Merit-Based Incentive Payment System FAQs
Answer: The Quality category of MIPS replaces the PQRS program. The difference between PQRS and MIPS is the change in reporting requirements. The process of collecting data remains the same.
Answer: Clinicians should report on all patients or encounters (including Medicare Part B and non-Medicare Part B) based on the CMS measure specifications for the denominator population and report on at least 70% of those patients in the numerator.
Answer: Measure groups are no longer a reporting option under MIPS.
Answer: 6 measures need to be reported on, of which one must be an outcome measure; if no outcome measure is applicable, then one high priority measure can be reported instead. Alternatively, eligible clinicians can choose to report measures in a specialty set.
Answer: No, there are no longer domain restrictions for quality measures.
Answer: Under MIPS, there are no longer any cross-cutting measures.
Answer: If you are not able to work on the 6 quality measures that are required then the clinician or group will be subjected to the Eligible Measures Applicability (EMA) process to determine if the clinician or group could have reported more.
Answer: Specialty sets are a group of measures that apply to clinicians in a specific specialty. A clinician may choose to report on a specialty measure set. If they report on a specialty measure set that has less than 6 measures included they do not need to report on any additional measures.
Answer: Three types are possible: positive, neutral, or negative.
- Positive adjustment: given to providers whose performance is exemplary.
- Neutral adjustment: given to providers who submit the minimum amount of data.
- Negative adjustment: -9% penalty given to providers who fail to report
Answer: Yes! Data abstraction is included with HCIS’ consulting service package.
Answer: The penalty for not reporting any data for the 2022 reporting year is a 9% negative payment adjustment in your 2024 Medicare reimbursements.
Answer: The HCIS MIPS team will verify your data before it is sent to CMS. They will also provide support over the phone or email to ensure you meet CMS requirements.
Answer: MIPS incentives and penalties will gradually increase over the next few years. With respect to 2022 reporting, clinicians can incur a +/- 9% incentive in their 2024 Medicare Part B reimbursements.
Answer: MIPS allows clinicians to submit a minimum amount of data for 75 points to Medicare and avoid the negative payment adjustment.
Q.1. Previously we have attested for Meaningful Use through our EHR. How do we report PI measures to CMS?
Answer: There are four mechanisms you can choose from to report your PI data: attestation, submitting through a QCDR, submitting via qualified registry, or submitting through an EHR. The ability to report PI measures via Registry and QCDR is new under MIPS, and for consolidation of reporting, you must submit for all categories through a single submission mechanism.
Answer: Yes, the clinician is required to be on the 2015 Edition Certified EHR Technology (CEHRT) for the 2022 MIPS reporting year.
Answer: By January 1, 2021 your practice will need to be on a 2015 certified version in order to report the measures included in the Promoting Interoperability category.
Answer: When reporting as a group for the Promoting Interoperability performance category, the group would combine their MIPS eligible clinicians’ performances under one Tax Identification Number (TIN). Therefore, they are not calculated based upon one MIPS eligible clinicians performance.
Answer: You must attest by indicating “yes” to each activity that meets the 90-day requirement; in other words, activities that you performed for at least 90 consecutive days during the current performance period (2021).
Answer: Improvement activities are assessed on the TIN level. Therefore, at least 50% of the clinicians in the group must perform the same activity during any continuous 90-day period within the 2022 performance year.
Answer: If a clinician bills less than $90,000 in Medicare Part B allowable charges OR sees less than 200 Medicare Part B patients OR provides less than 200 covered professional services in a calendar year, the clinician is excluded from MIPS reporting.
Answer: Clinicians who enroll in Medicare at any point during the 2022 year are considered new and therefore are not eligible to report for MIPS.
Answer: The Cost performance category uses your Medicare claims data to collect Medicare payment information for the care you gave to beneficiaries during a specific period of time. Because CMS will use Medicare claims data, the Cost performance category score will be automatically calculated on their end and you will not have to submit any data.
Answer: For year 2022, the following cost measures will be used to measure performance:
- Total Per Capita Cost Measure
- Medicare Spending Per Beneficiary measure
- 18 Episode-Based Cost Measures
For details on how the final MIPS Cost score is calculated please click here.
Answer: The cost category requires a minimum of 20 eligible cases for the total per capita cost measure, or 35 cases for MSPB measure or 10 cases for procedural episodes or 20 cases for acute inpatient medical condition episodes. If none of the measures can be scored, CMS will reweight the Cost performance category weight to the Quality performance category. This will make the Quality performance category worth 60% of your 2022 MIPS total score.
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You can register now to submit through our CMS qualified registry or hire our MIPS advisers to help you through the process. Please use this form if you have additional questions.