Understanding the Merit-Based Incentive Payment System

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The Merit-Based Incentive Payment System (MIPS) consolidates elements of existing Medicare physician quality programs—including the Physician Quality Reporting System, the Value Modifier, and the Electronic Health Record (EHR) Incentive Program—into one streamlined program. It reduces the aggregate level of financial penalties that physicians otherwise would have faced under existing quality reporting programs and offers the potential for incentive payments based on high value care.

To check whether you must submit data to MIPS, enter your National Provider Identifier number here.

Under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), CMS is required to evaluate clinician performance based on four categories—Quality, Cost, Advancing Care Information (ACI), and Improvement Activities (IA). 

For performance year 2017, eligible clinicians and groups will receive a total MIPS Composite Score for Quality, ACI, and IA. Although CMS will calculate Cost measures and provide clinicians with confidential feedback on their performance in this category, the agency will not use those scores to determine payment adjustments for payment year 2019 (based on 2017 performance).

MIPS Composite Scores will be based on a scale of 0–100 points. Clinicians and groups will be able to earn up to a certain number of points within each MIPS category, depending on how they perform. The weight of each category might be different for hospital-based versus non-hospital-based clinicians, who can voluntarily opt out of the ACI category.

CMS will provide payment adjustments on a linear sliding scale such that physicians with composite scores at the MIPS performance threshold (3 points for 2017 for those who do the bare minimum) will receive a neutral adjustment, and those with a score of 100 will receive the highest upward adjustment assigned for that year. Those who do not meet the performance threshold will be subject to a downward adjustment. The adjustment amount is set at + or - 4% for 2019 (performance year 2017), but CMS has the authority to increase or decrease this percentage by a scaling factor (up to 3x) to ensure budget neutrality. CMS cannot determine the extent of upward adjustments for 2019 until it knows the total amount of downward adjustments.

MACRA legislation also includes $500 million for the first 6 years of MIPS for exceptional performance bonuses. For the 2017 performance year, clinicians scoring between 70 and 100 points are eligible to receive an additional upward payment adjustment from this pool of funding. Adjustments will be made on a separate linear sliding scale such that an additional bonus of 0.5% would be assigned for a final score at the exceptional performance threshold (70 points for 2017), and an additional bonus of 10% would be assigned for a final score of 100. The exceptional performance adjustments are subject to their own scaling factor (up to 1x), if necessary, to ensure that bonuses do not exceed the available pool of funding. 

Physician Reporting Requirements Under MIPS

Eligible clinicians will be required to comply with MIPS beginning in 2017. Performance in 2017 will determine Medicare payment adjustments to these clinicians in 2019. However, recognizing that there is variation in readiness to engage in this new quality reporting program, CMS has declared 2017 a transition year where clinicians may “pick their pace” for MIPS reporting. Some level of participation ensures that a penalty will be avoided and may possibly result in a bonus. No participation results in an automatic 4% penalty. 

The Society strongly recommends that cardiothoracic surgeons participating in the Adult Cardiac Surgery Database (ACSD) use the STS National Database, which is a Qualified Clinical Data Registry (QCDR), to fulfill their Quality reporting requirements. Participation in the ACSD will allow surgeons to, at the very least, avoid a MIPS penalty and potentially qualify for a small to a moderate upward payment adjustment depending on performance and the number of measures and activities reported under MIPS. Learn more about how you can report your quality data to CMS through the Database.

Currently, the STS National Database can be used by cardiac surgeons only for Quality reporting. General thoracic surgeons, as well as cardiac surgeons who opt not to use the STS National Database for Quality reporting, will need to report Quality measures using an alternative method. For many, this will be via claims-based reporting, unless their institution or practice provides them with another reporting method. 

Note that not all of the reporting options listed below are currently available to cardiothoracic surgeons. For example, while STS is able to report Quality measure data to CMS on behalf of participants in the Adult Cardiac Surgery Database, it does not have the capability to report ACI or IA data to CMS for 2017. To minimize the administrative burden, STS is developing a single reporting tool for submission of most, if not all, MIPS data to CMS. In the interim, however, most cardiothoracic surgeons will have to rely on multiple modes of data transmission to satisfy the various MIPS components.

*Few, if any, cardiothoracic surgeons will rely on the CMS Web Interface or CAHPS for MIPS survey since these data submission mechanisms are geared more toward primary care.