CMS recently published a toolkit for individual providers and groups who elect to form a virtual group for the CY2019 MIPS Performance Year.  A virtual group is a combination of two or more tax identification numbers (TIN) assigned to one or more individual providers who are MIPS eligible, or one or more groups consisting of 10 or less providers (including at least one MIPS-eligible clinician) that elect to form a virtual group for a performance reporting year. The election period begins on October 1, 2018 and ends December 31, 2018.  The toolkit includes templates for virtual group agreement, election notification to CMS, and fact sheets about the election process and participation.

Centers for Medicare & Medicaid Services (CMS) updated its Quality Payment Program Look-Up Tool to allow clinicians to view 2018 Merit-based Incentive Payment System (MIPS) eligibility and Alternative Payment Model (APM) Qualifying APM Participant (QP) data—in one place.  With the enhanced tool, using your National Provider Identifier (NPI), clinicians can now review their MIPS participation status and/or their Predictive Qualifying APM Participant (QP) status based on calculations from 1/1/17 to 8/31/17.    CMS has also created the ability for group practices to download a list of all NPIs associated with the TIN to view eligibility status of every clinician in the group.   To obtain the detailed group list you must use your EIDM credentials and log into the CMS Quality Payment Program portal.  If you have questions about these tools and how to access them, please email QPP@cms.hhs.gov or call 1-866-288-8292 to speak with a QPP service representative.  

CMS is inviting eligible clinicians to participate in a study that will examine the burden clinicians’ face when reporting MIPS Quality measures.  CMS is specifically targeting the following areas: (1) clinical workflows and data collection methods using different submission systems; (2) challenges clinicians have when they collect and report quality data; and (3) changes to try to lower clinician burden, improve quality data collection and reporting, and enhance clinical care. Successful participation in this study will result in full credit for the 2018 MIPS Improvement Activities performance category. CMS anticipates that the study will run from April 2018 to March 2019.  With the extended deadline applications are due April 30, 2018.  For more information about the study, please email MIPS_Study@abtassoc.com.

In recognizing that MACRA changed the way performance would be scored under the MIPS program, the Centers for Medicare & Medicaid Services (CMS) will continue to address the issues impacted by the MIPS payment adjustments in 2019 and beyond (see CMS slides 45-49 published 4/23/2018) .  In CY2017 Final Rule CMS-5517-FC (pages 77330 – 77332), CMS recognized the payment adjustment challenges faced by individual clinicians (ie, NPIs) associated with more than one group, clinicians using multiple submission mechanisms, and an NPI billing under a new TIN after the performance period.  In their final rule making, CMS determined that performance will follow the NPI even if they leave the group (ie, TIN) before the payment adjustment. CMS intends to “use the TIN/NPI's historical performance from the performance period associated with the MIPS payment adjustment, regardless of whether that NPI is billing under a new TIN after the performance period. In the event that an NPI bills under multiple TINs in the performance period and bills under a new TIN in the MIPS payment year, [CMS will take] the highest final score associated with that NPI in the performance period.”  Unlike PQRS, CRNAs should now be aware that their best MIPS score will follow them into a new TIN.  To learn more about how to participate in the MIPS program visit the AANA Quality Payment Program website. 

CMS now offers two ways to verify your MIPS participation status.  Individual clinicians can continue to go to the MIPS Participation Status Lookup website to verify whether they met the 2018 eligibility criteria using their individual National Provider Identifier (NPI).   For authorized uses that want to view group level data, you may now also choose to log in to the CMS Quality Payment Program website using your Enterprise Identity Management (EIDM) credentials to check your group’s 2018 eligibility for MIPS.   If you don’t have an EIDM account, start the process now by referring to the EIDM User Guide for instructions, noting that the portal still refers to the Physician Quality Reporting System (PQRS).  After logging into this new feature with your EIDM credentials, browse to the Taxpayer Identification Number (TIN) affiliated with your group, and you will be able to click into a details screen to see the eligibility status of every clinician based on their NPI within your group to verify whether you or your group members need to participate in the 2018 MIPS performance year.  The quality payment program helpdesk is prepared to answer questions about the look up tools and participation status by email (qpp@cms.hhs.gov) or phone (1-866-288-8292).

You can now use the updated CMS MIPS Participation Lookup Tool to check on your 2018 eligibility for the Merit-based Incentive Payment System (MIPS).  Just enter your National Provider Identifier, or NPI, to find out whether you need to participate during the 2018 performance year.  The look up tool has been updated to address the changes to low-volume threshold for MIPS eligibility.   CRNAs in APMs should be aware that the CMS will update the Alternative Payment Model (APM) participants look up tool at a later time.  For more information about the visit the AANA Quality Reimbursement Website to learn about how CRNAs are impacted by the Quality Payment Program and MIPS today. 

The Centers for Medicare and Medicaid Services (CMS) is hosting a webinar series with APG to assist clinician groups better understand alternative payment models under MACRA and provide some “how-to” insight into APM implementation.   Subject matter experts from CMS will review the MIPS APM model and requirements for qualifying to become an advanced APM, while APG will offer their strategies behind how they made the transition for their organization/group and share any challenges/pitfalls during implementation.  This webinar will be held on April 30, 2018 at 12:00 pm – 1:30pm ET.  Register for this CMS sponsored webinar.

SCG Health specializes in making MIPS regulatory burdens more approachable so that you can plan how to respond with limited resources and time. AANA Members that become SCG Customers will receive a 10% discount off the retail base subscription of 2018 reporting at $275 per clinician for reporting Quality and Improvement Activities, which must include three or more SCG Health QCDR measures.  The discounted base subscription include submission of quality data to SCG Health, live on-shored call center and online support, data submission, data verification and communication to CMS as required. Contact qpp@scghealth.net  for more information or visit SCGhealth.com/QPP.  Data entry support for calendar year 2018 Quality data is available for AANA members for an additional $500 per clinician (discount does not apply).

CMS Extends the MIPS 2017  Data Submission Deadline from March 31 to April 3 at 8 PM EDT

If you’re an eligible clinician participating in the Quality Payment Program and would like to attest to an improvement activity, you now have until Tuesday, April 3, 2018 at 8 PM EDT to submit your 2017 MIPS performance data. This extension applies to registries as well. You can submit your 2017 performance data using the new feature on the Quality Payment Program website.

Go to qpp.cms.gov and click on “sign in” on the top right side of the web page. 

• You’ll be required to log into the Quality Payment Program data submission feature using your Enterprise Identity Management (EIDM) credentials user name and password. If you don’t have an EIDM account, you’ll need to obtain one. Review this EIDM user guide and get started with the process as soon as possible. Currently, you should allow at least 5 business days for EIDM requests to be processed.
• After logging in, the feature will connect you to the Taxpayer Identification Number (TIN) associated with your National Provider Identifier (NPI).
• You’ll be able to report data either as an individual or as a group. Be sure to login and get familiar with the feature before you submit your data.

Please contact the Quality Payment Program by email at qpp@cms.hhs.gov or toll free at 1-866-288-8292, if you need help or have questions about using the data submission feature.  

Earn MIPS Points:  Participate in CMS MIPS Reporting Burden Study

CMS is inviting eligible clinicians to participate in a study that will examine the burden clinicians’ face when reporting MIPS Quality measures.  CMS is specifically targeting the following areas: (1) clinical workflows and data collection methods using different submission systems; (2) challenges clinicians have when they collect and report quality data; and (3) changes to try to lower clinician burden, improve quality data collection and reporting, and enhance clinical care. Successful participation in this study will result in full credit for the 2018 MIPS Improvement Activities performance category. CMS anticipates that the study will run from April 2018 to March 2019.  Applications are due March 23, 2018.

Some highly influential organizations are making proposals that could significantly alter the Merit-Based Incentive Payment Systems (MIPS) Program as it is currently defined.  Recently, the Medicare Payment Advisory Commission (MedPAC) recommended that the MIPS Program be repealed because its reporting requirements are too burdensome.  Similarly, the White House’s Proposed Budget for 2019 put forward that MIPS eliminate the Advancing Care Information and Improvement Activities performance categories, leaving only the Quality and Cost performance categories.  Adding more fuel to this fire to change MIPS, the Bipartisan Budget Act of 2018, Section 53106, recommends changing the Physician Fee Schedule update drop from 0.50 percent to 0.25 percent for CY 2019 only.  What will happen to MIPS in the future is up in the air, but the Research and Quality Division as well as Federal Government Affairs is actively monitoring all proposals that would affect the program.   As of now eligible MIPS CRNAs should stay the course and continue to participate according to the 2018 MIPS performance period requirements.  Please visit our Quality Reimursement for more information on MIPS and the Quality Payment Program.