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by Antonio Arias, MBA, CHBME

MIPS 101: Understanding the New Merit-Based Incentive Payment System


Just when you got comfortable with every other incentive program - from Meaningful Use of EHRs to the Physician Quality Reporting System (PQRS) to Value Based Modifier payment structures (VBM) - here comes another: MIPS, or Medicare’s new ‘Merit-Based Incentive Payment System.’ The introduction of MIPS may be a blessing for medical practices, since, it merges the other three programs into one.

MIPS emerged thanks to the long-awaited sustainable growth rate (SGR) fix legislation that passed the House of Representatives in March. The program isn’t final, as a variety of changes are expected to be made to the legislation as it makes its way through Congress, but in its current form it’s fairly easy to understand. Here’s what we know so far:

It Measures What You’re Already Reporting: MIPS is designed to award bonuses and impose penalties to physicians based on whether they score above or below certain thresholds on the quality measures currently assessed via PQRS, VBM, and Meaningful Use. The three existing reporting programs will wrap at the close of 2018, though their existing standards will be folded into MIPS’ four new “assessment categories.” (The money from penalties that would have been assessed under the current programs will remain in the Medicare physician fee schedule, increasing total payments compared to the current baseline.)

Its Eligible Professionals (EPs) Are the Ones You’d Expect: Doctors of Medicine or Osteopathy, Dental Surgery or Dental Medicine, Podiatric Medicine, or Optometry will be eligible for inclusion in MIPS come 2019, as will chiropractors, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. Other professionals paid under the physician fee schedule may be included in MIPS beginning in 2021, pending the creation of viable performance metrics. (Professionals receiving a significant portion of their revenues from alternative payment models will be excluded.)

It’s Got Potential to Really Boost Your Revenue Cycle Management: The American Academy of Family Physicians (AAFP) calls MIPS “the first real opportunity for high-performing physicians to earn substantial bonuses, and for all physicians to avoid penalties if they meet prospectively established quality thresholds.” How so? Payments to professionals under MIPS will start in 2019, beginning with 4 to 9 percent “performance improvements payments.” Starting in 2026, physicians participating in MIPS will be eligible for a 0.25-percent annual update in their payments.

It Will Change a Bit Year Over Year: When it comes to Quality (one of the four MIPS assessment categories), the standards to which EPs will be held will be set and published annually. Each year, the Secretary of Health and Human Services will publish through notice and comment rulemaking a list of quality measures to be used in the forthcoming MIPS performance period, and eligible professionals will vote on and select which measures make the final cut.

Working with a medical billing firm may help your practice prepare for MIPS earn incentives under the current Medicare reporting programs. For more information, contact NGC Medical Billing.

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by Antonio Arias, MBA, CHBME

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