Anesthesia Coding Alert

Being in the transition years can still play in your favor.

CMS recently released proposed rules for the Merit-based Incentive Payment System (MIPS) in 2018 that could ease some of the cost and time demands related to the system that many practices are facing.

Read on for a summary of the major changes, and how they could affect your practice.

Upgrade Your Software

The 2018 rule pushes certain EHR requirements forward:

• You can still use 2014 edition CEHRT in 2018 - but you'll receive a 10-point bonus on your Advancing Care Information score (which makes up 25% of your total MIPS score) if you upgrade to the 2015 edition. Using the hybrid 2014/2015 edition doesn't make you eligible for that bonus.
• But keep in mind that the 2015 edition now becomes mandatory in 2019 instead. It's a delay, not a cancellation. Upgrading now will save you time and effort next year, and earn you a bonus in the meantime. The newer edition also contains tools that can help you boost your MIPS score now.

Adjust to Longer Timeframes

The rule proposes 90-day reporting periods for ACI and improvement activities, with a full year for quality and cost measures.

It also delays several requirements until a future year:

• The Cost Performance category is delayed until 2019.
• Like 2017, 2018 will be another year of easier "transition" scoring, with lower performance thresholds than in future years.

Watch for Small Practice Exceptions

The 2018 rule carves out exceptions for smaller practices that may be burdened by requirements:

• Small practices are eligible for a 5-point bonus. Practices with 15 or fewer individual NPI numbers and a group TIN can take advantage of this bonus.
• The low-volume exclusion from MIPS is tripled, from $30,000 per provider annually to $90,000.
• More EHR workflow exclusions, including an exception from eRx if you write fewer than 100 prescriptions per year, and from the "send summary of care" and "receive summary of care" measures for practices with fewer than 100 patients. This move is retroactive to 2017.
• A hardship exclusion for using CEHRT, available to practices with 15 or fewer clinicians, or to those in rural areas or health professional shortage areas.

Consider Joining "Virtual Groups"

The 2018 rule presents the option for smaller practices to join up and submit MIPS together as a larger "virtual group":

• Practices with 10 or fewer providers can now enter into agreements to submit jointly, with all partic­ipants receiving the same MIPS score.
• Virtual groups offer small or solo practices the opportunity to pool costs and other resources, making it easier and less expensive to aggregate their information. Each practice could end up with higher reimbursements and better patient care than if they went at it alone.
• Joining a virtual group also lowers certain requirements, including those for your ACI base score and your improvement activities.

Make the Best Use of Transition Years

These 2018 rules do smooth out some of the severity of the requirements, but it's important to keep in mind » » that 2018 will be the final transition year before full implementation. Don't use that leniency as an excuse to put off preparing your practice.

Mike Schmidt, Director of Compliance and Special Projects for Medflow, advises you to "think of MIPS as a game - your main goal is to practice getting good at the game during these transition years." Just like any game, MIPS has rules and a scoring system, all of which you can learn and improve at now to get higher reimbursements down the line.

For more information, read the full text of the new CMS rules here: https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-13010.pdf.