MIPS Quality Payment Program 2017 Participation & Consideration

Important takeaways for your office regarding Merit-based Incentive Performance System (M.I.P.S.) meaningful use (formerly PQRS & EHR) starting January 1, 2017.   Printable View Printable View

Exciting news for many for small/medium sized offices! You will no longer be penalized by bureaucracy. EHR certification is no longer mandatory and even better is the addition of a participation threshold that removes this Meaningful Use burden from many practitioners.

M.I.P.S. explained – click image for more info

  1. Simply put M.I.P.S. (formerly PQRS, EHR, Meaningful Use, etc) incentives and penalties do not apply to many offices/Drs. This includes new Medicare practitioners and offices/Drs who treat less than 100 unique Medicare patients per year AND bill $30,000 to Medicare based on the Medicare allowed amounts. You can run the M.I.P.S.report in ChiroPulse to see if you met that threshold over the past few years to help determine if M.I.P.S. applies to your office in 2017.
  2. PQRS reporting ends 12/31/2016 so report thru 12/31/16 as it effects 2018 payments.
  3. Merit-based Incentive Performance System (M.I.P.S.) reporting/collecting starts 1/1/2017 (MIPS is a formula that includes Quality Measures, Cost, Improvement Activities & Advancing Care Information (EHR use) and possible payment adjustments begin 2 years later.
  4. EHR certified software & use is no longer directly rewarded, nor are you penalized for not using EHR certified software. EHR use counts for a portion of your MIPS score (25%) but you can still gain an incentive payment if your score is 70 or above which is attainable with the other three components. You can submit a hardship application to Medicare to opt out of EHR Certified software utilization via simple explanations (such as ChiroPulse office software not being EHR certified 2017) and have that portion of your score assigned to one of the other areas. The important takeaway is that the simple lack of EHR software certification & 100% meaningful use does not cause financial penalty to your office.

To participate in M.I.P.S. assuring 2017 and avoid the 4% penalty in 2019 (IF APPLICABLE) simply do one of the following:

  • Test Pace Report – simply submit one (1) PQRS (pain or assess) Quality Measure from ChiroPulse in 2017 or track one improvement/new measure (more info on this coming soon). This avoids penalty but does not allow incentives (possible positive % adjustments).
  • Partial Year Report – for 90-days in 2017 to be eligible for a possible small positive payment adjustment. You must begin by 10/1/2016 to qualify for partial reporting and then begin full submission by 3/31/2018.
  • Full Year Report – on 1/1/2017 start all reporting for the full calendar year to avoid penalty and qualify for a possible maximum positive payment.

If you do not meet the 100 unique patients & $30,000 allowed amount Medicare invoicing in 2017:

  • You simply do nothing and receive the neutral payment without penalty or incentive.
  • Review 2018 eligibility.
  • You can optionally Report either the Test, Partial or Full track without incentive or penalty.

Clinicians are Excluded from M.I.P.S Participation (neutral payments, no penalty or incentive) if any one these apply:

  1. Clinician is newly Enrolled in Medicare in the performance period (i.e. 2017).
  2. Below the low-volume threshold (does not treat 100 unique Medicare patients AND invoice $30,000 in allowed amounts to Medicare).
  3. Significantly Participating – receive 25% of your overall payments from Medicare or see 20% of your Medicare patients through an Advanced APM

click picture for more info at https://qpp.cms.gov