Counting your chickens? Not so fast...

Thursday, March 15, 2018 | Cherie Kelly-Aduli

Counting your chickens? Not so fast

It is no surprise to me, as a MACRA consultant, that typically the first few questions I hear from physicians are "How much of an incentive payment are we going to receive if we participate in MIPS?” and “What is the minimum amount of work required to avoid the penalty?" In the past, when participating in the CMS legacy programs the answer was pretty simple. Participants knew upfront exactly what the potential gain or loss would be for each program year. While the MIPS program sure looks and feels a lot like the same old quality incentive reporting programs (Meaningful Use, PQRS and the Value Modifier), it is not. One of the biggest differences is budget neutrality. This means the pool of money generated from the MIPS penalties is the source of payment for incentives, so we really do not know what kind of payment to expect.

MIPS eligible clinicians still have several ways to avoid the 4% negative payment adjustment in 2019 from program year 2017. In my opinion, some of the easiest ways to avoid the penalty would have been by reporting claims based on a quality measure or completing the practice improvement activities. Either of these methods would have secured at least three (3) points, which is enough to avoid the 4% Medicare part B penalty in 2019. As of today, it is still not too late to submit your 2017 data to CMS through a registry or EHR direct since the deadline is on 3/31/2018. Below are a few of my top operational questions when assessing a clinic's MIPS readiness.

  • Did you use the CMS MIPS NPI lookup tool to see if you are considered a MIPS eligible clinician?  
  • Do you have an EHR (2014 or 2015 CEHRT)?
  • Are your quality and advancing care measures mapped correctly on the backend of your EHR?
  • Do you have a designated person in your clinic reviewing your data weekly or monthly and reporting results to key staff members?
  • Are you classified correctly with PECOS?
  • Have you reviewed your historical QRURs?
  • Have you completed a security risk assessment?
  • Did you meet the base measures for advancing care?
  • Have you met the 50% data completeness rule and the 20 case minimum for your quality measures? Go to if you need additional information on the two rules. (Note: In 2018 the data completeness rule increased to 60%.)
  • Have you completed your practice improvement activities for at least 90 days?
  • Will you get your data to CMS (attestation, registry, qcdr, claims, etc.) by the March 31st deadline?

So how did you score?  If you answered “yes” to most of the above questions then you are more than likely going to avoid the 4% penalty and possibly receive a positive adjustment from Medicare in 2019 based on your work in 2017. If you answered “no” then you will have some work to do in 2018. As always, we are here to help; please let us know if you have any questions or would like assistance with your 2018 MIPS operations.



Illustration: Lee Sauer

About the Author
Cherie Kelly-Aduli

Cherie Kelly-Aduli is the CEO of QPP Consulting Group in Mandeville, Louisiana, and a MedAxiom consultant. She has over 16 years of experience in healthcare operations, population health and accountable care. Prior to opening her own firm, Cherie was the Director of Clinical Operations and subsequently Director of Population Health and Accountable Care for the Louisiana Heart Hospital and Medical Group located in Lacombe, Louisiana.

Throughout her career Cherie has been highly successful in efficient practice management, practice adoption of electronic health records, and assisting providers with exceeding standards for patient satisfaction. As payors and patients have transitioned to "pay for value," Cherie has been instrumental in leading private practices and hospital systems to achieve high quality outcomes under the Meaningful Use, PQRS and Value Based Modifier programs; she is now assisting groups with their adoption of the Merit Based Incentive Payment system under MACRA.

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