As the 2017 Merit-based Incentive Payment System (MIPS) reporting year is fully underway, participants should verify which pathway is right for you and implement a reporting plan that complies with the program’s requirements. As a reminder, the following three pathways are offered within the MIPS program:
Minimum participation: By reporting on just one measure for one patient, MIPS providers can avoid a 4% negative payment adjustment in 2019. Therefore, it is recommended that clinicians choose this pathway over not submitting any data for the 2017 reporting year.
Partial participation: In order to participate in this track, CMS requires a 90-day participation period. This means that providers had to have started activities by Oct. 2, 2017. Clinicians who choose this pathway can potentially receive a positive payment adjustment in 2019.
Full participation: In order to qualify for this track, clinicians must submit data for more than 90 days. This pathway has the most extensive data reporting requirements but also offers the most opportunities for a high positive payment adjustment in 2019.
Some frequently asked questions related to MIPS participation are:
Can I complete activities retroactively for the partial or full participation tracks?
It depends. If you already have a system in place that automatically captures data in an acceptable format, then you can go back into these systems to obtain the necessary data. If you are reporting quality data via claims submissions, then you cannot go back and recreate these interactions in order to meet the requirements.
Do I need to designate my chosen MIPS track to the Centers for Medicare and Medicaid Services (CMS)?
No. CMS will ultimately determine what pace you fall under based on your submission. The benefit of this system is that you may decide to switch from one MIPS pathway to another over the course of a single reporting year.
When will the CY 2018 rule for the Quality Payment Program be finalized?
CMS released the final rule on Nov. 2, 2017. Read the Quality Payment Program Year 2 Final Rule Overview.
Are you ready to begin reporting data for your MIPS submission? The AASM offers an online tool called MIPSwizard that can guide you to rapidly collect, validate and submit your results to CMS.