LUTZ BUSINESS INSIGHTS
Provider Quality Reporting System (PQRS) + Merit Based Incentive Payment System (MIPS) Transition Update
JULIANNE KIPPLE, HEALTHCARE DIRECTOR
CMS provided an update in late January 2017 on the transition from PQRS to MIPS, which included a summary of the last year of reporting timelines for PQRS and the new reporting requirements for MIPS.
As noted above, 2016 was the last year of PQRS. If eligible providers do not complete the reporting requirements for 2016, there will be a negative payment reduction to all Medicare Part B Physician Fee Schedule services rendered in 2018. The reduction will be 2% for 2-9 Eligible Professionals (EPs) and 4% for groups with 10 or more EPs. In order to avoid the payment reductions in 2018, groups must report their 2016 activity through the PQRS system. These deadlines are quickly approaching as summarized below. Please note there are various requirements to have ability to file through the various methods below, so verify which requirements apply to you.
- The claims-based reporting mechanism has already ended as of 12/31/2016.
- Qualified Registry data submission period is from 1/3/2017 to 3/31/2017.
- Electronic Reporting data submission period is from 1/3/2017 to 3/13/2017.
- Quality Reporting Document Architecture data submission period is from 1/3/2017 to 3/13/2017 (XML only 3/31/17)
- Web Interface data submission is from 1/16/2017 to 3/17/2017.
The 2017 calendar year is the first performance measurement year for the MIPS system. During 2017, providers should collect data on quality measures and how technology is being used in the practice. By March 31, 2018, the data will need to be submitted to potentially earn a positive payment adjustment that would take place during 2019.
The MIPS program consists of the four performance categories listed below with the corresponding 2017 associated weights.
- Quality – 60% (replaces the PQRS method)
- Cost – 0%
- Improvement Activities – 15% (examples include increasing access, shared decision making, coordinating care)
- Advancing Care Information – 25% (replaces the EHR Incentive Program/Meaningful Use)
The cost category is not part of the positive payment adjustment in 2017. However, – CMS will be collecting data in this category which will be part of the payment calculation in future years.
For 2017 the payment calculation will rate each category above times their associated weighting and then add them together. That total will be multiplied by 100. The result will be rated on a scale of 0-100. Seventy points and above will earn the highest positive payment adjustment, 4-69 points will still yield a positive payment adjustment but not the highest possible, 3 points is a neutral payment adjustment, and 0 points will be a negative payment adjustment of 4%.
There are certain MIPS exceptions for small and rural providers, including reduced reporting requirements for the improvement activities category and increased ability for CAH, RHC, and FQHCs to qualify as a Qualifying APM Participant.
If your group is looking for assistance with the programs, there are organizations that have been funded by CMS. Great Plains Quality Innovation Network serves providers in Kansas, Nebraska, North Dakota and South Dakota with the MIPS program. http://greatplainsqin.org/
Source: CMS, MLN Connects – National Provider Call. Physician Quality Reporting System (PQRS) to the Merit- Based Incentive Payment System (MIPS). Carol Jones & Molly MacHarris. January 24, 2017.
ABOUT THE AUTHOR
JULIANNE KIPPLE + HEALTHCARE DIRECTOR
Julianne Kipple is a Healthcare Director at Lutz with over 10 years of professional experience in the healthcare industry. Her expertise is in accounting and consulting services for healthcare facilities, including outsourced CFO services, Medicare and Medicaid reimbursement, and Medicaid Disproportionate Share Surveys (DSH).
AREAS OF FOCUS
- Healthcare Accounting & Consulting
- Medicare & Medicaid Reimbursement
- Outsourced CFO Services
- Medicaid Disproportionate Share Surveys (DSH)
- Financial Support Services
AFFILIATIONS AND CREDENTIALS
- Healthcare Financial Management Association, Member
- American Institute of Certified Public Accountants, Member
- Nebraska Society of Certified Public Accountants, Member
- Certified Public Accountant
- Certified Healthcare Financial Professional
- BSBA in Accounting, with high distinction, Creighton University, Omaha, NE
- MBA, Creighton University, Omaha, NE
- External Financial Statement Audit + Medicare Cost Report Best Practices
- Year-End Audit and Cost Report Planning, Preparation Tips
- Medicare Cost Report Electronic Filing
- Attention Kansas CAH's - Upcoming DSH Surveys
- Flex Monitoring - CAH Financial Indicators Released
- Provider Quality Reporting System (PQRS) + Merit-Based Incentive Payment System (MIPS) Transition Update
- CMS Medicare Outpatient Observation Notice (MOON) Form
- Hospital Board of Director Responsibilities
- Not-For-Profit Net Asset Classification Changes
- Healthcare Revenue Recognition & Self-Pay Contracts
- Changes in Accounting for Leases + the Impact on Healthcare Entities
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