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Are you ready for submitting MIPS 2019 Data?

It’s that time of the year again! MIPS data submission season is upon us. CMS is reminding physicians that the data submission period for 2019 Merit-based Incentive Payment System (MIPS) data is now open. Clinicians must attest by March 31, 2020, at 8 PM EDT to avoid a -5% payment adjustment in 2020!

For the 2020 payment year, which is based on 2018 data, eligible clinicians needed to report on a full year’s worth of quality data, and CMS increased the performance threshold to 15 points for providers to avoid the 5% penalty, applied to payments in 2020. Beginning in the 2021 performance period, the new MIPS Value Pathways (MVP) participation framework will seek to overhaul MIPS reporting to reduce the burden and make the program more meaningful for participating clinicians and patients.

To learn more about how your organization can succeed in, make sure to attend our on-demand webinar, ‘Getting Ready for Submitting Y2019 MIPS Data’. iPatientCare will walk you through the steps to successfully complete your submission. The session will provide you with the necessary information, and steps to get you from preparation for data submission.

Recap of MIPS 2019 requirements

MIPS 2020 is here. It may seem too soon, as some clinicians are still finishing their reporting for the MIPS 2019 performance year. However, the time has come. The Quality performance category requires clinicians to report a full year’s worth of data. So, the sooner providers start, the better.

To help you get going quickly, we’ve summarized the biggest changes to the MIPS 2019 Final Rule.

The biggest changes in 2019 were:
1. Quality score reduced from 50% to 45%
2. Cost score increased from 10% to 15%
3. Improvement Activities: Interoperability bonus removed
4. Eligible clinicians must use 2015 edition or newer certified EHR technology
5. Performance Threshold minimum increased from 15 to 30 points. Exceptional Performance Range is at least 75 points.

Eligible Clinicians for 2019

  • Physicians, including doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry; osteopathic practitioners; and chiropractors
  • Physician Assistants
  • Nurse Practitioners
    • Clinical Nurse Specialists
    • Certified Registered Nurse Anesthetists
  • Clinical Psychologists
    • Occupational Therapists
    • Qualified Speech-Language Pathologists
    • Qualified Audiologists
    • Registered Dieticians & Nutritionists

Participation Requirements for 2019

Providers had to:
1) accumulate $90,000 in Medicare Part B allowed charges,
2) See more than 200 Part B patients, and
3) Provide 200 or more covered professional services to Part B patients

Payment Adjustment for 2019

  • MIPS-eligible providers stand to lose up to 7% of their Medicare reimbursements in 2021 for lack of participation.
  • Participating providers stand to receive up to 7% in bonus Medicare reimbursements in 2021.
  • Bonuses: Small practices (of 15 or less clinicians) earn 6 bonus points in the Quality category if they submit data for at least one Quality Measure.
  • Penalties: Providers need a final MIPS score of 30 to avoid a negative payment adjustment.

Preparing your data for submission

Preparing to submit your data may be as complicated as the MIPS program itself! There are so many decisions to make and things to do before you are ready to attest.

If you don’t believe it, these are some of the high-level questions you should be asking yourself:

1. Do I need to submit MIPS data?

  • Are you excluded?
  • Are you considered a Qualifying Participant (QP) in an Advanced Alternative Payment Model (AAPM)?
  • Are you a part of a MIPS Alternative Payment Model (APM) that will submit data on your behalf?

2. Do I have to attest as an individual or a group?

  • If you report MIPS data in as an individual, your payment adjustment will be based only on your performance. An individual is defined as a single National Provider Identifier (NPI) tied to a single Taxpayer Identification Number (TIN).
  • If you report MIPS data as a group, your payment adjustment is based on the group’s A group is defined as a set of clinicians—identified by their NPI—sharing a common TIN, no matter the specialty or practice site. Keep in mind, if you are individually excluded, and yet your TIN is submitting MIPS data as a group, you will no longer be excluded and will need to submit MIPS data as part of the group submission. This is a decision to think carefully about.

Are you Audit-prepared?

You must be thinking that you are ready to enter your data now, right? NOT SO FAST! One mistake practices often make is to forget to prepare an audit folder. CMS can request an audit up to 7 years after you submitted your data! If you don’t know what to have on file, our MIPS expert will provide the documentation tips, which would be very helpful.

Join us to learn more about MIPS submission and make sure you’re prepared to successfully take on 2020.

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