Using the Last 90 days of MIPS 2017 to Prepare for 2018 Reporting

By Hannah Lerner Harrison, MSPH, Senior Quality Programs Coordinator, TSI Healthcare
Twitter: @tsihealthcare

When the 2017 Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Final Rule was released fall 2016, it was branded as a “transition” year. It truly is a transition allowing increased flexibility and limited opportunity to fail. For 2017, CMS estimated only 8.1% – 5.3% of clinicians would fail¹.

As we move into the last 90 days of the 2017 MIPS reporting period, how do practices set themselves up to achieve their highest MIPS Composite score? The expectations of bonuses this year are smaller than expected, so focusing on the 2018 MIPS proposed rule changes and implementing them today can ultimately increase a practice’s MIPS incentives in the next couple of years as more practices fail to meet the MIPS requirements.

Prioritize Quality Reporting
Are you ready to start your 2018 quality reporting period on January 1st, 2018? For 2018, the Quality category is proposed to be a full year reporting period. This category of MIPS is the most influential category, accounting for 60% of your total MIPS composite score in 2017 and potentially 2018. Practices will want to be strategic in the quality measures they are choosing and the submission mechanism they are using.

  • Focus on CQMs.
    • CQM measures reported via EHR submission have lower benchmarks than quality measures reported via QCDRs and Registry submission mechanisms. The lower the benchmark, the easier it will be to achieve a higher performance score on your quality measures.
  • Cut out the topped out measures.
    • Not only is it harder to earn the maximum 10 points for topped out measures in 2017, topped out measures are proposed to drop to a maximum of 6 points in 2018. Identify which measures you focus on now that are considered topped out and look for alternatives.
  • Identify your submission mechanisms.
    • In 2018 it is proposed that if a practice has access to more than one quality submission mechanism, like a QCDR and EHR submission option, you can strategically select your best measures from each mechanism for submission.

Evaluate your EHR Certification
2018 will be difficult year to balance both completing the Advancing Care Information (ACI) Category and moving through an upgrade to 2015 Certified EHR Technology (CEHRT). Though you still have flexibility in 2018 to be on either 2014 or 2015 CEHRT, by 2019 you will likely need to be on 2015 CEHRT to complete the ACI category. This means completing any necessary upgrades next year.

Use 2018 to be strategic with the ACI measures you report. If your practice has been knocking the transition ACI measures out of the park, finalize your reporting period early on in 2018. This gives your practice time to focus on the upgrade process. While you can benefit by upgrading earlier in 2018 to a 2015 CEHRT version by receiving a 5 point bonus in the ACI category, practices may want to be cautious of the ACI core measures. The ACI core measures have more requirements and may introduce new workflows into your practice’s day to day.

So what does this all mean? MIPS is a numbers game and knowing where to put the most effort now can ultimately lead to better incentives in the long run. Use the flexibility of 2017 as an opportunity to make the necessary changes to be prepared for when MIPS becomes a more difficult program.

¹ Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, 81 Fed. Reg. 77008 (November, 4th, 2016). Pg. 77522