Merit-based Incentive Payment System
The Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) replaced the Sustainable Growth Rate (SGR) and created the Merit-based Incentive Payment System (MIPS).
Extreme and Uncontrollable Circumstances Policy for MIPS Clinicians in 2017 - 12/6/2017
As part of the Quality Payment Program (QPP) Year 2 final rule, which was released on November 2, 2017, CMS issued an interim final rule with comment period, which includes the Extreme and Uncontrollable Circumstances policy for the transition year of MIPS. This policy specifically addresses extreme and uncontrollable circumstances for the MIPS Advancing Care Information, Quality, and Improvement Activities performance categories in 2017. (It does not apply to the Cost performance category since it has a 0 percent weight in 2017.)
Who does this policy apply to?
Under this policy, if you’re a MIPS eligible clinician who has been affected by Hurricanes Harvey, Irma, or Maria, or the Northern California wildfires:
- You do not need to submit an application to reweight the performance categories; CMS will be able to identify you based on the information in the Provider Enrollment, Chain and Ownership System (PECOS).
- You will automatically receive a neutral MIPS payment adjustment, unless you choose to submit data for any of the MIPS performance categories, in which case you will be scored based on the data you submitted.
Note, this automatic extreme and uncontrollable circumstances policy only applies to you if you’re a MIPS eligible clinician in an affected area. It does not apply to MIPS eligible clinicians in MIPS Alternative Payment Models (MIPS APMs) in 2017 (such as the Medicare Shared Savings Program).
To learn more about the policy, view the interim final rule with comment period and the Extreme and Uncontrollable Circumstances Policy for MIPS in 2017 Fact Sheet (found on the right-hand side).
Contact the QPP Service Center for questions at 1-866-288-8292 (TTY 1-877- 715- 6222), Monday through Friday, 8:00 AM-8:00 PM Eastern time or by email at: QPP@cms.hhs.gov.
Quality Payment Program (QPP) Hardship Exception Application for the 2017 Transition Year is Now Open
The QPP Hardship Exception Application can be found on the QPP website. MIPS eligible clinicians (ECs) and groups may qualify for a reweighting of their Advancing Care Information (ACI) performance category score to 0% of the final score, and can submit a hardship exception application, for one of the following specified reasons:
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances
- Disaster (i.e., natural disaster in which the Certified EHR Technology (CEHRT) was damaged or destroyed)
- Practice or hospital closure
- Severe financial distress (bankruptcy or debt restructuring)
- EHR certification/vendor issues (CERHT issues)
- Lack of control over the availability of the CERHT
In addition to submitting an application via the QPP website, ECs may also contact the QPP Service Center and work with a representative to verbally submit an application.
To submit your application, you will need:
- Taxpayer Identification Number (TIN) for group applications or National Provider Identifier (NPI) for individual applicants;
- Contact information for the person working on behalf of the individual clinician or group, including first and last name, e-mail address, and telephone number; and
- Selection of the hardship exeception category (listed above) and supplemental information
Applications will be processed on a rolling basis. Once an application is submitted, a confirmation email will be sent out to indicate status as pending, approved or dismissed.
You may contact the QPP Service Center by calling 1-866-288-8292 or TTY: 1-877-715-6222. You may also email them at QPP@cms.hhs.gov.
Academy Submits Comments on Episode-Based Cost Measures
On April 24, the Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) on CMS' Request for Information on Episode-based Cost Measure Development for the Quality Payment Program (QPP). CMS will incorporate cost measures into the cost performance category for MIPS for 2018 reporting. You can read the Academy's comment letter here
CMS Announces Initiative to Support Small Practices with MIPS Reporting
The Centers for Medicare & Medicaid Services (CMS) is offering small practices with 15 or fewer clinicians, including those in rural locations, health professional shortage areas, and medically underserved areas, support for reporting under MIPS in 2017. CMS has identified experienced local organizations that can help clinicians with the following:
- Selecting and reporting appropriate measures and activities under each MIPS performance category
- Engage in practice improvement
- Optimize their Health Information Technology (HIT)
- Evaluate options for joining an Advanced Alternative Payment Model (APM)
You can find the contact information for local technical assistance organizations and addtional resources here
Preparing for MIPS: HP Update Podcasts Released
The HP Update podcast features discussions on MIPS reporting in 2017, providing insights into how practices are preparing for the new program. 3P leaders, Robert Lorenz, MD, and Jane Dillon, MD, discuss the details of 2017 MIPS reporting requirements while Lance Manning, MD, explains how his private practice is preparing for MIPS.
You can listen to the podcasts here.
Academy Comments on MIPS and APM Final Rule
On December 19, the Academy submitted comments to Centers for Medicare & Medicaid Services (CMS) in response to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Final Rule. The Academy commented on the reduced reporting requirements for the transition year; MIPS performance category criteria and scoring; Qualified Clinical Data Registry (QCDR) and quality measure reporting requirements; and applicability of APMs to Otolaryngologists - Head and Neck Surgeons. Access the comments.
Academy Factsheets on the New MIPS and APM Programs
To assist Members with MIPS and APM reporting, the Academy has created fact sheets providing an overview of each program including MIPS reporting categories and Advanced APM eligibility criteria.
Starting January 1, 2017 eligible clinicians (ECs) will report under MIPS. Unless they qualify for an exemption, do not meet the minimum reporting threshold, or are part of an Advanced APM, all physicians, physician assistants, nurse practitioners, clinical nurse specialists, or certified registered nurse anesthetists who bill Medicare are considered ECs and must participate in MIPS.
For the 2017 reporting period, clinicians have the option to pick their pace with three reporting periods for MIPS:
- Test Pace: Report some data in 2017.
- 1 quality measure, or 1 improvement activity, or 4/ 5 required advancing care information (ACI) measures.
- Partial MIPS Reporting: Report one or more MIPS performance categories for at least 90 consecutive days in 2017 (must begin reporting by October 2, 2017).
- 1+ quality measure, or 1+ improvement activities, or 4/ 5 required ACI measures
- Full MIPS Reporting: Report all MIPS categories for at least 90 consecutive days in 2017 (must begin reporting by October 2, 2017).
ECs will report on three categories that will add up to a composite performance score (CPS). The CPS will be used by CMS to determine whether or not an EC will receive a bonus payment or will be subject to a payment reduction. The 2019 payment adjustments will be based on 2017 reporting. Learn more about the MIPS program here.
MIPS Payment Update Table
2019 (based on 2017 reporting)
2020 (based on 2018 reporting)
2021 (based on 2019 reporting)
2022 (based on 2020 reporting)
2023 (based on 2021 reporting)
2024 (based on 2022 reporting)
2025 (based on 2023 reporting)
- 60% of the total score in year 1 (CY 2019, based on 2017 reporting).
- Learn more here.
- 25% of the total score in year 1 (CY 2019, based on 2017 reporting)
- Learn more here.
- 15% of the total score in year 1 (CY 2019, based on 2017 reporting).
- Learn more here.
- 0% of the total score in year 1 (CY 2019, based on 2017 reporting).
- Learn more here.