The Department of Health and Human Service recently issued the final rule for the Merit-based Incentive Payment System. Though it was received with mixed reviews, the final rule actually offers many ways to eligible clinicians to avoid negative payment adjustments under MIPS in the first reporting period. HHS also made it clear that they would follow a systematic model to allow smooth transition of eligible participants into the program.
Reports say that there are three ways to avoid negative payment adjustments under MIPS for the 2019 Medicare reimbursements. However, if an eligible clinician does not choose any of the models, the participant would receive a minus 4% Medicare payment adjustment.
The first choice to avoid negative payment adjustments is by enrolling in an evaluation period, during which, the participant would be required to submit at least some of the data under the calendar year reporting period. HHS said that the minimum requirement would be to submit at least one performance measure data.
“Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment,” HHS said summarizing the final rule.
The agency also added that even though eligible clinicians will be able to avoid MIPS negative payment adjustment through the first model, they will not receive a positive payment adjustment, but instead, the payment adjustment would stay neutral.
The second path is a partial-year reporting model, which would require clinicians to submit a 90-day report to Medicare. “Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017, but for a full 90-day period at a minimum,” HHS clarified.
The agency continued that eligible clinicians would need to “report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment.” The partial-year reporting participants, however, might receive a small positive payment adjustment, besides avoiding the negative payment adjustments.
The third model for avoiding MIPS negative payment adjustments is to submit data for more than the 90-day reporting period. “Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment,” the agency explained.
“In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program,” HHS concluded. Eligible clinicians participating in the third model would also receive a higher positive payment adjustment.