Question

Only recently has Happy Hospital introduced the Merit-based Incentive Payment System (MIPS) to its clinicians.
Which clinicians would be considered “eligible professionals” under MIPS? List the eligible clinicians under MIPS. Also, keeping in mind the most recent MIPS requirements, what measures and sections would you include when reporting? Designing the report mainly involves including the necessary measures and sections that would be included in the report.

Answer 1

What is a MIPS Eligible Clinician?
• MIPS eligible clinicians are both physicians and non-physician clinicians who are
eligible to participate in MIPS
• CMS, through rulemaking, defines the clinician types that are considered MIPS eligible
clinicians for a specific performance year

So What?
• Being identified as a MIPS eligible clinician type is the first step in determining whether
you’re required to participate in MIPS
• Clinicians who are not considered MIPS eligible clinicians are excluded from MIPS

For 2019, MIPS Eligible Clinicians Include:
• Physicians
• Physician Assistants
• Nurse Practitioners
• Clinical Nurse Specialists
• Certified Registered Nurse Anesthetists
• Clinical Psychologists
• Physical Therapists
• Occupational Therapists
• Speech Pathologists
• Audiologists
• Registered Dieticians or Nutrition
Professionals
• Groups of such clinicians

MIPS Requirements

Performance period-

A performance period is the length of time that you or your group are required to report data for a specific MIPS performance
category.
In order to receive the highest possible MIPS final score, you should report data for the minimum performance period under each performance category.

Performance Category Performance Periods for 2019
Quality 12-months
Cost 12-months
Improvement Activities 90-days
Promoting Interoperability 90-days

Performance Category Weight-

A “weight” is the overall value assigned to each performance category.

The performance category weights have gradually increased over the last three performance years.
For the 2022 performance year, when the program is fully implemented, both Quality and Cost will be weighted at 30%.

Performance Category Performance Category Weights for 2019
Quality 45%
Cost 15%
Improvement Activities 15%
Promoting Interoperability 25%

Measures and sections include when reporting-

Collection type – a set of quality measures with comparable specifications and data completeness criteria
including, as applicable, including, but not limited to: electronic clinical quality measures (eCQMs); MIPS
Clinical Quality Measures* (MIPS CQMs); Qualified Clinical Data Registry (QCDR) measures; Medicare Part B
claims measures; CMS Web Interface measures; the CAHPS for MIPS survey; and administrative claims
measures
• Submitter type – the MIPS eligible clinician, group, virtual group, or third party intermediary acting on behalf
of a MIPS eligible clinician, group, or virtual group, as applicable, that submits data on measures and
activities.
• Submission type – the mechanism by which a submitter type submits data to CMS, including: direct, log in and
upload, log in and attest, Medicare Part B claims, and the CMS Web Interface.
- The Medicare Part B claims submission type is for clinicians or groups in small practices only to continue providing
reporting flexibility

What are the different measures used for MIPS reporting?

There are two different categories of quality measures: MIPS measures and QCDR measures. Both can be used for MIPS reporting.

1. MIPS measures are measures that are approved by CMS to be included in the QPP. The MACRA final rule each year also specifies the dermatology specialty measure set. This measure set is not required for dermatologists to report but labels high priority measures that are considered most applicable to dermatologists and the care they provide. Not all measures in the specialty set will be applicable to all dermatologists, but it allows for dermatologists to select a subset of measures that apply to their practice. Any eligible clinician is able to select these measures for use in MIPS.
   
2. QCDR measures are measures that a medical specialty society creates and are approved by CMS for reporting in MIPS. However, these QCDR measures are not available for everyone to report on. QCDR measures can only be reported on if you report through the QCDR that owns/licenses those measures. For the AAD, DataDerm is an approved QCDR that dermatologists can use to report dermatology-specific QCDR measures.