Beginning in 2017, Medicare will start measuring performance under the  Merit-Based Incentive Payment System (MIPS) program, as required by Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  Here is what you need to do starting now to prepare for January 2017 to enroll, and be successful.  Remember, what you do only 7 months from now will determine payment adjustments for 2019 and beyond.

Step 1. Determine Eligibility.  If you fall into these buckets, you will be eligible for MIPS:

• Physician (MD/DO/DDM/DDS), PA, NP’s, CNS, CRNA. Note, starting in Years 3, MIPS may be opened up to other clinical groups
• NOT in your first year of Medicare Part B participation (may be a sub bullet as this is an exclusion and it doesn’t match with “fall into these…” language above – the box would not let me say this in a comment
• Above patient threshold. Defined as Medicare billing charges greater than $10,000 and providing care to at least 101 Medicare patients per year
• Certain participants in Advanced Alternative Payment Models (“APM”). If a physician does not meet the threshold for payments and volume under an advanced APM, they can be eligible for the MIPS track. Similarly, any physician in a non-advanced APM may be eligible.

Note: Hospital Employed Physicians Only.  Note that only your Medicare Part B claims will count towards the MIPS program. Services rendered and submitted by the hospital are not eligible.

Step 2. Determine whether you will participate as an individual or with a group.  A group practice would be defined using their tax payer identification number (“TIN”).

Step 3.  Choose which measures you would like to be evaluated on each of the four performance categories and/or understand how the measures are calculated. The four performance categories under the MIPS program are: Quality, Resource Use, Clinical Practice Improvement Activities and Advancing Care Information. Not all measures require additional data submission or measure selection.

TIP:  Be mindful of the category weights (shown in parenthesis below).  In Year 1, Quality measures will be weighed more heavily than the other categories.

Step 3a. Quality Measures (50 % in Year 1).  Select 6 measures from the list of approximately 300 measures. If you do not want to comb through all 300 measures you also have the option to select a pre-defined set of 6 called a specialty measure set. These sets were created using input from specialty associations.

Step 3a1. 1 of the measures must be a cross-cutting measure, if you are a patient-facing clinician

Step 3a2. 1 of the measures must be an outcome measure. If an outcome measure is not available, you would need to select another high priority measure.  High priority measures include outcome measures, appropriate use measures, patient experience, patient safety or care coordination.

Step 3b. Resource Use (10% in Year 1). Understand submission process, no submission is required! CMS will calculate based on claims data. CMS will use 40 episode specific measures that are relevant to each specialty.

Step 3c. Advancing Care Information (“ACI”) (25% in Year 1). Understand how the ACI score is calculated. This category is made up of a base score, performance score and bonus point to calculate the ACI score. If you achieve at least 100 sub-points from base, performance and bonus point scores you will meet the ACI measure and receive the full 25 ACI points.

Step 3c1. Base Score (50 points toward ACI score): To achieve the 50 points respond yes/no or provide a numerator/ denominator for the following ACI measures:

• Select yes or no for the following measures:
  • Protect patient health information
  • Report to public health and clinical data registry
• Provide a numerator/denominator for the following:
  • Electronic prescribing
  • Patient electronic access
  • Coordination of care through patient engagement
  • Health information exchange

Step 3c2. Performance Score (80 points toward ACI score): To achieve the 80 points select from measures in the following categories:

• Patient electronic access
• Coordination of care through patient engagement
• Health information exchange

Step 3c3. Bonus Point (1 point toward ACI score):  To get the bonus point you can report whether you submit data to a public health registry. Because the Immunizations registry is mandatory it does not count towards the bonus point.
Step 3d. Clinical Improvement Activities (15% in Year 1). Select at least 1 measure from the list of approximately 90 measures.

TIP: The more measures you select the more credit you will receive toward this category. If you are a patient centered medical home, you will receive full credit for this category and a minimum of half credit if you are in an APM

Step 4. Stay tuned for more information from Provident on data submission requirements, overall scoring calculations, performance periods and payment adjustments.