Practice Management Alert

There's still time to submit before you miss out on a 4 percent bump.

Due to overwhelming confusion, the Centers for Medicare and Medicaid Services (CMS) streamlined the 2017 Quality Payment Program (QPP) data reporting process for eligible clinicians. You still have time to submit your Performance Year 1 data - and potentially receive a Part B pay increase in 2018 - butyou'll need to hurry because deadlines are coming up soon.

"To potentially earn a positive payment adjustment under MIPS, send in data about the care you provided and how your practice used technology in 2017 to MIPS by the deadline, March 31, 2018. In order to earn the 5 percent incentive payment by significantly participating in an Advanced APM, just send quality data through your Advanced APM," says the CMS QPP website.

Know these Basics for Performance Year 1

CMS's QPP began in 2017, as mandated by MACRA. The QPP includes two levels of participation for providers who bill Medicare. The entry-level MIPS falls under the mantra "Pick-Your-Pace" for Performance Year 1 of the new program. Advanced Alternative Payment Models (APMs), on the other hand, concern higher-levels of participation in Medicare programs that support savings, quality, and coordination.

MIPS requirements: To participate in this first performance year, you must be a Medicare Part B physician, physician assistant, nurse practitioner, clinicalnurse specialist, or certified registered nurse anesthetist, or be in a group practice where these clinicians are employed.

If your specialty falls under the QPP criteria, you then must bill $30,000 or more in allowable charges under Part B, as well as provide services to at least 100 Part B beneficiaries annually.

"If a clinician or group does not meet both the Medicare revenue and number of Medicare patients' thresholds, the clinician or group is excluded from MIPS and does not have the option to participate," reminds attorney Benjamin Fee, Esq. of Dorsey and Whitney LLP in the Des Moines, Iowa office.

Beware: You were not required to participate in Performance Year 1 - but "nonparticipation" in 2017's inaugural year will lead to a 4 percent penalty to your 2019 Medicare payment rates, CMS warns. If, however, you want to "test" the waters and ensure steady reimbursement, you may report one quality measure or an improvement activity before the deadline.

Those reporting the all of the 2017 MIPS data will get the biggest benefit, including the possibility of a significant pay boost. But to remain status quo with Part B colleagues and earn a small positive payment adjustment, you'll need to post 90 days' worth of data to equal a "partial year," QPP guidance suggests.

Details: The new data-submission system went live on Jan. 2, 2018, and allows Part B providers to "log into the system, submit data, and satisfy all MIPS reporting requirements," notes a QPP fact sheet on the subject. Large group practices utilize the CMS Web Interface system, which opened up for Performance Year 1 reporting on Jan. 22, 2018.

Before you can send your data, you must register for an "Enterprise Identity Management (EIDM) account and an appropriate user role associated with your organization," the agency advises. And according to the QPP guidance, your EIDM information will be good-to-go across all of your CMS touchpoints and systems.

Resource: Find the EIDM guide and account set-up advice at: www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Enterprise-Identity-Data-Management-EIDM-User-Guide.pdf.

Bonus: If you've been sending your stats through previous "legacy" programs like the Physician Quality Reporting System (PQRS) or Meaningful Use, your accounts will be the same for the QPP. And more importantly, the design of the one-stop reporting option connects your "Taxpayer Identification Numbers (TIN) associated with your National Provider Identifier (NPI) ... with an approved EIDM account," CMS says.

Important Info for MIPS Data Submissions

Once you've established your QPP participation and have an approved EIDM account, you are ready to report your quality data from last year.

A few things factor into the submissions process and pinpoint how and where you plug in your data, the QPP fact sheet says. These factors matter:

• Practice size
• Solo or group practice
• Year of Certified EHR Technology
• Performance category (Quality, Improvement Activities, and Advancing Care Information for 2017 QPP)
• MIPS, MIPS APM, or Advanced APM

Group review: Whether you start by reporting individually or as a group for your practice, you have the option to switch. "We'll retain all submitted data in our system and calculate an eligible clinician's score (and MIPS payment adjustment) using the data that results in the higher score," explains the QPP fact sheet.

Don't forget: The sign-in to report your QPP measuresalso saves as you submit and promises to "calculate" your submissions right up to the deadline, showing youwhatever your payment adjustment will be. "As you enter data, you'll see initial MIPS performance category scoring based on your submissions," the guidance says. However, "this scoring may change if you participate in an APM, report new data, or use quality measures in the Quality performance category that have not yet been benchmarked," the agency warns.

Remember these deadlines: Eligible clinicians reporting through the new login option have until March 31, 2018, to report their Performance Year 1 measures. Group practices utilizing the CMS Web Interface system are on a tighter schedule, with their submission window closing on March 16, 2018.

Resource: To review new CMS guidance on submitting 2017 QPP measures, visit www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/QPP-2017-Data-Submission-Factsheet.pdf.

Try the new data-submissions tool here: https://qpp.cms.gov/login.