Make a Penalty-Free Shift From Meaningful Use to MIPS

Q. The Advancing Care Information (ACI) performance category under the Merit-Based Incentive Payment System (MIPS) replaces the meaningful use incentive program. I’m confused about the overlap of dates. ACI reporting starts this year, but meaningful use penalties extend to 2018. Will there be extra work during the transition for physicians who participate in meaningful use and choose to participate in MIPS?

A. 2016 data you submitted (or failed to submit) to the Medicare EHR Incentive Program (meaningful use) affects your 2018 Medicare payments, with either no adjustment or a downward adjustment (a penalty). MIPS reporting started in 2017, so there’s no overlap there. The question to ask is whether you have reported successfully to the meaningful use program in the past.

If you have successfully demonstrated Medicare meaningful use in a year before 2017:

Beginning with reporting periods in 2017 for the 2019 payment year, you no longer will report to the meaningful use incentive program. Instead, you’ll report to MIPS and be subject to its program requirements. Here’s how to submit the bare minimum data to avoid the 2019 MIPS penalty. (Medicaid meaningful use participants will continue to attest to through the Texas Medicaid EHR Incentive Program Portal to earn an incentive payment).

If you are participating in the Medicare EHR Incentive Program for the first time in 2017:

You must take one of the following actions by Oct. 1, 2017, to avoid the 2018 payment penalty:

  1. Attest to the Modified Stage 2 2017 EHR Incentive Program requirements; OR
  2. Submit a one-time hardship exception application if you are transitioning to the MIPS path of the Quality Payment Program in 2017 and plan to report on measures specified for the Advancing Care Information performance category.

Note that some physicians may be exempt from MIPS in 2017 — you can check your status online. However, being MIPS-exempt doesn’t affect a physician’s status as a first-time participant in the Medicare EHR Incentive Program; meaningful use first-timers must take one of the steps above to avoid the 2018 penalty, regardless of their MIPS status.

For More Information About MIPS

Published June 14, 2017

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Last Updated On

June 14, 2017

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