How To Avoid The MIPS Penalty For the 2018 Performance Year

With the passing of the Bipartisan Budget Act of 2018, the Centers for Medicare and Medicaid Services (CMS) continue to gradually implement the Merit-based Incentive Payment System (MIPS) for an additional three years with the goal of helping providers transition to value-based care. 

The performance threshold was 3 points in 2017 and is 15 points in 2018. What this means is that if you reported and received a MIPS score of 3, you would not have a penalty applied to your 2019 Medicare reimbursement. In 2018, you will need to get a MPIS score of 15 in order to avoid a penalty.

In addition, the MIPS Cost Category weight was 0% in 2017 and is 10% in 2018. The MIPS Quality Category was 60% in 2017 and is 50% in 2018. The low volume threshold was $30,000 (or 100 patients) and is $90,000 (200 patients) in 2018. The minimum reporting period was 90 days and is 12 months in 2018.

The category of Clinical Practice Improvement Activities (CPIA) is what I want to focus on. If you are planning to participate in MIPS for 2018, the easiest way to avoid the penalty is as follows. As this category is this CPIA gives providers an opportunity to obtain the minimum points required and you may already be performing many of the activities in this category, you can achieve this with the four months remaining in the year.

The CPIA category allows those of us in small groups—those with less than 15 employees and/or in solo practice—to double the weight of the category as well. This means this category score requires 40 CPIA points in order to get the full 15 MIPS score, just by reporting this one category.

You can perform one high weight activity for 20 points. Doubling this gets you the full score or you can pick a medium-weight activity to receive medium weight activity for 10 points each. Accordingly, you only have to do two activities to get the full CPIA credit and thus the full MIPS score.

You can still use the CPIA category to easily prevent a penalty if you are in a larger group — even if the scores are not doubled — by either picking two high weight activities, four medium weight activities or a combination of high and medium weight activities to get the full 40 points needed to achieve the full 15 MIPS points.

There are over 90 improvement activities you can choose from. One high weight activity is: “Provide 24/7 access to MIPS eligible clinicians or groups who have real-time access to patient’s medical record.” If you use a web-based electronic medical record (EMR) system, you meet this definition and CMS does require that you are able to “provide same or next day access to the MIPS eligible clinician, group or care team when needed for urgent care or transition management.”

A medium weight CPIA might be registration to your state’s Prescription Drug Monitoring Program. If you logged in and checked a patient before prescribing the narcotic mediation, say for post-op pain management, and did this before giving your patient five to seven days’ worth or medication, this second part of Consulting the Drug Monitoring Registry is considered a high weight activity.

Other medium weight activities include:

Assess patient experience through surveys

         Provide self-management materials

         Evaluation of tobacco use and cessation discussion

         Providing a report to a referring physician

         Fall screening/assessment

If you are exempt from MIPS participation, you can still choose to report individually by submitting data on quality measures to receive feedback from CMS. However, exempt physicians are not eligible for positive or negative payment adjustments either way. Why would you then consider voluntarily reporting? This may enable you to receive feedback on performance in preparation for future participation in MIPS as it moves further into quality payment models or to meet quality requirements if you want to join an advanced alternative payment model.