Navigating the World of MIPS

March 15, 2023


Remind me again, what is MIPS?

MIPS (Merit-based Incentive Payment System) is a program under Quality Payment Program (QPP) that aims to improve the quality of care provided to Medicare beneficiaries while also controlling healthcare costs. Participation in the program is required for eligible clinicians who bill Medicare more than a certain amount. Depending on certain criteria, clinicians can participate at an individual or group level. There are incentives for those who participate and those who do not participate may face penalties, including payment reductions. The performance year begins January 1 and ends on December 31. All reporting for the previous year must be completed by March 31.

MIPS now offers multiple reporting options to accommodate the needs of different clinicians and practices. Traditional MIPS is the standard reporting option, while the APM Performance Pathway (APP) and MIPS Value Pathways (MVPs) provide more streamlined and flexible reporting options for clinicians who participate in APMs or have specific practice focuses. This blog will specifically focus on the Traditional MIPS reporting option.

What is the difference between Traditional MIPS, APP, and MVPs?

Traditional MIPS

Traditional MIPS is the original MIPS program that was established by CMS in 2017. It is a performance-based payment system that measures the quality of care provided by eligible clinicians, as well as their use of certified electronic health record (EHR) technology, improvement activities, and cost. Eligible clinicians can choose which performance categories they want to report on and how much weight to assign to each category. CMS took feedback from clinicians on Traditional MIPS and in response created APM Performance Pathway (APP) and MIPS Value Pathways (MVPs).

APM Performance Pathway (APP)

The APP is a performance pathway that was introduced as part of the MIPS program in 2021. The APP is designed for MIPS eligible clinicians who participate in MIPS Alternative Payment Models (APMs). The APP is a streamlined program with the primary objectives being to alleviate the reporting burden on eligible clinicians, offer new scoring opportunities for MIPS APMs participants, and promote involvement in APMs. Unlike Traditional MIPS, there are three (3) performance measures rather than four (4). This includes quality, improvement activities, and promoting interoperability.

MIPS Value Pathways (MVPs)

MVPs are a new approach to the MIPS program that is scheduled to be implemented in 2023. MVPs are designed to simplify the reporting process and provide more meaningful data to clinicians. Under the MVPs, CMS will group related measures and activities into sets that are aligned with specific medical specialties or conditions. Clinicians will report on a smaller set of measures that are more relevant to their practice and patient population. There are currently 12 MVPs that are available for the 2023 performance year. MVPs will also allow for more flexible reporting options, such as group reporting or episode-based reporting. The goal of the MVPs is to reduce the reporting burden on clinicians while still promoting high-quality care. 

CMS is aiming to eventually sunset traditional MIPS and then depending on eligibility, MVPs or the APP will become mandatory in performance year 2026.

What are the categories under Traditional MIPS?

Quality: This category measures the quality of care provided to patients. It is measured by assessing clinical practices and patient outcomes to evaluate how well healthcare providers are providing evidence-based care and meeting patient needs.

Improvement Activities (IA): This category encourages clinicians to participate in activities that improve patient care. Clinicians report on four (4) categories: enhancing patient engagement, care coordination, population management, and health equity.

Promoting Interoperability (PI): This category focuses on the use of EHR technology to improve the coordination and quality of care. Clinicians report on a set of measures related to EHR use, health information exchange, patient engagement, and health information security.

Cost: This category measures the cost of care provided by clinicians based on Medicare claims data. Clinicians do not need to report any additional data for this measure as it is calculated automatically based on claims data.

What does reporting look like for the 2023 performance year under Traditional MIPS?

Quality: Eligible clinicians must report on at least six (6) quality measures, including at least one (1) outcome measure, or a high-priority measure set if applicable.

Improvement Activities (IA): Eligible clinicians must report on: a total of four (4) medium-weighted activities, or two (2) high-weighted activities and either (2) medium-weighted activities or one (1) high-weighted activity. 

Promoting Interoperability (PI): Eligible clinicians must use an EHR that meets certain criteria. They must also report on a set of required measures, and then can choose additional measures from a list of optional measures. 

Cost: No reporting required. Cost measures will be calculated by CMS based on claims data. 

Note: The requirements throughout this blog are subject to change annually, so it is important to stay up-to-date with the latest information from CMS to ensure compliance with reporting requirements.

How is the Traditional MIPS score calculated?

The MIPS score is based on clinicians’ performance in those four (4) categories. Each category is weighted differently and will result in a final score of 0 to 100. The Quality category is 30% of the final score, the Improvement Activities category is 15% of the final score, Promoting Interoperability is 25% of the final score and Cost is 30% of the final score. The score can also be adjusted based on factors such as practice size and patient population. For example, practices with 15 or fewer clinicians can receive bonus points for the Quality category score if they participate in at least one (1) measure.

How is the data submitted to CMS?

To participate in MIPS, clinicians must report performance data to CMS. There are various ways to report, such as through a Qualified Registry (QR), a Qualified Clinical Data Registry (QCDR), an electronic health record (EHR), or the CMS web interface. Vendors can be a helpful resource for clinicians with data collection, reporting, and performance analysis. When working with outside vendors, it is important to ensure that they are certified by CMS to submit data. CMS will accept data from multiple vendors.

What are the benefits of participating in MIPS?

There are financial incentives for those who participate in MIPS and meet certain performance thresholds. The incentives are funded through adjustments to Medicare Part B payments, and the amount of the incentive varies based on performance score. Those who are high-performing will receive positive payment adjustments, while poor performers may receive negative payment adjustments. By participating in the program, clinicians can also track their performance on various quality measures and identify areas for improvement. This can help them improve the quality of care they provide to their patients and increase patient satisfaction.

How can CODE help with MIPS?

CODE is well-informed on programs like MIPS and we make a point to stay up-to-date with the annual changes. With CODE’s expertise, we can help make sure you’re on track to successfully meet the requirements.

These Quality measures can be met organically by collecting PRO data with CODE:

  • 376 Functional Status Assessment for Total Hip
  • 459 Back Pain After Lumbar Surgery
  • 461 Leg Pain After Lumbar Surgery
  • 470 Functional Status After Primary Total Knee Replacement
  • 471 Functional Status After Lumbar Surgery

Sources    | How MIPS Eligibility is Determined | Individual or Group ParticipationTraditional MIPS Overview | Quality: Traditional MIPS Requirements| Promoting Interoperability: Traditional MIPS Requirements | Improvement Activities: Traditional MIPS Requirements | Cost: Traditional MIPS Requirements | MIPS Value Pathways (MVPs) | APM Performance Pathway

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