Merit-Based Incentive Payment System Resources

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.

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, clinicians are required to us an EHR technology that is certified to the 2015 Edition Cures Update certification criteria for the 2023 MIPS reporting year

Answer: The 2015 Edition Cures Update functionality must be in place by the start of the performance period with certification obtained by the last day of the performance period.

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 2023, the following cost measures will be used to measure performance:

• Total Per Capita Cost Measure
• Medicare Spending Per Beneficiary measure
• 23 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 redistribute the Cost performance category weight to other performance categories.