This FAQ is an attempt to explain the key aspects of MIPS along with a brief explanation of Improvement Activities and Promoting Interoperability Category as updated for the 2019 performance year, both for those new to the program as well as those with previous experience and familiarity with the 2018 MIPS rule.
What is MIPS and how it has evolved over the years?
The Merit-based Incentive Payment System (MIPS) track has replaced three previous quality programs such as Medicare Electronic Health Records (EHR) Incentive for Eligible Clinicians, Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier (VBM). It is a performance-based payment system created under MACRA.
How and on what basis CMS will grade you?
CMS will grade you on a scale of 0-100 to determine your payment for providing services. This is known as your Final MIPS Score and is measured by data recorded and reported in four categories:
- Quality Reporting
- Improvement Activities
- Promoting Interoperability
What are the performance category weights for 2019?
- Cost: 15 percent of the final score, up from 10 percent in 2018.
- Quality: 45 percent of the final score, down from 50 percent in 2018.
- Promoting interoperability: 25 percent of the final score, the same as 2018.
- Improvement Activities: 15 percent of the final score, the same as 2018
What are the Improvement Activities?
Improvement activities are activities that improve clinical practice and care delivery that are likely to result in improved outcomes. Here the CMS rewards clinicians for delivering care that emphasizes care coordination, patient engagement, and patient safety.
In 2019, there are 118 improvement activities to choose from that are eligible for MIPS credit.
What improvement activities should you report?
It is likely that you are already fulfilling at least one improvement activity in your practice but may be calling it by a different name. It is recommended that you review the list of 118 improvement activities and select that are most applicable to your practice. CMS will post the data validation and documentation required for each activity for audit purposes on the CMS QPP Resource Library.
Reporting mechanisms depend on the category and your collection type whether you participate as an individual, group, or Virtual Group.
How IA scoring works?
You have to report that you completed one or more out of 118 Improvement activities available in 2019. CMS will divide the sum of the points earned by the provider by 40, the total available points for the category which carries 15% weight towards the final MIPS Score.
What are the options available to the clinician to fulfill the Improvement Activities (IA) requirement?
Clinicians have three options for combinations of activities to fulfill the IA requirement:
- Submit two high-weighted activities
- Submit two medium-weighted activities and one high-weighted activity
- Submit four medium-weighted activities
What is Promoting Interoperability (PI) Category about?
The Promoting Interoperability category (formerly the Advancing Care Information) is intended to encourage:
Use of certified electronic health record technology (CEHRT) to improve care coordination efforts through health information exchange
- Use of certified electronic health record technology (CEHRT) to improve care coordination efforts through health information exchange
- Increase patient engagement using tools like Patient Portals and sharing information with caregivers, family, and clinicians.
MIPS eligible clinicians report data on objectives and measures that are collected in their certified EHR technology. The weight of Promoting Interoperability category is 25 percent of the Merit-based Incentive Payment System (MIPS) Final Score.
How clinician can fulfill the Promoting Interoperability (PI) requirement?
For the performance year 2019, 2015 Edition CEHRT is required for participation in this performance category. The MIPS PI measures fall under four objectives. Clinicians are required to report measures from each of the four objectives to complete their PI requirements.
- e-Prescribing – Worth 10 percent of PI score
- Health Information Exchange – Worth 20 percent each for sending and receiving information via EHR
- Provider to Patient Exchange – Worth 40 percent of PI score
- Public Health and Clinical Data Exchange – Worth 10 percent for participating in two registries
Participants must submit collected data for certain measures from each of the 4 objectives measures for 90 continuous days or more during 2019.
How you can score the Promoting Interoperability Performance Category?
A physician’s or group’s PI category score will be based on the collective performance of each of the required measures. Physicians must report on all required measures or receive zero points for the entire category.
Every measure will be scored based on the submission of a numerator and a denominator, except for the measures associated with the Public Health and Clinical Data Exchange objective, which require “yes” or “no” submissions. To receive credit for the measures, all measures must have at least 1 in the numerator or answer “yes”.
The scores of these measures will be calculated by dividing the numerator by the denominator and multiplying by the designated weight of the measure. The measures are assigned points similarly to the previous methodology, where performance between 1% and 10% equals 1 point, 11% and 20% equals 2 points, etc. Each measure score is then multiplied by the individual measure’s weight, which varies from measure to measure.
What are the Most Significant Changes to the Promoting Interoperability Performance Category from 2018 to 2019?
For scoring the Promoting Interoperability performance category for 2019, CMS has moved away from the base, performance and bonus score methodology that was used for 2017 and 2018 to provide a simpler, more flexible, less burdensome structure.
How can providers submit their Improvement Activities (IA) & Promoting Interoperability (PI) data?
There are generally five collection type options via which physicians can submit their data:
- Log-In and Attest
- Log-In and Upload
What are the changes for 2019?
- Patient-Specific Education
- Secure Messaging
- View, Download or Transmit
- Patient-Generated Health Data
- The query of the Prescription Drug Monitoring Program (PDMP) (bonus)
- Verify Opioid Treatment Agreement (bonus)
- Support Electronic Referral Loops – Receiving and Incorporating Health Information
Although there is a lot to digest, iPatientCare offers step-by-step guidance through webinars that can explain what participating doctors must accomplish to avoid penalty and earn incentives. In our upcoming webinar, we will walk you through the Key changes in how you will be scored on Improvement Activities and Promoting Interoperability and how to improve your score in these categories. During this webinar, our expert will review the final objectives, measures, and associated weights, along with the challenges of the new scoring approach. We’ll discuss how your practice can plan out the year now to mitigate any potential risk and be successful in Year 3 of the QPP.
Click here for more information about iPatientCare’s MACRA eLearning Series, including additional resources.