It's the last quarter of MIPS performance year 2019: Do you have a game plan?
Answers in Practice
Faiza Wasif, MPH, is the AAD's practice management manager. Her column offers tips on an area she commonly receives questions about from members.
By Faiza Wasif, MPH, October 1, 2019
Another performance year for the Merit Based Payment System (MIPS) program is almost over — only about 90 days remain. At this point, if you haven’t already started collecting data, at the very least you should know the following:
Are you required to participate?
Be sure to check your participation status by using the QPP participation look-up tool. Enter your NPI. Review your results. If you do not have to participate, keep a copy of the results on file and breathe a sigh of relief. If you do have to participate, determine next steps.
What outcome do you want after participation? Are you just trying to avoid that 7% penalty or still thinking about going for that incentive? Check the chart below for a quick reminder of the basic 2019 reporting options.
As you can see, you must do more this year than years past to achieve any outcome. Avoiding the penalty isn’t as simple as reporting just one quality measure or even reporting a few quality measures. This year you’ll have to either engage in improvement activities, or if you have an EHR, opt to attest to measures in the promoting interoperability category. Additionally, in order to satisfy the requirement for either one of those categories, you must start no later than Oct. 2, 2019, so you meet the minimum criterion of 90-consecutive days of engagement.
An additional resource that can help you plan for this year is your MIPS 2018 performance feedback, available at the QPP site. The feedback includes your final score, your 2020 payment adjustment (since the adjustment is applied two years after the performance year), and your final performance category scores and weights. You can use this to determine where you performed well and where you may want to increase engagement this year.
Still having trouble deciding what to do? Consider this: The expected maximum incentive is predicted to be less than the 1.88% paid out for MIPS 2017 participation because the program needs to be budget neutral. In fact, some predictions — based on available CMS data for MIPS 2017 and 2018 participation — indicate that the maximum incentive may decline to 1.68%. For some that may not be enough return on investment. However, it may still be worthwhile to engage at a higher level so that you are better prepared for the future years of MIPS when the penalty will go as high as 9%. It will be impossible to avoid the penalty without participating in one or two additional MIPS categories going forward.
Last, the AADA Practice Management Center has an easy, step-by-step guide and interactive tools to help you understand the MIPS program and outline your strategy for success.
