How to Submit the Bare Minimum to Avoid 2019 MIPS Penalty

Under the new Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rules, physicians submit data on their 2017 performance, and that data will affect their 2019 Medicare payment rates. TMA has compiled some easy steps you can take now to avoid the 4-percent Medicare penalty in 2019.

To implement MACRA, the Centers for Medicare & Medicaid Services (CMS) designed a new Quality Payment Program (QPP) that has two paths: the Merit-Based Incentive Payment System (MIPS) and advanced alternative payment models (APMs). Although you don't submit data for the 2017 performance period until early in 2018, you may take the necessary steps now to avoid the 2019 MIPS penalty. Here's how.

For the first year, CMS offers a "pick-your-pace" approach to participation. In 2017, you may participate in an advanced APM or submit data under the MIPS program for a full year or for a partial year (90 days), or you may just test the system by submitting a minimum amount of data for any point in time to avoid a penalty. If you choose not to participate in any path in 2017, you will receive an automatic 4-percent pay cut on a per-claim basis to your Medicare Part B payments in 2019. 

CMS will exempt physicians from MIPS in 2017 if they are in their first year of Medicare Part B participation, part of an advanced APM, or are below the low-volume threshold of $30,000 or less in Medicare Part B charges or 100 or fewer Medicare Part B enrolled beneficiaries annually. Access the MIPS lookup tool to find out if you are required to submit data to MIPS or if you are exempt this year. If you’re not exempt, check the list of 53 Texas counties to see if you qualify for a separate MIPS exemption.

Bare-Minimum Requirements

If you are not in an advanced APM and are not exempt from MIPS in 2017, you must complete at least one of the following bare-minimum requirements to avoid the 2019 MIPS penalty:

Quality Category  

  • To submit the bare minimum for this category, you only need to report data on one quality measure for one patient for any point in time in 2017. TMA recommends physicians report on more than just one patient to ensure sufficient data is received by CMS. 
  • Start by reviewing the list of 271 MIPS quality measures and select a measure that applies to you and your patients.
  • The most affordable and easiest way to submit the bare minimum for the quality category is through claims-based reporting. The process to report data on quality measures via claims should be similar to what it was for PQRS, except you will need to refer to 2017 MIPS measure specifications to obtain the most current data codes for the quality measure you choose to report. NOTE: Make sure you use only MIPS codes and not old PQRS codes.
  • Access this step-by-step guide on how to select a quality measure and review measures specifications to obtain quality data code(s) that you will use on a 2017 claim form. MIPS measure specifications for 2017 are located on the CMS website and numbered 001-500.
  • The deadline for claims-based reporting for the quality category for the 2017 performance period is March 1, 2018 (for 2017 claims). Refer to this TMA article for additional details. 
  • If your practice has already submitted 2017 claims and you no longer have the opportunity to report MIPS data via claims-based reporting for the 2017 performance year, then consider submitting data via qualified registryqualified clinical data registry, electronic health record (EHR) or attestation on the new data submission system by March 31, 2018. For a demonstration, see instructional video.

Improvement Activities Category  

  • To submit the bare minimum for this category, you only need to report that you completed one improvement activity for a minimum of 90 days in 2017. 
  • Review the list of 92 improvement activities, and identify at least one improvement activity your practice completed in 2017.
  • The most affordable and easiest way to submit data on improvement activities is by attesting to participation via the new data submission system on the QPP website. For a demonstration, see instructional video
  • The deadline for attestation for the Improvement Activities category for the 2017 performance period is March 31, 2018. 

Advancing Care Information Category  

  • To submit the bare minimum for this category, you only need to attest to meeting the four or five measures that are required for the base score. CMS will accept a minimum of 90 consecutive days of data in 2017. 
  • Review the list of up to 15 measures and two reporting options, and select your reporting option and number of measures required for the base score that corresponds with your EHR edition.
  • For the measure requiring a yes/no response, the answer must be "yes." For numerator/denominator measures, you must report at least "one" in the numerator, meaning at least one patient per measure during the 90-day reporting period to meet the bare-minimum requirements for the base score. 
  • Contact your EHR vendor to inquire about these requirements, whether you will be able to meet them through your EHR system, and to discuss fees for MIPS reporting. You or your vendor can submit data to CMS via the new data submission system on the QPP website. For a demonstration, see instructional video.
  • The deadline for attestation for the Advancing Care Information category for the 2017 performance period is March 31, 2018.  

According to CMS, completing one of the above actions in 2017 will ensure you avoid the 2019 MIPS penalty. However, the more data you submit, the greater the potential for a higher performance score and bonus payment. If you decide to report more data for the 2017 performance period to shoot for a bonus payment in 2019, check out these resources to learn about requirements for full year or partial year participation: 

  • For a general overview of the QPP, explore the CMS QPP website
  • For comprehensive education on how to navigate the QPP, visit the MACRA QPP resource center by the Physicians Advocacy Institute.
  • To communicate with QPP experts, join the learning and action network by the TMF Health Quality Institute for no-cost technical assistance and education via a web-based platform.
  • For customized on-site assistance to help you with your practice’s specific needs, TMA Practice Consulting offers personalized quality improvement services and a MACRA readiness assessment to help you succeed in the QPP.  

For questions, contact the CMS QPP Service Center at (866) 288-8292 or by email at QPP[at]cms[dot]hhs[dot]gov. As always, visit the TMA MACRA Resource Center to stay up to date on the latest information. 

Action, April 3, 2017

Revised, Feb. 13, 2018

Last Updated On

February 14, 2018

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