2. AGENDA Participating in MIPS in 2017 MIPS Performance Categories
Reporting Requirement & Scoring
Payment Adjustments
Timeline
Additional Resources
Checklist for Clinicians

3. What Is MIPS?
MIPS is the “Merit-Based Incentive Payment System” track of CMS’s new QPP developed under MACRA (replaces the Sustainable Growth Formula)
MIPS streamlines 3 existing programs under a single umbrella – PQRS, MU, and VBM
MIPS adds a new category to reward clinicians for activities to improve clinical practice
Participants in MIPS will earn a performance-based payment adjustment to their Medicare payment
Only affects clinician reimbursement under Medicare Part B
MACRA = Medicare Access and CHIP Reauthorization Act of 2015; MU = Meaningful Use; PQRS = Physician Quality Reporting System; QPP = Quality Payment Program; VBM = Value-Based Modifier.
CMS. What’s the Merit-based Incentive Payment System (MIPS)? Accessed 12/8/16.

4. What Are the MIPS Performance Categories?
Cost
(replaces VBM)
Improvement Activities
(new category)
Advancing Care Information
(replaces MU [CEHRT])
Quality
(replaces PQRS)
CEHRT = certified electronic health record technology; MIPS = Merit-Based Incentive Payment System; MU = Meaningful Use; PQRS = Physician Quality Reporting System; VBM = Value-Based Modifier.
CMS. What’s the Merit-based Incentive Payment System (MIPS)? Accessed 12/8/16.

5. How Is The Quality Category Different From Current Requirements?
Similarities
~300 measures to choose from
Claims data used to calculate population-based measures
Differences
“Pay for performance” instead of “pay for reporting”
Only required to report 6 measures instead of 9
No longer required to report across National Quality Strategy Domains
Quality
(replaces PQRS)
Clinical Practice Improvement Activities
Advancing Care Information
(Meaningful Use)
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16.. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

6. What are the Quality Reporting Requirements?
2017
To avoid negative payment adjustment in 2019:
Report on 1 quality measure for at least 1 patient
To potentially earn a positive payment adjustment in 2019:
Report on 6 quality measures (including at least 1 outcome or high priority measure) or 1 measure set
Bonus points can be earned:
Reporting through an CEHRT, clinical registry, QCDR, or web interface
Reporting through a QCDR will also help meet requirements in the Improvement Activities category
Reporting an additional high-priority quality measure
Quality
(replaces PQRS)
Clinical Practice Improvement Activities
Advancing Care Information
(Meaningful Use)
Quality
(PQRS/VBM)
CEHRT = Certified Electronic Health Record Technology; PQRS = Physician Quality Reporting System; QCDR = Qualified Clinical Data Registry.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16.. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

7. How is the Score for the Quality Category Calculated?
Total Quality Performance Category Score
(60% of Total MIPS Score
in 2017)
Points earned on required 6 quality measures
Any bonus points
Maximum number of points
(Maximum number of points = # of required measures x 10)
MIPS = Merit-Based Incentive Payment System.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

8. How Is The Improvement Activities Category Different From Current Requirements?
NEW category to reward clinicians for participation in activities that improve clinical practice
Clinicians choose from over 90 activities across 9 sub-categories:
Expanded practice access
Population management
Care coordination
Beneficiary engagement
Patient safety and practice assessment
Participation in an APM
Achieving health equity
Integrating behavioral and mental health
Emergency preparedness and response
Improvement Activities
(new category)
Clinical Practice Improvement Activities
Advancing Care Information
(Meaningful Use)
APM = Alternative Payment Model.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

9. What are the Improvement Activities Reporting Requirements?
2017:
Perform improvement activities for ≥90 consecutive days
Most clinicians:
Attest to 2 high-weighted activities (20 points each) or 4 medium weighted activities (10 points each)
Small, rural, HPSA, and non-patient facing clinicians:
Attest to 2 medium-weighted activities or 1 high-weighted activity
Automatic credit:
Certified/accredited PCMH
MIPS APMs
Other APMs (at least half credit)
Preferential scoring by using CEHRT to perform ≥1 improvement activity
Improvement Activities
(new category)
Clinical Practice Improvement Activities
Quality
(PQRS/VBM)
APM = Alternative Payment Model; CEHRT = Certified Electronic Health Record Technology; HPSA = Health Professional Shortage Area; MIPS = Merit-Based Incentive Payment System; PCMH = Patient-Centered Medical Home.
CMS. Quality Payment Program Fact Sheet. Updated 10/26/16. Accessed 12/9/16. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

10. How is the Score for the Improvement Activities Category Calculated?
Total Improvement Activities Category Score
(15% of Total MIPS Score
In 2017)
Total number of points scored for completed activities
100
Maximum number of points (40)
MIPS = Merit-Based Incentive Payment System.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16.

11. How Is The Advancing Care Information Category Different From Current Requirements?
Similarities
EHR use encouraged
Differences
Can report individually or as a group
Partial credit opportunity for EHR measurement
Data may be submitted through QCDRs
Applicable to all clinicians (not just Medicare)
Reporting only required for 4 or 5 measures
No longer required:
Computerized Physician Order Entry
Clinical Decision Support
Advancing Care Information
(replaces MU [CEHRT])
Clinical Practice Improvement Activities
Advancing Care Information
(Meaningful Use)
Quality
(PQRS/VBM)
EHR = Electronic Health Record; MU = Meaningful Use; QCDR = Qualified Clinical Data Registry.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16.. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

12. What are the Advancing Care Information Reporting Requirements?
2017:
Report on all of the base measures
Report on optional performance measures for additional credit
Bonus opportunities:
Immunization, public health, or clinical data registry
Using CEHRT:
2017: or 2015 CEHRT
2018: CEHRT
Advancing Care Information
(replaces MU [CEHRT])
CEHRT = Certified Electronic Health Record Technology; MU = Meaningful Use.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16.. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

13. Advancing Care Information
Are There Any Exceptions to the Advancing Care Information Reporting Requirements?
Exceptions:
CMS will automatically re-weight this category to “0” for:
Hospital-based MIPS clinicians
Non-patient facing clinicians
NPs, PAs, CRNAs, and CNS
Clinicians with a hardship for reporting can apply to have their score weighted to “0”
Advancing Care Information
(replaces MU [CEHRT])
CEHRT = Certified Electronic Health Record Technology; CMS = Centers for Medicare & Medicaid Services; CNS = Clinical Nurse Specialist; CRNA = Certified Registered Nurse Anesthetists; MIPS = Merit-Based Incentive Payment System; MU = Meaningful Use; NP = Nurse Practitioner; PA = Physician Assistant.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

14. How is the Score for the Advancing Care Information Category Calculated?
FINAL
SCORE
Earn ≥100% and receive full credit
for the Advancing Care Information Category
(25% of Total MIPS Score
In 2017)
BASE
SCORE
(up to 50% of the final score)
PERFORMANCE SCORE
(up to 90% of the final score)
BONUS
SCORE
(up to 15% of the final score)
MIPS = Merit-Based Incentive Payment System.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

15. How Is The Cost Category Different From Current Requirements?
Similarities
2 measures continue:
Total per capita costs for all attributed beneficiaries
Medicare spending per beneficiary
Clinicians are still evaluated based on Part A and Part B costs
Uses measures previously used in VBM or reported in the QRUR – only the scoring is different
Differences
10 new episode-based cost measures for specialists
Anticipated inclusion of assessment of Part D costs in the future
Cost
(replaces VBM)
Clinical Practice Improvement Activities
Advancing Care Information
(Meaningful Use)
Quality
(PQRS/VBM)
QRUR = Quality and Resource Use Report; VBM = Value-Based Modifier.
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

16. What are the Cost Reporting Requirements?
No Cost Reporting Requirements in 2017
In 2017: calculated from claims
In 2018: 10% of the MIPS score
To prepare for 2018, clinicians can review their QRURs to:
Identify the most costly conditions/diagnoses
Identify the episode of care cost measures relevant to the practice
Identify the lead clinician for each attributed patient for each measure
Cost
(replaces VBM)
Clinical Practice Improvement Activities
Quality
(PQRS/VBM)
MIPS = Merit-Based Incentive Payment System; QRUR = Quality and Resource Use Report; VBM = Value-Based Modifier. CMS. Quality Payment Program Fact Sheet. Updated 10/26/16. Accessed 12/9/16. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/9/16.

17. What Do I Need to Report For Full Participation in 2017?
None in 2017
Improvement Activities
Advancing Care Information
Cost
Quality
6 measures* OR
1 measure set*
4 medium or 2 high weighted activities
(Certain clinicians have fewer requirements or will receive automatic credit)
4 or 5** measures
(bonus for using CEHRT and for reporting to registries)
No Reporting Requirement
in 2017
(calculated from claims)
* Including at least 1 outcome or high priority measure if applicable; Groups using the web interface need to report 15 quality measures.
** 4 or 5 measures depending on which CEHRT edition is used (2014 or 2015).
CEHRT = certified electronic health record technology. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.

18. How Is The Performance Score Calculated?
2017 MIPS Scoring Model
Creates 100-point system to increase and consolidate financial impacts
Cost is 0 for 2017, but will be scored in 2018 and beyond
2017 weightings put 85% in the Quality and Improvement Activities categories
Ranks peers nationally
CMS will report physicians’ scores publicly on
Physician Compare
Improvement Activities
(15%)
Quality
(60%)
Advancing Care Information
(25%)
MIPS = Merit-Based Incentive Payment System.
MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.

19. How Is the Final MIPS Score Calculated?
Quality Performance Category Score X
Actual
Quality Performance Category Weight
(60%)
Improvement Activities Performance Category Score X
Actual Cost Performance Category Weight
(15%)
Advancing Care Information Performance Category Score X
Actual Advancing Care Information Performance Category Weight
(25%)
Cost Performance Category Score X
Actual Cost Performance Category Weight
(0%)
FINAL
MIPS
SCORE
100
CMS. The Merit-Based Incentive Program /29/16. Accessed 12/13/16..

20. Where Will CMS Report the MIPS Scores?
CMS = Centers for Medicare & Medicaid Services; MIPS = Merit-Based Incentive Payment System.
Medicare. Physician Compare. Accessed 12/6/2016.

21. How Can I Report?
Clinicians can report as an individual, as a group, or through an APM.
Data must be reported the same way across all categories.
Individual
Single NPI tied to a single TIN
Low volume threshold determined at the individual level
Payment adjustment based on individual clinician’s performance
Option to report via Medicare claims
Group
2+ eligible clinicians, identified by their NPIs, who share a common TIN
Low volume threshold determined at the group level
All clinicians must report on the same set of measures across all 4 MIPS categories
APM
Clinicians submit quality data through their APM
APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System; NPI = National Provider Identifier; TIN = Tax Identification Number. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.

22. How Can I Report? (cont.)  Individual Group Medicare Claims
Clinical Data Registry
Qualified Clinical Data Registry
CEHRT
Web Interface*
Must register by June 30, 2017
* Only available to group practices of 25+ eligible clinicians. CEHRT = Certified Electronic Health Record Technology.
CMS. Getting Ready for MIPS. Accessed 12/8/16.

23. “Pick Your Pace” Reporting Options for 2017
Don’t Participate
Receive a negative 4% payment adjustment in 2019
-4% 0%
Test: Submit some 2017 data (eg, 1 quality measure or 1 improvement activity)
Avoid negative payment adjustment in 2019 +%
Partial: Submit ≥90 days of 2017 data (can start anytime between Jan. 1 and Oct. 2)
Potential for small positive payment adjustment in 2019
Full: Submit a full year of 2017 data
Potential for moderate positive payment adjustment in 2019 +%
+5%
Participate in an Advanced APM*
5% incentive bonus payment in 2019
* If you receive 25% of Medicare payments or see 20% of your Medicare patients through an Advanced APM in 2017
CMS. Quality Payment Program. Accessed 12/8/16.

24. What Are The Payment Adjustments Based On?
Positive payment adjustments are based on: how much data you submit and your performance
CMS. Quality Payment Program Fact Sheet. Updated 10/26/16. Accessed 12/9/16.

25. 2017 MIPS Payment Adjustment “Pick Your Pace”
Option 3 Example:
“Full Reporting”
Clinicians who report data for the required measures will have the best opportunity to maximize incentive payment adjustments
Option 2 Example: “Partial Reporting”
Clinicians report data for >1 measure for at least a 90-day period, but may not have enough data for all the measures
Option 1 Example: “Test”
Clinicians can report on just one measure for at least a 90-day period and earn 3 points, thereby avoiding the up to 4% penalty
Part B
Payment
Adjustment %
Max Total Incentive
+2.4%
Total Incentive
Max Base Incentive
+0.9% 0%
Base Incentive 3 70
100
MIPS Points
“No Reporting”
MIPS-eligible clinicians who do not report will receive the full 4% payment penalty
CMS 2017 Performance Threshold
Clinicians who achieve a final MIPS score of >70 will be eligible for an exceptional performance adjustment
-4%
DHHS. CMS. 42 CFR Parts 414 and Medicare Program; MIPS and APM Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Final Rule. Federal Register. November 4, 2016;81(214): (Page 77341).

26. MIPS Maximum Payment Adjustments
+9%
Clinicians will receive upward or downward adjustments of payments based on how their MIPS composite score compares with the national performance threshold
+7%
+4%
+5%
2019
(2017 PY)
2020
(2018 PY)
2021
(2019 PY)
2022
(2020 PY)
-4%
-5%
-7%
-9%
MIPS = Merit-Based Incentive Payment System; PY = performance year.
CMS. Quality Payment Program. Accessed 12/8/16.

27. What is the Timeline for the Quality Payment Program?
2017 Performance Year
MIPS Track: record data for MIPS measure(s) for at least 90 consecutive days
Advanced APM Track: provide care during the year through the Advanced APM
Feedback
CMS provides feedback about your performance
Jan. 1, 2017
Jun. 30, 2017
Oct. 2, 2017
Dec. 31, 2017
Mar. 31, 2018
Jan. 1,
2019
Deadline to Register as a Group
Last Day to Start Collecting Data
to participate in
MIPS in 2017
Submit Performance Data
MIPS Track: submit data for MIPS measures to avoid the negative payment penalty and potentially earn a positive payment adjustment
Advanced APM Track: submit quality data through your Advanced APM to earn the 5% incentive payment
Payment Adjustment
MIPS Track: maximum +/- 4% payment adjustment
Advanced APM Track: 5% incentive payment
APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System.
CMS. Quality Payment Program. Accessed 12/8/16.

28. Where Can I Go For More Information & Support?
CMS Quality Payment Program
Online Portal & Service Center
Available Monday – Friday, 8 AM – 8 PM ET

29. Where Can I Go For More Information & Support?
Transforming Clinical Practice Initiative (TCPI)
CMS-funded; provides resources and technical support to help practices improve quality of care, reduce costs, and prepare for value-based payment arrangements
Quality Innovation Network (QIN)-Quality Improvement Organizations (QIOs):
Instruments/QualityImprovementOrgs/index.html?redirect=/qualityimprovem entorgs/
Patient safety, healthy communities, care coordination, clinical quality
American Medical Association:
MACRA educational resources; MACRA Assessment

30. What Should I Do Next?
Determine if you qualify for MIPS, MIPS APM, or Advanced APM
Determine if you meet requirements for small, rural, or non-patient facing exceptions
Educate and engage your team
If you qualify for MIPS:
Review your QRUR; estimate your MIPS score using your current MU, PQRS, and VBM scores
Optimize activities, organizational structure, and resources under the MIPS categories to maximize the MIPS score for 2017
Identify:
WHO will be reporting (individual, group, or APM)
WHAT measures you will be reporting on
HOW you will be reporting (CEHRT, QCDR, clinical data registry)
WHEN you will be reporting (key deadlines)
“Pick Your Pace” for 2017
Check that your EHR is certified by the Office of the National Coordinator for Health IT
Join a CMS-funded TCPI Practice Transformation Network
APM = Alternative Payment Model; CEHRT = Certified Electronic Health Record Technology; CMS = Centers for Medicare and Medicaid Services; EHR = Electronic Health Record; IT = Information Technology; MIPS = Merit-Based Incentive Payment System; MU = Meaningful Use; PQRS = Physician Quality Reporting System; QCDR = Qualified Clinical Data Registry; QRUR = Quality and Resource Use Report; TCPI = Transforming Clinical Practice Initiative; VBM = Value-Based Modifier.
CMS. Quality Payment Program. Accessed 12/8/16.

31. POLLING QUESTION
What is the top challenge you have to participating in the Quality Payment Program (MIPS/APM) in 2017?
Lack of time to set up
Investment needed in technology
Changes in organizational structure/workflow needed
Lack of reporting mechanisms in my practice setting (CEHRT, clinical registries, web interface)
Lack of resources to support data collection, monitoring, & reporting
Lack of staff training, engagement
I don’t understand what I need to do to participate
I’m not eligible to participate

32. Key Takeaways MIPS measures clinicians’ performance in 4 categories:
Quality (replaces PQRS)
Improvement Activities (new category)
Advancing Care Information (replaces MU)
Cost (replaces VBM; no reporting requirements in 2017)
MIPS = Merit-Based Incentive Payment System; MU = Meaningful Use; PQRS = Physician Quality Reporting System; VBM = Value-Based Modifier.

33. Key Takeaways (cont.)
“Pick Your Pace” reporting options are available in 2017
Submit data on at least 1 measure in 2017 to avoid the 4% penalty
Positive payment adjustments can be maximized by earning bonus points or demonstrating exceptional performance
Clinicians’ MIPS scores will be reported publicly by CMS on the Physician Compare website
CMS = Centers for Medicare & Medicaid Services; MIPS = Merit-Based Incentive Payment System.