How to Avoid MIPS Penalty with Minimal Reporting by April 2
By David Doolittle


Is submitting data for the 2018 Quality Payment Program (QPP) so much of a hassle that you’re willing to take a payment cut instead?

You might not be alone.

Of the 62,731 Texas clinicians who were eligible for the 2017 Merit-Based Incentive System (MIPS), 1,830 did not participate and received an automatic 4-percent pay cut in their Medicare payments this year, according to the Centers for Medicare & Medicaid Services (CMS).

For 2018 reporting, your 2020 Medicare payments will be cut even more – by 5 percent – if you are required to participate in MIPS but choose not to submit data.

So if you’d rather get paid in full next year (or – even better – receive a payment bonus), there’s still time to submit 2018 data. But you should act fast. The deadline is April 2. That’s next week.

Don’t be scared. Submitting the minimum amount of information – the least amount of data you can send and still avoid the penalty – is actually pretty easy.

Why is it so easy, you ask? Well, because of ongoing advocacy by the Texas Medical Association and other medical societies around the country, the overall MIPS performance target only slightly increased (from 3 to 15 points) for the 2018 performance year. In other words, you only have to score 15 points to avoid a pay cut in 2020.

If that sounds pretty good to you, the first step is confirming that you are indeed required to participate in the QPP by visiting the CMS website.

Once you’ve figured that out, all you have to do is report the required number of medium- or high-weighted activities in the 2018 MIPS improvement activities category. This could range from one to four activities depending on your practice size, type, and setting.

Scoring the maximum score for that category – 40 points – is worth 15 points toward your overall score, which would mean no penalty in 2020.

Because you can choose from 113 improvement activities, you are likely to find activities your practice regularly performed throughout 2018 that are eligible for MIPS credit: expanded hours, same- or next-day visits, 24/7 access to clinicians, screenings, care management, medication management, seeing new Medicaid or dual-eligible patients, and many more.

To report MIPS improvement activities, you may self-attest by submitting a “yes” response next to each activity you would like to claim credit for via the free QPP portal, or you can use a vendor.

That’s all you have to do.

But if you still need help, review this TMA guide. For guidance on documentation requirements for each activity, download the 2018 MIPS Data Validation Criteria (zip file) and select “2018 Improvement Activities Criteria”.

For more ways on how to achieve at least 15 points for the 2018 performance year, refer to this guide from the American Medical Association.

To get no-cost technical assistance on how to submit your data to CMS, contact the TMF Health Quality Institute. For general questions, contact the 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 all things QPP.

Last Updated On

March 25, 2019

Originally Published On

March 25, 2019

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