Radiology Coding Alert

Boost your revenue by staying on top of MIPS compliance guidelines.

The Merit-Based Incentive Payment System (MIPS) is a brand-new Medicare initiative that has taken the place of The Physician Quality Reporting System (PQRS).

History: MIPS comes as a result of The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Essentially, the passing of this law ended the Sustainable Growth Rate (SGR) formula, instead introducing a new and improved quality payment program.

For most providers, that program is MIPS. There are a select few who will qualify for the Advanced Alternative Payment Model (APM). In order for a provider to participate in APM, providers must receive 25 percent of their Medicare Part B payments or see 20 percent of their Medicare patients (increasing at yearly intervals) through one of the following models:

• Comprehensive ESRD Care Model (Large Dialysis Organization (LDO) arrangement)
• Comprehensive ESRD Care Model (non-LDO arrangement)
• Comprehensive Primary Care Plus (CPC+)
• Medicare Shared Savings Program ACOs - Track 2
• Medicare Shared Savings Program ACOs - Track 3
• Next Generation ACO Model
• Oncology Care Model (two-sided risk arrangement).

Since these models don’t apply to radiology as much as other specialties, we are going to focus exclusively on MIPS measures.

Here’s How to Transition from PQRS to MIPS

The good news is that the transition between PQRS and MIPS is a relatively smooth one when it comes to applying quality reporting measures. In fact, many of the measures you reported for PQRS have not changed. Additionally, MIPS now assesses quality of care using five revised domains:

• Clinical care,
• Safety,
• Care coordination,
• Patient and caregiver experience, and
• Population health and prevention.

Understanding how to maximize payment adjustments through MIPS requires a basic understanding of what the key similarities and differences are between MIPS and its predecessor:

Key Similarities:

• Quality of care measures are nearly identical.
• Both offer financial incentives for participating in the program.
• Both penalize providers who do not participate (or meet expected requirements) with negative payment adjustments.

Key Differences:

• MIPS requires that providers select six measurements to report (rather than nine previously).
• MIPS does not have a “number of domains” requirement. 
• MIPS relies on a scoring system rather than PQRS’s pass/fail dynamic.

Max Out Profits with MIPS

While the fine details are important, every provider wants to know how they can maximize profits utilizing the newly implemented MIPS system. First and foremost, this can be accomplished by reporting six radiology-specific MIPS measures on at least 50 percent of all Medicare Part B patients (this increases to 60 percent as of 2018). Additionally, these measures should be reported over the course of a minimum of 90 days. If you report more than six measures, you’ll receive credit for the six highest-scoring measures.

Meeting all the necessary requirements on the first year of reporting can yield you a maximum of a 4 percent payment adjustment increase. On the contrary, failing to document MIPS could result in a maximum 4 percent negative payment adjustment. This payment differential of 4 percent will increase to 5 percent in 2018, 7 percent in 2019, and 9 percent from 2020 and beyond. The underlying difference between MIPS and PQRS is that MIPS relies on a sliding scale scoring system while PQRS relied on a pass/fail system. This new dynamic allows for providers to achieve a positive payment adjustment anywhere between 1 and 4 percent depending on their degree of reporting and participation.

Final note: If your practice has yet to make the transition, you’ve got until July 15, 2017, to meet the regular enrollment deadline for MIPS reporting in 2017. Assuming that you have begun reporting before this cutoff date, you’ll want to make sure you are reporting on at least 50 percent of your Medicare Part B patients for a minimum of 90 days.