What You Need to Know

The Ifs, Ands, and Buts About It

Proposed Rule

As many may already know, to promote greater value within the healthcare system, MACRA established that the Quality Payment Program (QPP) be updated, annually. The proposed rule was introduced in June 2017, and the plan suggests changes to increase flexibility and reduce burdens, particularly for small, independent, and rural practices; however, the aim is to simplify reporting requirements and offer support for doctors and clinicians, overall. Though the comment period has ended, the Final Rule has yet to be posted. For consideration, here are just a few of the proposed changes awaiting finalization, to whet the appetite:

  • Increasing the Low-Volume Threshold (LVT) to exempt more small practices and currently eligible clinicians in rural or Health Professional Shortage areas.
  • Awarding bonus points to users exclusively on 2015 Edition CEHRT.
  • Potential bonus points being awarded for caring for complex patients.

For more information, please refer to the CMS Proposed Rule and associated Fact Sheet.

End-of-Year Approaching

For eligible clinicians, all is not lost if participation has not been an option so far this year. With MIE, data collection can go back as late as October 2nd, 2017, to attest for a 90-day partial-year performance period, which could potentially earn a positive payment adjustment. Remember, if avoiding a negative, or downward, adjustment is the only concern, simply submitting something will address this concern. The 2017 Transition Year allows for a test pace of participation, where EPs are able to submit as little as one measure or activity for one patient, on one day. This means data can be acquired as late as December 31st of this year, to avoid the negative payment adjustment!

Test Participation

Submit ONE (1) of the following:

**Category** **Quality** **ACI** **IA**
**Requirements** One (1) Quality Measure Four (4) Required Measures of Base Score ***** One (1) Improvement Activity (High or Med)
  • The required Advancing Care Information (ACI) Base Score measure set is determined by the electronic health record (EHR) edition certification.

For more information, review the ACI Fact Sheet or QPP webpage

Partial- or Full-Year Participation

To potentially earn a positive adjustment, or even a maximum adjustment, submit 90 days or a full year of 2017 data to Medicare. Because MIPS payment adjustments are based on the quality of data submitted, clinicians could earn the maximum adjustment with this track. Submitting all of the following requirements, with substantial quality data, can amount to a modest to maximum payment adjustment.

**Category** **Quality** **ACI** **IA**
**Requirements** Six (6) Quality Measures (including 1 Outcome Measure) ***** Base Score + add'l measures to increase Performance Score 2 High or 1 High & 2 Med or 4+ Med
  • Partial and Full participation requires that no fewer than six (6) Quality measures be submitted, of which, one (1) must be an Outcome measure, which is defined as a high-priority measure, appropriate-use measure, patient safety, efficiency measures, or care coordination.

Data Submissions

Don’t forget, MIE is a certified Data Submission Vendor, capable of submitting quality performance data on behalf of enrolled providers. MIE does not automatically enroll providers into incentive programs (including previous participants). Therefore, to participate, simply fill out a 2017 Quality Data Submission Authorization and Agreement. This must be on file for each provider interested in submitting their quality performance data through MIE.

We understand how important this is, so we have our Project Manager available to walk you through the enrollment process and work closely with your practice administrator(s) to prepare for data submission. Questions and concerns regarding MIPS, the enrollment process, and participation, or any completed Enrollment Agreements/Authorizations can be emailed to Theresa Juillerat, at tjuillerat@mieweb.com.

Questions

If you have general questions, or you are still unclear about MIPS and its requirements, review the MIPS Fact Sheet, or send us your questions. If you would rather, call us with any concerns. MIE Helpdesk is available 24 hours a day, every day, and can be reached via email at support@mieweb.com, or by telephone, at (260) 459-6270, Option 1, or even toll free, at 1-888-498-3484, Option 1.

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