MIPS reporting in 2018

By Rachna Chaudhari, MPH, director of practice management, February 1, 2018

After requiring dermatologists to report one measure one time in 2017 to avoid a 4% penalty in 2019, Medicare has raised the stakes and the requirements in 2018. Most dermatologists will report via the Merit-based Incentive Payment System (MIPS) program to avoid the 5% penalty or obtain up to 5% in incentives in 2020. It is important to remember that there is a two-year gap between reporting and receiving the payment adjustment; therefore, what you report in 2018 will impact your Medicare Part B payments in 2020.

Are you exempt?

MACRA does allow physicians to be excluded from the program entirely if you meet one of the following criteria:

• See less than 200 Medicare Part B patients per year

OR

• Have less than $90,000 in Medicare Part B allowed charges per year

You can look up whether you are exempt at https://qpp.cms.gov/. If you are, you will not receive the 5% penalty in 2020 nor be eligible for an incentive. Your reimbursement rate from Medicare Part B in 2020 will stay the same. You should note that your exemption does not hold for future years. You must check every year to determine if you are exempt from the program.

Simply avoid the 5% penalty in 2020

If you are not exempt from the MIPS program, are in a practice of 15 providers or less, and only want to avoid the 5% penalty, you have several options to report. The MIPS program is scored out of 100 possible points, and you have to achieve 15 points to simply avoid the penalty. You can achieve 15 points by reporting ONE of the following options in 2018:

• Five quality measures at least one time each*

OR

• One high-weighted improvement activity

OR

• Base score measures of the advancing care information (ACI) category on at least one patient PLUS integration with DataDerm (staging.aad.org/dataderm). (Base score measures include performing a security risk analysis, electronic prescribing, providing access to a patient portal, and health information exchange.)

*Note, the Academy strongly recommends practices report more than one time as an insurance policy in the event of submission issues or inaccuracies. Failure to correctly report in 2018 will result in a 5% penalty in 2020.

Please note, these criteria are for practices of 15 providers or less — which comprises the majority of dermatology practices. If you have more than 15 providers, you will be expected to perform more measures on more patients.

If you do not have electronic health records (EHR) in your office, you should report either the quality measures or the improvement activity.

Reporting quality measures

You can report some quality measures through claims, but the vast majority of quality measures are only reportable through a registry like DataDerm™ (staging.aad.org/dataderm) or via EHR. If you are interested in the quality measure option, see a full list of dermatology-specific quality measures.

Reporting improvement activities

If you prefer not reporting quality measures, you can also review the list of dermatology-applicable practice improvement activities and choose one activity to report in 2018 to avoid the 5% penalty which will be applied in 2020. Please note to report, you would have to attest to completing the activity through a registry like DataDerm or your EHR. You cannot simply perform the activity and not report — it otherwise it won’t count.

Reporting advancing care information

If you have an EHR, you can instead choose to report the ACI base score measures either through DataDerm or your EHR vendor; check both options as you may find reporting via DataDerm is less expensive. These measures only have to be performed on one patient and integrating your EHR to DataDerm would be the most beneficial way to report. 

Obtain a small incentive in 2020

If you want to obtain a small incentive in 2020, you would need to achieve above 15 points. You can choose to report ONE of the following options in 2018 for the full year to obtain anywhere from 16 to 70 points out of the possible score of 100 points:

• Report at least two quality measures on all of your eligible patients

OR

• Base score measures of the advancing care information (ACI) category PLUS integration with DataDerm PLUS at least one ACI performance measure

OR

• One of the above PLUS one high-weighted improvement activity

Again, you must report this through a registry like DataDerm or an EHR. Your incentive would most likely be small, around 0.5% of Medicare Part B payments in 2020 or less.

Obtain the maximum incentive (up to 5%) in 2020

If you are trying to be a top performer in 2018 and expect to earn a high incentive, you must score at least 70 points. You can choose to report ALL of the following for the full year to achieve this goal:

• Report 6 quality measures on all of your eligible patients
• One high-weighted improvement activity
• Base score measures from the ACI category

At a minimum, you must report 6 quality measures on at least 60% of ALL your patients during 2018 (not just Medicare patients), however if you want to achieve the maximum points possible you should aim to report on 100% of your eligible patients as each quality measure has a benchmark score and most require a 100% reporting rate to achieve the full 10 points per measure.

Additional changes from 2017

Cost

One of the major changes from 2017 MIPS reporting is that cost is a new category in MIPS reporting for 2018. The new structure of points is as follows:

1. Quality 50%
2. Improvement Activity 15%
3. Advancing Care Information 25%
4. Cost 10%

CMS will evaluate dermatologists on cost through their claims data, and you as a provider will not submit anything. Your score in this category will be calculated by CMS based on total cost of care for attributed beneficiaries. If you score zero in this category, you would still be able to avoid the penalty or apply for the incentive as described above.

Small practices

CMS has provided additional incentives to small practices, which are defined as 15 providers or less. You receive five bonus points for being a small practice and submitting at least one data point. Additionally, if you are in a small practice without EHR, you can apply for a hardship exemption and have your ACI score re-weighted to zero. This allows you to have your quality score count for more — 75 points, so you can potentially earn the maximum incentive even without an EHR.

Extreme and uncontrollable circumstances hardship

If your practice was affected by the recent wildfires in California or Hurricanes Irma, Harvey, or Maria, you can also be entirely exempt from the MACRA program in 2017. You do not need to file any application as CMS will automatically prevent you from receiving the penalty. If you still cannot report in 2018 due to these circumstances, you can file a hardship application before Dec. 31, 2018, and be exempt from the penalty in 2020. 

Additional DermWorld Resources