American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

Steps for Potentially Receiving an Increase in Medicare Payment but Definitely Avoiding a Penalty

1. Determine if all of your MIPS data will be reported by your institution or group via a Group Reporting option (GPRO).

  1. If “YES,” you are done.
  2. If “NO,” move to number 2.

2. Has CMS notified you that you are exempt from participating in MIPS due to the LOW-VOLUME THRESHOLD?

  1. If “YES,” you are done.
  2. If “NO,” move to number 3.

3. If you want to compete for positive updates in your Medicare payment rates in 2019 (based on 2017 reporting), read the ACS Quality Payment Program Manual, watch the videos, and develop your plan.

4. If your goal is simply to AVOID A PENALTY, CMS only requires data be reported for one of the following:

  1. Required Base Score measures for your EHR (now known as Advancing Care Information) OR
  2. One Improvement Activity for 90 days (report by simple attestation) OR
  3. One Quality Measure on one patient (report by registry, QCDR, EHR, or claims)

Note: One is NOT required to have a certified EHR to avoid a penalty for 2017.

5. If you did not report PQRS data and did not participate in the electronic health record meaningful use program in 2016 and have no intention of participating in MIPS in 2017:*

  1. Your lack of participation in 2016 programs will lead to a 10% negative payment adjustment in 2018.
  2. Your lack of participation in MIPS in 2017 will lead to a 4% negative payment adjustment in 2019.

*Note: This option is not recommended, as in future years the annual cuts will gradually increase to 9%.

MIPS is set up as a tournament model. In other words, “Losers” pay for “Winners.” Don’t put your money in someone else’s pocket. The ACS strongly encourages ALL Fellows to, at the MINIMUM, participate at the level sufficient to AVOID A PENALTY in 2017 and, thus, not serve as the “pay for” for another provider.