The Merit-based Incentive Payment System or MIPS is the outgrowth of MACRA (Medicare Access and CHIP Reauthorization Act) a comprehensive payment reform system for Medicare providers. MACRA attempts to deal with increasing healthcare costs by evaluating services and rewarding quality of care. MACRA replaces the use of both the Sustainable Growth Rate to contain costs and the Physician Quality Reporting System (PQRS) to assess service quality. MACRA also has another payment model called the Advanced Alternative Payment Model (APM), but most psychologists are not expected to provide services in the settings that would support its use.
Psychologists are eligible to begin MIPS reporting in 2019, while physicians are expected to collect data in 2017. Although the program may change by 2019, psychologists can do practice reporting this year so that they can get CMS feedback. The MIPSPRO registry by Healthmonix is a great way to do this without concern for positive or negative Medicare fee adjustments. Participation in the MIPS program in 2019, will affect your 2021 fee schedule, and continued reporting will affect payment changes two years after each annual data collection.
It is expected that most psychologists in Medicare who participate in MACRA, will use MIPS. To participate in MIPS, providers are asked to collect data in four domains to produce a composite score. The overall score determines if fee adjustments will be neutral, negative or positive. The four performance measures are Quality, Clinical Practice Improvement, Advancing Care Information and Cost.
The Quality measures for the current year, are PQRS measures which are in the Mental/Behavioral Health Specialty Measures Set. They range from Depression, Alcohol and Tobacco Screenings to Dementia Screening. Quality measures contribute 60 % of the composite score.
Clinical Practice Improvement measures allow individual providers to choose 4 activities from a list of 90 improvement activities and attest to enacting them for a minimum period of 90 days. The activities are assigned points and then summed and weighted to be 15% of the composite score. Some examples of this are: care coordination, emergency response and preparedness, and depression screening and follow up. A helpful website is qpp.cms.gov/Measures/ia.
Advancing Care Information incorporates the idea of meaningful use of electronic health records. Psychologists were not includes in incentives for electronic health records, yet this measure contributes 25% of the composite score. It is uncertain how the formula will be modified for us.
Cost data is taken directly off the claims data. It will be used starting 2018.
There are Low Volume Threshold (LVT) exclusions for MIPS participation. Currently, if you treat 100 or fewer patients or are reimbursed $30,000 or less, you do need to participate in MIPS. It is expected that for 2018, the LVT will be 200 patients or $90,000, respectively. If you do not participate, you will not be eligible for gains or losses accrued from MIPS, but your fees schedule may be frozen.
Groups may also participate in MIPS by assigning Medicare billing rights to a group Tax ID. Note that the LVT applies to the sum of services of the entire group, and not individual providers in the group. To qualify as a group there must be at least two MIPS eligible providers in the group.