The Centers for Medicare and Medicaid Services (CMS) deemed 2017 a transition year for MIPS, allowing participating clinicians to “pick their pace.” To avoid a penalty in 2020, clinicians will have to report more quality information in 2018.
CMS finalized a performance threshold of 15 points for the 2018 performance period, an increase from the threshold of three points required in the first year of the program. Providers can reach the 15-point threshold through multiple pathways, many of which only require partial MIPS reporting. For instance, small practices could reach the performance threshold by reporting just three quality measures or one quality measure and one medium weighted improvement activity along with receiving the five-point small practice bonus. Any physician or practice could submit the maximum number of improvement activities and reach the 15-point threshold because the improvement activities performance category is worth 15 percent of the final score.
Scoring between 15 points and 69 points will allow a clinician to avoid a negative payment adjustment and may provide a slight positive payment adjustment.
The additional performance threshold for exceptional performance will remain at 70 points, the same as for the transition year. A provider whose MIPS score reaches 70 points or above will receive an additional, escalating positive adjustment ranging between 0.5 percent and 10 percent.
It is important to note that for the quality and cost categories CMS is requiring a full calendar year reporting period for 2018. However, no quality data is reported for the cost category; CMS extracts the information from claims. The performance period for improvement activities and advancing care information is a minimum of a continuous 90-day period within the calendar year up to and a full year as a maximum.
Clinicians may choose to report all of the required data for a full year. To learn what the requirements are for each performance category, refer to the chart in the “How do clinicians report their data?” question below.
Please note: Not participating in the QPP or scoring below 15 points for 2018 will result in a negative 5 percent payment reduction in 2020.