MIPS Tips No. 2: Five Things You May Not Know About MIPS

MIPS is here, and it’s not going anywhere. It’s possible that you may still have questions about this value-based payment model, so we have compiled some tips to help you along the way. In our first MIPS Tips post, we covered eligibility and participation, performance, and payment adjustments. Today, we will focus on five things you may not know about MIPS. 

1. You should consider participating in MIPS, even if you are not required to do so.

MIPS, or Merit-Based Incentive Payment System, is exactly what it sounds like: an incentive-based system designed to reward you for great care—or require you to pay a specific adjustment based on less-than-optimal care. Although there are pros and cons to any healthcare system, there are two good reasons why you should consider opting into MIPS.

As previously mentioned, opting into MIPS allows you to potentially earn incentive payments based on the data collected from your practice. This means a higher income that could allow you to incorporate newer technologies or modalities to better serve your patients in practice. Secondly, by participating in MIPS now, you can prevent confusion later on when MIPS participation becomes mandatory for your practice and others in the medical field.1

2. The MIPS Data Submission Deadline for this year has been changed. 

Due to the unforeseen circumstances of the present day, the deadline for submissions has been extended to April 30, 2020 at 8 p.m. EDT, according to the Quality Payment Program. If you submit to MIPS after April 30, 2020, “you will qualify for the 2019 automatic extreme and uncontrollable circumstances policy and receive a neutral payment adjustment in 2021.3

3. You can participate in MIPS as a Virtual Group.

Since participation is still optional at this time, you can choose to participate as an individual, a group, or a Virtual Group. According to the Quality Payment Program, “A Virtual Group is a combination of two or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together ‘virtually’ (no matter specialty or location) to participate in MIPS for a performance period of a year.3” 

4. Your eligibility in MIPS can change for a variety of reasons. 

The eligibility that you initially have when you opt into MIPS isn’t set in stone for the rest of your career. Your eligibility could change when you join a new practice, when you fall below the low-volume threshold, or when there is a change to your specialty code or provider type.4 There are a number of other reasons why your eligibility in MIPS could change, so be sure to communicate your questions to the Centers for Medicare & Medicaid Services (CMS).

5. You can qualify for Special Status in MIPS.

Being designated with Special Status in MIPS is another way for CMS to categorize eligible clinicians or groups of clinicians who participate in the program. Clinicians who qualify for Special Status have reduced reporting requirements. It applies to clinicians practicing in rural areas, non-patient facing, hospital-based, or ambulatory surgical center-based areas, or small practices/Virtual Groups with 15 or less clinicians.5

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1“MIPS Or Not? .” American Physical Therapy Association, 2018, www.apta.org/uploadedFiles/APTAorg/Payment/VBC/QPP/MIPS/MIPSDecisionTree.pdf.

2“The Quality Payment Program.” The Quality Payment Program, qpp.cms.gov/. Accessed 24 March, 2020.

3“MIPS Overview.” The Quality Payment Program, https://qpp.cms.gov/mips/overview. Accessed on 24 March, 2020.

4“Eligibility Determination Periods and Snapshots.” The Quality Payment Program, https://qpp.cms.gov/about/eligibility-determination-periods-and-snapshots?py=2019#eligibility-change-2019. Accessed on 24 March, 2020. 

5“Reporting Factors Overview.” The Quality Payment Program, https://qpp.cms.gov/mips/reporting-factors-overview. Accessed on 24 March, 2020.

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