Starting with the Merit-based Incentive Payment System (MIPS) can feel overwhelming, especially for small to medium practices. However, by breaking down the process into manageable steps, you can simplify your approach and set your practice up for success. Here’s a comprehensive guide to help you start with MIPS, understand eligibility, select the right measures, and ensure a streamlined process.
What is MIPS and Why Should You Participate?
MIPS is part of the Quality Payment Program (QPP) under Medicare, which adjusts payments based on providers’ performance across four categories. For eligible providers, participating in MIPS is essential to avoid penalties—up to a 9% reduction in Medicare payments—and to potentially receive positive payment adjustments for high scores.
With MIPS, your focus should be on maximizing your score in a way that aligns with your practice’s strengths and resources.
Step 1: Determine Your MIPS Eligibility
Who Needs to Participate?
Start by verifying if you meet the following eligibility criteria:
Billing over $90,000 in Medicare Part B services.
Seeing more than 200 Medicare Part B patients.
Providing over 200 covered professional services to Medicare beneficiaries.
If you meet all three thresholds, you are required to participate. If you meet just one or two, you may be exempt but can opt in voluntarily. Check your eligibility status using the QPP Participation Status Tool to confirm if you’re required to report.
Step 2: Choose Your Reporting Option
MIPS offers flexibility in how you report. Your options include:
Individual Reporting: Report under your unique National Provider Identifier (NPI) and Taxpayer Identification Number (TIN).
Group Reporting: Report as a group under one TIN if you practice with other clinicians, sharing a combined MIPS score.
Virtual Group: If you’re a small practice, you can join with others to form a virtual group, sharing a unified score.
APM Entity Reporting: If you’re part of an Alternative Payment Model (APM), you may be eligible for different reporting requirements.
Each option has advantages and limitations, so consider your practice size, resources, and reporting needs to choose the most appropriate method.
Step 3: Understand the Four MIPS Performance Categories
To succeed in MIPS, familiarize yourself with the four performance categories and how they contribute to your total score:
Quality (30%): Report on six measures that reflect the level of care you deliver. Select measures that align with your specialty and patient population.
Promoting Interoperability (25%): Focuses on the use of certified Electronic Health Record (EHR) technology. Key components include e-prescribing, health information exchange, and providing patient access to health data.
Improvement Activities (15%): Complete activities that enhance clinical practice. Many small practices can satisfy this category with fewer activities than larger practices.
Cost (30%): Cost is automatically calculated based on Medicare claims, so no additional reporting is required. Medicare evaluates cost measures based on the efficiency of care provided.
Each category has a different weight, so understanding where to focus can help you make the most of your efforts.
Step 4: Select the Right Quality Measures and Improvement Activities
Selecting the right measures and activities is essential to achieve a high MIPS score.
Choosing Quality Measures
Align with Practice Strengths: Choose measures that represent areas where your practice excels.
Consider Specialty-Specific Measures: CMS offers specialty measure sets that provide options tailored to specific fields, such as cardiology, orthopedics, or primary care.
Be Aware of “Topped-Out” Measures: Some measures have high national averages, meaning they might earn lower points if you can’t exceed those benchmarks.
Selecting Improvement Activities
Focus on High-Impact Activities: Activities that promote patient safety, care coordination, or population health management are often valuable.
Look for Medium or High-Weighted Activities: High-weighted activities are worth more points, which can help you meet the required 40 points more quickly.
Check for Automatic Reweighting: Small practices often have the advantage of lower thresholds in the Improvement Activities category, making it easier to complete.
Step 5: Choose Your Quality Reporting Method
There are three main methods to submit MIPS data:
Qualified Registry: CMS-approved third-party registries help collect and submit your data.
eCQM (Electronic Clinical Quality Measures): Report directly through your EHR, provided it’s certified for MIPS.
Claims-Based Reporting: Report directly on Medicare Part B claims, typically available to practices with 15 or fewer clinicians.
Consider your practice’s technology, resources, and the level of support you need in choosing the best method.
Step 6: Track Your Performance Throughout the Year
Continuous monitoring is crucial to stay on top of your MIPS goals. Here’s how to keep track:
Use EHR or Registry Dashboards: Many EHR systems and registries offer dashboards to track your progress in each MIPS category, helping you identify areas for improvement.
Check for Measure Updates: CMS occasionally updates measure specifications, so stay informed on any changes to ensure accurate tracking.
Regularly Assess Performance: Monthly or quarterly reviews can give you insights into how well you’re meeting MIPS requirements and allow time to make adjustments.
Step 7: Prepare and Submit Your Data
The MIPS submission period typically begins in early January and ends in late March of the following year. Here’s how to prepare for submission:
Compile Data Accurately: Ensure all quality measures and activities are documented and ready for submission.
Review Submission Guidelines: Familiarize yourself with CMS guidelines to ensure your data meets reporting standards.
Submit Through Your Chosen Method: Submit through your registry, EHR, or directly on the CMS Quality Payment Program (QPP) portal.
Submitting your data on time and accurately can make a big difference in avoiding penalties and securing positive adjustments.
Step 8: Review Your MIPS Feedback and Adjust as Needed
After submitting, you’ll receive feedback from CMS on your performance. Reviewing this feedback is essential:
Analyze Your Score: Identify strengths and areas needing improvement for future MIPS reporting.
Adjust Strategies: Use feedback to refine your approach, whether that means adjusting measure selection or improving specific activities.
Plan for the Next Performance Year: Based on your feedback, set goals for the next MIPS cycle to continuously improve your score.
Getting started with MIPS may seem complex, but with a clear, step-by-step plan, you can simplify the process and maximize your score. By determining your eligibility, choosing the right reporting option, and selecting measures that align with your practice strengths, you’re well on your way to success. Monitoring your progress and adapting based on feedback will ensure your MIPS participation becomes a valuable part of your practice.
Let Premier MIPS Consulting Guide You Through MIPS
Starting with MIPS doesn’t have to be overwhelming. At Premier MIPS Consulting, we help independent providers get started with confidence. From determining eligibility and selecting measures to tracking performance and submitting data, our experts simplify each step, so you get the most out of MIPS with minimal hassle.
Don’t let the complexities of MIPS hold your practice back. Contact Premier MIPS Consulting (803-205-2544) today to ensure a smooth start, avoid penalties, and secure the positive payment adjustments you deserve.
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