Does MIPS transition year require a 90-day or 365-day reporting period?
What is the reporting period for MIPS in 2017? A full year? 90-days? There is a lot of confusion.
A common misconception is that practices have to report data that covers a full year in order to avoid a negative adjustment or maximize their incentive under MIPS. While reporting on 365 days has its benefits, you can still avoid the penalty and earn maximum incentive by reporting for a period of just 90-days.
What does it mean to “Fully Participate” in the 2017 Transition Year of MIPS?
One of the myths that needs to be debunked is that you are not “fully participating” and cannot reach maximum incentive unless you use a full year as your reporting period for your 2017 MIPS submission.
Full participation in the 2017 MIPS program is defined as reporting for 90-days, for 50% of your eligible patients for all-payers, for all three performance categories. The requirement to include data from all-payers is a major change from the PQRS requirement to include just Medicare Part B or Railroad Retirement Benefit patients.
Here is how “full participation” under MIPS differs from full participation for PQRS.
| 2016 PQRS | 2017 MIPS Transition Year | |
| Reporting Period | Full Year | 90-Day Period (Can report up to 365-day period, but no additional incentive) |
| Reporting Rate* (% of Eligible Patients) |
50% | 50% |
| Insurance | Medicare Part B or Railroad Retirement Benefit | All-Payers (Including private pay patients) |
* Reporting rate is scheduled to increase each year for MIPS under the Quality Payment Program
The 2017 Proposed Rule called for a full-year reporting period, 90% of patients eligible for the measure and all payers. Comments on the Proposed Rule, sent in during the comment period, emphatically proclaimed that a full year of reporting on all payers (and no measures groups) would be very hard for small practices. The comments registered with CMS. When the 2017 Final Rule was published, they came up with the less rigorous data-completeness criteria of 90-days and 50% of patients eligible for the measure. They still encourage reporting data for a full year. This will be the direction of MIPS going forward. But for 2017, you have relief from that heavier burden of reporting.
In one CMS presentation, they note a key takeaway on the subject: “positive adjustments are based on the performance data and the performance information submitted, not the amount of information or length of time submitted.”
Can I still avoid a penalty without “full participation?”
Yes! CMS understands that the transition to the new Quality Payment Program will take some adjustment time and will likely be difficult for many practices. To help relieve some of the stress this may cause, CMS has made it easy to simply avoid the penalty by submitting just ONE of these options:
- Submit one quality measure
- Attest to one Improvement Activity that you have done for 90 days
- Attest to Advancing Care Information Base Score Measures
During the 2017 transition year, making an effort to report at least one of these options will allow you to avoid a 4% negative adjustment to your Medicare Part B reimbursements in 2019.
You can even earn an incentive without “full participation.”
Incentives are going to be determined on a sliding scale for anyone that has a Final Score of more than three points on their submission. You can earn three points for each quality measure reported with no “completeness criteria” required. For example, if you report on 6 measures in the Quality Category (regardless of how you perform or how many of your eligible patients you report on), you would score 18 points:
- Submit six measures on just a few eligible patients, all with a “Not Met” performance
- One of them must be an Outcome measure
- Your results would be:
| 6 (measures reported) | x3 (points each) | 18 points total |
Even though it’s not required, reporting for a full 365 days may be beneficial.
While it is still possible to earn maximum incentive reporting on just a 90-day period, the biggest benefit to reporting a full 365-days of data is that it will best prepare you for the future of the program.
Secondly, measures with fewer than 20 cases, cannot earn more than three points. There is a chance that in a 90-day period, you will not have enough cases to meet that 20-case threshold. Reporting for more than 90 days may make it possible to earn more points per measure.
Reporting on a full year of data can seem like a daunting and time-consuming task.
One way that may alleviate some of your burden would be to report as a group instead of individually. This method of reporting closely mimics that of the GPRO reporting option available for PQRS, with the exception that there is no self-nomination period, so you can choose to report as a group at any time throughout the year. Particularly helpful for larger practices, this would allow you to send in just ONE submission for all clinicians under your TIN. Or you might monitor your performance throughout the year and you might want to choose your “best” 90 days of performance.
CMS is encouraging full-year reporting, and we want to see clinicians and practices pick the option that is best for you and your capabilities. Mingle Health will work with you to make that decision. It may be beneficial to report for an entire year to prepare for success in 2018. If you have the ability to report a full-year, why not reap the benefits?
Have questions about your practice? We’ll be there to help every step of the way! Contact one of our knowledgeable Consultants today to find out how you can get started.
Medicare reporting doesn't have to be overwhelming. This eBook will help you prepare for success!