TriumpHealth MIPS Compliance Consulting Solutions

How does MIPS work?

Traditional MIPS, which started in the first year of the Quality Payment Program, is the first way for MIPS eligible clinicians to collect and report data to MIPS. It measures how well you do in 4 areas: quality, improvement activities, promoting interoperability, and cost.

What are MIPS reporting options? Are you required to report?

Clinicians who are required to report for MIPS will need to submit certain performance measures related to quality, promoting interoperability and improvement activities. Based on their performance, eligible clinicians will receive a negative or positive payment adjustment to their Medicare reimbursements. As rules and regulations are being continually updated and changed it becomes very burdensome for a practice or healthcare organization to stay abreast with the ever-changing requirements.

Who has to report MIPS?

According to the Centers for Medicare and Medicaid Services (CMS), clinicians who are eligible to report MIPS include:

• Physicians (MD/DO)
• Dentists (DDS/DMD)
• Nurse Practitioners (NP)
• Physician Assistants (PA)
• Clinical Nurse Specialists (CNS)
• Certified Registered Nurse Anesthetists (CRNA)

Additionally, physical or occupational therapists, speech-language pathologists, audiologists, clinical psychologists, certified nurse-midwives, and registered dietitians or nutrition professionals may also be required to participate in MIPS if they meet certain eligibility criteria.

It is important for all clinicians to understand if they are required to report MIPS and what is expected of them in order to avoid penalties and potentially earn bonuses.

CMS provides a tool on their website called the QPP Participation Status Lookup Tool, which allows clinicians to check their participation status for each performance year. Clinicians can also contact their Medicare Administrative Contractor (MAC) for more information on their specific MIPS reporting requirements.

What are the criteria for participating in MIPS?

To be eligible to participate in MIPS, clinicians must meet certain criteria set by CMS:

• Have an active National Provider Identifier (NPI)
• Bill Medicare Part B
• Exceed at least one of the following thresholds:
  • $90,000 in Medicare Part B allowed charges for covered professional services
  • Provide care for more than 200 Medicare patients
  • Provide at least 200 covered services
• If a clinician meets all of these criteria, they are considered eligible to participate in MIPS and must report data on their performance measures to CMS. However, there are certain exemptions and special circumstances that may apply to some clinicians. It is important for clinicians to review their specific eligibility requirements with CMS or their MAC.

How is MIPS data reported?

MIPS data can be reported in various ways, including through qualified registry, electronic health record (EHR) vendor, or directly to CMS. Clinicians must report data for a full calendar year by the deadline set by CMS each year.

CMS provides a list of approved MIPS Registry vendors and EHR vendors on their website. These vendors have been vetted and are considered reliable for reporting MIPS data accurately and securely.

Clinicians should carefully review the reporting requirements and options available to them in order to determine the best method for reporting their MIPS data. It is also important to stay updated on any changes or updates made by CMS to reporting requirements.

Are any providers exempt from MIPS? What are the exclusions from MIPS?

Yes, there are certain providers who may be exempt from participating in MIPS. These include:

• Newly enrolled Medicare providers (less than one year)
• Providers significantly participating in an Advanced Alternative Payment Model (APM)
• Providers with low-volume thresholds (less than $90,000 in Medicare Part B allowed charges., provide less than 200 covered services or fewer than 200 Medicare patients)
• Hospital-based clinicians

These exemptions are based on the type of practice and level of participation in alternative payment models. CMS determines these exemptions each year and updates them as needed. It is important for clinicians to review their specific eligibility requirements with CMS or their MAC in order to determine if they are exempt from MIPS reporting.  Overall, these exemptions help ensure that only eligible clinicians who meet certain criteria are required to participate in MIPS and report data on their performance measures. This is meant to make the program more manageable for providers and allow them to focus on providing quality care to patients without additional regulatory burdens.

MIPS Eligibility and Participation Options

The MIPS program has three reporting options for eligible clinicians:

1. Individual Reporting: Eligible clinicians can report as individuals and have their performance measured based on their individual data.
2. Group Reporting: Eligible clinicians can join with other practitioners in a group practice to report MIPS data collectively as a group.
3. Virtual Group Reporting: This option allows solo practitioners or groups of up to 10 eligible clinicians to form “virtual groups” and participate in MIPS together.

Each reporting option has its own set of rules, requirements and benefits. It is important for eligible clinicians to carefully consider which option is best suited for their practice before making a decision.

How can participating in MIPS benefit a clinician?

Participating in MIPS can bring several benefits for clinicians, including:

• Avoiding penalties: Eligible clinicians who do not participate or fail to meet reporting requirements may face penalties through negative payment adjustments. By actively participating and reporting MIPS data, clinicians can avoid these penalties.
• Potentially earning bonuses: Eligible clinicians who successfully report MIPS data may be eligible to earn positive payment adjustments as a reward for their efforts in improving healthcare quality.
• Improving healthcare quality: The goal of the Quality Payment Program is to improve the overall quality of healthcare by promoting value-based care. By participating in MIPS and accurately reporting data, clinicians can contribute to this effort and ultimately provide better care for patients.
• Staying ahead in the industry: As value-based care continues to grow, participation in programs like MIPS can help clinicians stay up-to-date with industry trends and demonstrate their commitment to providing high-quality care.

Overall, participating in MIPS can bring several benefits for clinicians and ultimately contribute to the improvement of healthcare quality.  By meeting reporting requirements and actively engaging in improving healthcare value, clinicians can position themselves as leaders in the industry and provide better care for their patients.  It is important for eligible clinicians to understand their participation status and reporting requirements in order to take advantage of these potential benefits.

What is the MIPS 2024 threshold?

The performance threshold represents the minimum score that an eligible clinician must achieve to avoid a negative payment adjustment. In MIPS 2024, this threshold continues to stay at 75 points, just like 2023. However, CMS has proposed to raise the passing threshold to 82, though they do not have an exact date for that change.

This potential increase reflects CMS’s efforts to continuously raise the bar for quality and cost performance in healthcare. It also means that clinicians will need to put more effort into meeting these higher thresholds to avoid penalties.

How do I get started reporting MIPS?

Speak to our MIPS Consultants here at TriumpHealth to learn more about the MIPS program.