additional requirements for practices with more than 15 providers.
To calculate your MIPS score, CMS will evaluate your performance in four core areas. Scores in each area will be weighted. CMS has indicated the weights below for 2017 but will adjust these as the program evolves.
- Quality Reporting, 60%: This category evolves the PQRS requirements. You must report only 6 measures, rather than the 9 required under PQRS. Of the 6, one must be an outcome measure or high-priority measure. You must report measures for 50% of your population regardless of payer. Reporting may be completed via a registry such as DataDerm or via your EHR. You will receive 3 - 10 points for each measure based on how your performance compares to the benchmark. You can select any 6 measures or pick from the dermatology specialty measure set. Learn more about quality.
- Advancing Care Information, 25%: This category assigns credit for your use of a certified EHR and replaces the requirements of the current Meaningful Use program. You will receive an overall score comprised of several elements:
Required reporting may be completed via a registry like DataDerm, your EHR, or the CMS portal. Learn more about ACI.
- Base score: 50 points for reporting 5 required measures.
- Performance score: 90 points for reporting 9 optional measures which assess patient interaction and health information exchange.
- 5 Bonus points: For participation in a registry such as DataDerm.
- 10 Bonus points for completing improvement activities related to ACI.
- Improvement Activities, 15%: A practice of 15 or fewer physicians will receive full credit for completing one high-weight activity or two medium-weight activities selected from a list of 90 activities qualified by CMS.
You can report on these activities through a data registry such as DataDerm, your EHR, or the CMS portal. Learn more about improvement activities.
- Cost, 0%: No reporting will be required for this category. CMS will assign your score based on claims data in 2017 and report it to you in your feedback report, but it will not account for your overall score.
CMS will develop benchmarks for each of these measures and points will be assigned based on how your score compares to benchmark. Your overall score will be based on how you compare to others reporting the measure, which represents an evolution by CMS to pay for performance under MIPS from the pay for reporting approach of PQRS.
Your MIPS incentive in 2019 will be based on your 2017 performance. Incentives continue until 2022.
MIPS: Delving into the Details
Watch the presentation below to learn more about how to participate in MIPS.