Avoiding a penalty in 2018 MIPS: the nuts and bolts

The 2018 Quality Payment Program final rule is here, and the MIPS requirements are increasing toward full implementation in 2019. One of the biggest changes between 2017 and 2018 for providers participating in MIPS is that the threshold for avoiding the negative payment adjustment is jumping up from 3 points in 2017 to 15 points in 2018 (out of 100 total possible points). This means that in order to avoid a -5% payment adjustment on your Part B payments in 2020, you will need to earn at least 15 points in your MIPS Composite Performance Score (CPS) in 2018.

That’s a bit leap from 2017. This year, submitting any data for one measure will be sufficient to avoid the negative payment adjustment. Not so in 2018. In this article, Able Health breaks down four ways that you can achieve the 15 points in 2018 required to avoid the negative payment adjustment.


Approach #1: Meet ACI base score and submit 1 quality measure that meets data completeness

First a note on data completeness in the Quality category: in 2018 if you submit a measure that does not meet data completeness, meaning that you report less than 60% of patients eligible for that measure, then you will receive 1 point. If you submit data that does meet data completeness for a measure, you will receive at least 3 points on that measure.

Therefore,if you report one quality measure that meets data completeness, then you will earn 3/60 points in the Quality category. If you meet the ACI base measures, then you will earn 50/100 points in the ACI category, bringing you up to 15 CPS points.

50/100 ACI points * 25% = 12.5 CPS points

3/60 Quality points * 50% = 2.5 CPS points


Approach #2: Meet ACI base score and submit one medium-weighted improvement activity

Similarly, if you meet the ACI base measures and attest to at least one medium-weighted improvement activity, it will earn you 15 CPS points.

50/100 ACI points * 25% = 12.5 CPS points

10/40 IA points * 15% = 3.75


Approach #3: Submit 6 quality measures that meet data completeness criteria

Recall that a Quality measure that meets data completeness will earn you at least 3 points in the Quality category. Therefore, if you report 6 measures, this will earn you enough points to meet the 15 point minimum performance threshold.

18/60 Quality points * 50% = 15 CPS points


Approach #4: Earn 100% in the Improvement Activities category

Full credit in the IA category will earn you 15 Composite Performance score (CPS) points. This is because Improvement Activities are worth 15% of your final CPS.

40/40 IA points * 15% = 15 CPS points


As you prepare for next year, keep in mind the requirements to meet the minimum threshold. 2018 is a bridge year between the very minimal 2017 performance requirements, and full implementation of MIPS beginning in 2019. Able Health can help you meet the requirements and make sure you are on track to succeed as MIPS continues to ramp up toward full implementation.


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Further reading:
2018 MIPS Composite Score Overview: How you will be scored in year 2 of the Merit-Based Incentive Payment System
6 ways to improve MIPS quality performance with the data you already have

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