Introduction to MIPS 2018 -Fundamentals

Brett M. Paepke, ODDirector, ECP Services

March 13, 2018

Objectives• What’s the alphabet soup all about (MACRA, MIPS, QPP)?• What is MIPS?• Are you eligible to participate in MIPS?• Why should you want to participate in MIPS?• What MIPS resources does Rev360 provide?

Disclaimer

• All information is accurate to the best of our understanding of the 2018 Final Rule at the time of this presentation

MACRA

• Medicare Access and CHIP Reauthorization Act of 2015• Aims to pay for quality of

care rather than quantity

MACRA

Quality PaymentProgram

APMs MIPS

MIPS Fundamentals for 2018

• Eliminates the separate penalties of MU, PQRS, and VBM

• Rolls certain components of each program into a composite/final score for MIPS• 0-100 based on performance in 4 categories

• Your Final Score is compared to the “performance threshold” to determine how you’ll be paid for Part B services in 2020• +/- 5%

MIPS Fundamentals for 2018• 2017 Example

• Dr. Smith’s Final Score: 77• 2017 MIPS performance threshold: 3

3 1000 77

Performance threshold Dr. Smith

• Additional performance threshold: 70• $500 million in bonuses available for exceptional

performance between 2019 and 2024

70

Additional Performance

threshold

MIPS Fundamentals for 2018• Dr. Smith’s Final Score: 77• 2018 MIPS performance threshold: 15

15 1000 77

Performance threshold Dr. Smith

• Additional performance threshold: 70• $500 million in bonuses available for exceptional

performance between 2019 and 2024

70

Additional Performance

threshold

MIPS Eligibility

• Who is excluded in 2018?1. Newly eligible Medicare Part B clinicians2. APM Qualifiers and Partial Qualifiers who opt out3. Clinicians below the low-volume threshold

• Increased for 2018: • < $90,000 in Part B allowable charges OR < 200 Part B beneficiaries

• Will capture about 40% of clinicians billing for Part B services and about 66% of all Part B spending

MIPS Eligibility

• When is the low-volume threshold determined?• Determined via a 24-month, dual period view

• 1st is September 1 - August 31 of the year prior to performance• 2nd is September 1 – August 31 of the performance year

• If you are under the threshold for either period, you’re excluded

2016 2017 2018 2019

Performance Year

Sep 1 Aug 31 Aug 31Sep 1

MIPS Eligibility• The low volume threshold is determined at the level of participation• Example

• 3 doctor practice• Doctor A: $40,000 in MAC and 100 patients• Doctor B: $40,000 in MAC and 100 patients• Doctor C: $40,000 in MAC and 100 patients

Individuals

Under threshold

Group

Exceeds threshold

($120,000 and 300 patients)($40,000 and 100 patients)

ELIGIBLENOT ELIGIBLE

MIPS Eligibility

• Are you eligible?• Nearly 90% of optometrists

could be excluded in 2018• Can check your eligibility status

using CMS’ NPI Lookup Tool at qpp.cms.gov• Cannot opt-in for 2018, but CMS

has proposed it for 2019

Participation Options• Individual• No registration required

• Group• No registration required• Data of all clinicians in practice added together and reporting once

• Virtual Group (new for 2018)• Must register by December 31 of year preceding the performance year• Requires signed agreement between providers in the group• Practices with ≤ 10 clinicians can join, but anyone who joins must be eligible

outside of the virtual group

Data Submission• Each participation option (i.e. individual, group) has its own ways to

submit data to Medicare• You Can:• Report via different mechanisms for each category

• i.e. Attestation for Advancing Care Information, claims-based for Quality

• You Cannot:• Report via multiple mechanisms for the same category

• i.e. Registry AND claims-based for Quality• Report as an individual for one category and a group for the others

Data SubmissionWhen does all performance data need to be submitted?• No later than March 31 of the year following the performance year

• i.e. for 2018 performance year = March 31, 2019

Where does data get submitted?• Attestation and electronic file submissions take place on qpp.cms.gov

2018 Performance Periods

• Advancing Care Information: at least 90 straight days• Improvement Activities: at least 90 straight days• Quality: full calendar year• Cost: full calendar year

• 2019 will also feature 90 day periods for ACI and IAs

Key Differences in 2018

• Increase in Low-Volume Threshold• $90,000 in Part B Allowable and ≥200 Part B beneficiaries for inclusion

• Increase in performance threshold to 15

• Voluntary Opt-In on horizon

Thank You!

Brett M. Paepke, ODDirector, ECP Services

revaspire@rev-360.com