In the last post in our MACRA 101 Series, we talked about how to tell if you were eligible to participate in MACRA and MIPS. In this post, we’ll talk a little about your options for participating in MIPS during the 2017 Transition Year.
Pick Your Pace
2017 is the first performance year. It determines the percentage of increase, or penalty, in payment adjustments for 2019. The percentage is capped at +/-4%. During 2017 you can pick your MIPS participation pace. The choice is yours. You can choose to:
Not participate
Test Pace
Partial Year
Fully Participate
Let’s take a look at each of those options:
Not Participate
You can decide not to participate during 2017. But there’s a catch… Not sending any data during 2017 means you will receive a -4% payment adjustment in 2019. You miss out on any gain. And your payments will be penalized.
Test Pace
Perhaps you haven’t yet gotten started with MIPS, yet. You certainly don’t want to be penalized – especially if you can start taking steps now. If you submit ‘some’ data after January 1, 2017, you will get a neutral payment adjustment in 2019. You won’t get an increase in payments, but at least you won’t have a decrease.
To avoid a downward adjustment, submit at least one of the following:
1 Quality Measure
1 Improvement Activity
4-5 required Advancing Care Information Measures (depends on your EHR system qualifications)
Partial Year
You’ve been planning ahead, but still, haven’t started with MIPS. If you want to get in on seeing a rise in your payment adjustment in 2019 – the Partial Year option might be for you. You can still benefit from a small positive payment adjustment. As long as you start anytime before October 2, 2017.
You qualify by reporting one, or more, 90-day period(s) after January 1, 2017. The percentage of your positive payment adjustment depends on how much data you report. Here is the minimum for a positive payment adjustment:
Report more than one Quality Measure
Report more than one from the Improvement Activity
and the minimum requirements from the Advancing Care Information Measures
Keep in mind; it’s not just the amount of requirements you report. The quality of the information you report affects what your payment adjustment will be.
Fully Participate
If you fully participate during all of 2017, you will benefit from a modest positive payment adjustment in 2019 – This is the best way to get the most out of MIPS.
You are also eligible to be considered an Exceptional Performer. An Exceptional Performer may qualify for an additional positive payment adjustment, on top of the 4%.
Future ‘Performance Years’ and related payment adjustments
The payment adjustment starts out at +/-4% for 2017. It then rises over the next few years. Here’s what you can expect:
2018 will be the performance year for 2020 and is capped at +/-5%.
The payment adjustment jumps to +/-7% in 2021, based on your performance in 2019.
2020 marks the performance year when the payment adjustment is raised to +/-9% in 2022.
All the following performance years will remain at +/-9%.
2017 is just the beginning. You have the flexibility to ease yourself into the MACRA and MIPS requirements now. Take advantage of the Transition Year to get your reporting where it needs to be. In future performance years, that flexibility goes away.
This post was a high-level look at pacing options for 2017. You got a look at the different paces of participation, and the payment adjustments you might expect. In the next MACRA 101 Series post, you’ll get a peek at a summary of the MIPS Performance Categories.
In the meantime – comment below! What does the Transition year mean to you and your organization? Let us know what has worked for you, or where you are struggling. Have you already started? Almost ready, and just about to start? Or are you still trying to figure things out?
Richards, A. (2016, November 10). Quality Payment Program – Executive Summary [PDF]. CMS.gov.
Quality Payment Program – Executive Summary. Centers for Medicare & Medicaid Services. 42 CFR Parts 414 and 495 [CMS-5517-FC] RIN 0938-AS69 [PDF]. (2016, October 14). CMS.gov.
Future ‘Performance Years’ and related payment adjustments
