Q. What’s not different from year-one MIPS?
A. One major similarity from year-one to year-two MIPS include that there are still four areas: Quality; Improvement Activities (IA); Advancing Care Information (ACI); and Resource Use (Cost). There’s still a penalty or bonus possible, but any bonuses are likely to be small, since avoiding the penalty is straightforward, and this part is budget-neutral. The “exceptional performers” bonus of up to 10 percent remains and is non-budget-neutral since it has the same 70-point MIPS Composite Score threshold as in year one.
Q. What are some major things to know about MIPS in year two?
A. First, the minimum total Composite Score to avoid a MIPS penalty rose from three points for reporting-year 2017 (year one) to a still manageable 15 points for reporting-year 2018 (year two). As before, nearly all eye-care providers will remain on the MIPS side of QPP, as opposed to the Advanced Alternative Payment Model side under QPP. Any bonuses and penalties for year two happen in payment-year 2020.
Second, the possible 2020 MIPS penalties or bonuses rise from 4 percent in year one to 5 percent in year two, so it’s even more important to avoid a 2020 penalty by getting at least 15 points in 2018.
The Cost component under MIPS is now 10 percent, which is up from zero in 2017. The methodology for attribution of costs remains contentious. ACI and IA remain unchanged at 25 percent and 15 percent, respectively. The Quality component of MIPS decreased to 50 percent, but can be re-weighted upwards (more on that below). The Quality component is now in effect for the entire reporting year, while the ACI and IA components can be in effect for as few as 90 consecutive days.
There was a recent “Technical Correction” to the original April 2015 MACRA law that was just passed in February 2018 as part of the budget reconciliation bill to continue funding the federal government. It made some subtle but permanent changes to the MACRA regulatory language that have a significant positive impact for ophthalmologists. The words “items and services” under MACRA were changed to “covered professional services.” This means that Part B drugs (which are billed by the provider from the office) are no longer subject to the MIPS eligibility and penalty provisions. CMS will now make all these determinations only on covered professional services (e.g., eye exams, surgeries and tests). No longer are your 2020 payments for intravitreal drugs such as bevacizumab, ranibizumab and aflibercept at risk under MIPS.
Q. How can I get to 15 points for reporting year 2018 and avoid a 5-percent penalty?
A. Making three points in 2017 was fairly easy—successful reporting in any of the four MIPS areas basically carried at least three points with it. Going all the way to 15 is a bit more work, but it is still relatively easy to get there. Among the many ways to get to 15 for a 2018 MIPS Composite score are the following:
• Successfully report for IA. A perfect score here (40/40 = 100 percent) has a 15-percent weight and would therefore yield 15 points.
— As in year one, CMS has allowed small practices a bit of a leg up in this area. Small practices only have to score 20 and CMS will double the score to 40.
— Large practices need to score the 40 points the usual way.
— Medium-weighted IA are worth 10 points each; high-weighted ones are worth 20 points each. Any combination of high- and medium-activities works.
• Get at least 15 points from ACI.
— Making the base score section within ACI is half (50) of the maximum 100-point score achievable in this category, so after weighting, this would be 12.5 pts.
— Anything in the performance section of ACI that adds three more points after weighting can contribute.
• Score 15 in Quality only.
— This could be done by scoring three or more points in each of the six highest-scoring quality measures a provider chooses.
— There is a large variety of measures to report in this part of MIPS, but the particular measures available depend on the reporting method chosen.
Any other combination of ACI, Quality or IA that totals 15 points also avoids the 5-percent penalty in 2020.
Q. Are there still exemptions from MIPS available?
A. Yes, and they are much more favorable than in year one, which was $30,000 in allowed Part B charges or 100 Part B patients. The 2018 thresholds for an individual provider reporting alone are now $90,000 in allowed Part B charges or 200 Part B patients, so many more providers are likely off the hook and won’t be subject to MIPS at all in 2018. They therefore cannot be penalized in 2020.
Q. Can the areas in MIPS be re-weighted?
A. Yes. Re-weighting might occur in a couple of scenarios:
• If a provider has a hardship exemption for ACI, that 25 percent from ACI would go to Quality, which would then carry a 75-percent weight.
• If there were no Costs assigned to a provider, the 10 percent from Resource Use would go to Quality.
• It’s possible that you might have both of the above, so Quality could be as high as 85 percent of the composite MIPS score. REVIEW
Mr. Larson is a senior consultant at the Corcoran Consulting Group. Contact him at plarson@corcoranccg.com.
