The Merit-based Incentive Payment System (MIPS)
MIPS combines the Physician Quality Reporting System (PQRS), the Physician Value-Based Modifier and Meaningful Use into a single performance-based payment system. It also adds an additional performance domain – Improvement Activities. MIPS is the default payment system for all providers unless they meet the criteria for successful participation in an Advanced Alternative Payment Model (APM).
The weighting for each of the four MIPS categories – Quality, Cost, Promoting Interoperability (formerly Advancing Care Information), and Improvement Activities – in 2019 are below:
The Quality category replaces the PQRS and requires providers to report on quality measures. Scoring in this category will be based on performance on those measures providers choose to report.
In 2019, providers will be required to report on at least six quality measures, one of which is an outcome measure. For hospitalists, the quality category will be 70% of their MIPS score in 2019. Most hospitalists will not have enough quality measures to report and will be subject to a validation process to ensure there were no other measures available to them.
Read SHM's MACRA and the Quality Payment Program | Frequently Asked Questions (FAQs) for further information on this process.
The Promoting Interoperability – formerly Advancing Care Information – category replaces the Meaningful Use program and is centered around the use of Certified Electronic Health Record Technology (CEHRT). Hospitalists who meet the definition of “hospital-based” will be automatically exempt from ACI, which would shift the category weight to the Quality category. “Hospital-based” is defined as providers who bill 75% or more of Medicare Part B services in Place of Service 19 (off-campus outpatient hospital), 21 (inpatient), 22 (hospital outpatient) and 23 (ER).
Hospitalists who practice significantly (>25% of services) in settings such as skilled nursing facilities (SNFs) will still be subject to this category. SHM recommends these providers apply for hardship exceptions if they are unable to meet the category requirements.
The Improvement Activities category is based upon providers completing a range of activities designed to improve or expand provided care. CMS created an Improvement Activities inventory, with more than 90 activities assigned weights of high (20 points) or medium (10 points). Providers need to attest to 40 points worth of activities during the performance year.
The Cost category comprises cost and efficiency measures, such as the Total Per Capita Costs and Medicare Spending Per Beneficiary measures from the current Value-Based Payment Modifier (VBPM). Scoring in this category is based on performance in CMS calculated cost measures.