The MIPS Promoting Interoperability (PI) (formerly
Advancing Care Information (ACI)) and Improvement Activities (IA) categories have both expanded
reporting activity options to ease participation.
Many practices do not realize that submitted IA
measures can come from differing 90-day periods,
not all within the same timeframe.
If you are a 2018 MIPS participant, thoroughly
document IA starting points and activity measurement progress. Take advantage of demonstrating
improvement of an existing practice activity for
easy comparison and completion. Within the PI
category, report on all base measures. 5
Do not skip this requirement. If skipped, you
will receive a zero for the category, losing the
chance to report on PI performance measures
to build up additional category points. The total
possible base and performance measures also
depend on Certified EHR Technology (CEHRT)
used. Using 2015 CEHRT offers the opportunity
to earn 10 bonus points, but this elevated CEHRT
requires advanced functionality with five base
measures and nine performance measures (see
“Five ACI Base Measures with 2015 CEHRT”).
Using 2015 CEHRT means you can reach the full
25% PI score toward the MIPS total score.
Centered on resource-strained practices, the
MACRA Year 2 Merit-Based Incentive Payment
System (MIPS) leniencies relieve small and rural
providers’ reporting and administrative burden.
This year, the exemption threshold covers clinicians or groups who have billed $90,000 or less
in Medicare Part B or treat 200 Part B or fewer patients. 3
Exemption is automatically based on Medicare claims, and a
new Medicare-enrolled eligible clinician; a qualifying Advanced
Alternative Payment Model (APM) participant; or a partial
qualifying APM participant is exempt from MIPS reporting.
Use the Centers for Medicare & Medicaid’s (CMS’s) Quality
Payment Program site to help determine provider participation
status verification per clinician National Provider Identifier
(NPI) or your group’s tax identification number (TIN). 4 The status check can also detail special status based on practicing
in a federally designated Health Professional Shortage Area,
small practice, and other factors.
Verify MIPS Year 2 Participation Status
Anticipate Year 2 Costs
The biggest shakeup for MIPS reporting requirements in Year 2 is that Cost
is now weighted at 10% of the final
MIPS score. Last year, Cost carried no
weight in the final score as part of
the participation transition period.
To strategically anticipate your
position, look at measures like
Medicare Spending per Beneficiary,
Quality Resource Usage Report
data, and 2017 Quality Payment
Program (QPP) performance feed-
back from CMS.
If you are a 2017 MIPS partici-
Five ACI Base Measures with 2015 CEHRT
pant, you should have received your
performance feedback in Septem-
ber 2018. CMS encourages you to
double check Year 1’s payment
adjustment calculation and use the
targeted review process if you think
payment error occurred. 6 With the
passing of the Bipartisan Budget
Act of 2018, MACRA’s initial tran-
sition years extend into 2021, and
Cost Improvement scoring will not
be considered for MIPS score calcu-
lations in 2018.
Improve Activities and Promote Interoperability Submissions
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