Quick-Look Comparison: MIPS 2017 vs. 2018 requirements

Are you keeping an eye on the progress of MIPS to understand whether it should be a priority for your medical group, practice, IPA or health system? The recent proposed rule for 2018 QPP gives us some insight on how the program will evolve. Here is a quick-look comparison on the fundamentals of the program, and where the requirements are likely to increase, stay the same, or relax.

Which requirements are proposed to increase?

2017 Actual 2018 Proposed Comments
Total penalty and reward +/- 4% +/- 5% This increase is expected based on the increases required by law.
Performance threshold to avoid a negative payment adjustment Composite Performance Score of 3 points Composite Performance Score of 15 points This is the number of points required to avoid a negative payment adjustment. The significant increase means that in 2018 it will no longer be possible to avoid a negative payment adjustment by reporting just one measure.
Data completeness requirement for quality measures 50% of patients across all payers 60% of patients across all payers This is an increase in the percentage of eligible patients required to be reported for each quality measure.
Points awarded for quality measures that don’t meet data completeness requirements 3 points 1 point (except small practices will still earn 3 points) This reduces the value you can gain from incomplete reporting in the quality category.
Quality reporting period 90 days 12 months The new 12-month reporting period mirrors PQRS requirements

Which requirements are proposed to stay the same?

2017 Actual 2018 Proposed Comments
Performance category weights Quality: 60%
Advancing Care Information: 25%
Improvement Activities: 15%
Cost: 0%
Quality: 60%
Advancing Care Information: 25%
Improvement Activities: 15%
Cost: 0%
This is a change from the expected breakdown, which originally included a 10% weight for cost in 2018.
ACI and Improvement Activities performance periods 90 days 90 days This is the minimum period you must report on for these categories to earn a maximum score.
Exceptional performance threshold Composite Performance Score of 70 points Composite Performance Score of 70 points This is the threshold above which you are eligible to earn incentive payments from the $500M bonus pool.
CEHRT Requirements 2014 certification required, 2015 certification optional 2014 certification required, 2015 certification optional (but with bonus points for use of exclusively 2015 CEHRT) This is different from the original expectation that 2015 EHR certification would be required in 2018. However there is still a benefit for using a 2015 certified system due to the added bonus points.

Which requirements are proposed to relax?

2017 Actual 2018 Proposed Comments
Low-volume thresholds Clinicians or groups with ≤$30,000 in Part B allowed charges or ≤100 Part B beneficiaries are excluded from MIPS Clinicians or groups with ≤$90,000 in Part B allowed charges or ≤200 Part B beneficiaries are excluded from MIPS This will mean that some clinicians and groups reporting in 2017 will not need to report in 2018.
Small practice bonus points Small practices (15 or fewer clinicians) do not earn additional bonus points Small practices automatically earn 5 bonus points in their final score as long as they submit data in at least one performance category This is an additional benefit for small practices to help them perform well in the program.
Benefit for providers with complex patient populations No bonus is given to clinicians and groups serving complex patient populations Clinicians and groups can earn up to 3 bonus points based on complexity of their patient population The proposal is to use the average HCC score to determine this bonus.

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Further reading:
At long last: The documentation you need for Improvement Activity audits
Need to Know: Highlights from the 2018 QPP Proposed Rule and What It Means for You

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