What is MIPS?

MIPS is the Merit-Based Incentive Payment System for Medicare reimbursement to physicians and other eligible providers, created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).  This bipartisan legislation eliminates the flawed Medicare sustainable growth rate (SGR) formula that has repeatedly called for drastic cuts in physician payments, and establishes a reliable 0.5% annual increase in the physician fee schedule from 2016 to 2019.  While the much of the actual payment incentives (and penalties) of MIPS go into effect as of 2019, practices will be judged on some data points (such as quality of care and utilization rates) from 2017.

Who is eligible for MIPS?

In addition to osteopathic and allopathic physicians, other eligible Medicare Part B providers include physician assistants and nurse practitioners.

How does MIPS consolidate current incentive programs?

MIPS consolidates the current Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VBM) programs.  Participating providers will submit practice data which will be calculated into a composite performance score, which is comprised of four categories:
- Meaningful use of certified electronic health records
- Quality of Care
- Resource utilization MIPS
- Clinical practice improvement activities
It is important to note that providers MIPS scores will be available on Medicare’s Physician Compare website.  This is a significant increase in the amount of detailed practice information that will now be available to the public.

Are there any alternatives to participating in the MIPS program?

In order to promote physicians to enter more at-risk, performance-based contracts, the MACRA legislation allows providers who receive a significant portion of their Medicare reimbursements from alternative payment models (APM’s) to be exempt from MIPS reporting.  Additionally, these providers receive an additional 5% annual increase in their Medicare payments. 

Providers whose total Medicare payments fall below a certain threshold (to be determined) are also exempt.

How can a solo or small group (i.e. <15 EP’s) successfully participate in MIPS or an APM?

In recognition of the difficulties solo or small group practices may encounter in attempting to satisfy the MIPS requirements, the MACRA legislation provides $20 million a year for technical assistance via regional extension centers and quality improvement organizations.

What can (or should) I be doing now to prepare for MIPS?

Although MIPS doesn’t officially begin until 2019, many of the clinical performance and utilization data will be taken from the 2017 performance year.  Thus, physicians should review their own practice data for meaningful use, PQRS, and VBM to try and improve their processes, workflow, and performance in these key programs.  Practices should also identify (if they haven’t done so already) which clinical quality measures best correspond to their patient population, as well as design workflows and processes to capture data in reportable form.

Where can I find more information about MIPS?

In addition to ACOFP’s Practice Transformation tools, refer to the CMS’ webpage on MIPS.