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(Blog post #3 in a series covering 2016 anesthesia quality reporting)

When the permanent “doc fix” became law last year, it created two new quality-reporting tracks for providers. Starting in 2019, providers pursuing Medicare reimbursements must choose either the Merit-Based Incentive Payment System (MIPS) or Alternative Payment Models (APM).

We’ll cover APM in a subsequent blog post; the following will give you a good feel for what’s defined at this point regarding MIPS – a fee-based approach to Medicare with a familiar feel, plus important new dimensions.

MIPS’ blending of existing and new elements

At the end of 2018, MIPS will absorb meaningful use, the value-based payment modifier and PQRS reporting penalties, rolling their requirements into a single program. MIPS will also add a new category, “clinical practice improvement activities,” which will include care coordination, patient satisfaction and access measures.

Many anesthesia groups may opt for MIPS rather than APM, as MIPS is a continuation of multiple, familiar elements. abeo will be standing by to help its clients determine which methodology is the best fit for them in the coming months. The key to begin thinking about MIPS is to understand how its elements work together to determine payments.

MIPS scoring

MIPS includes four performance categories, weighted as shown below (note: the first two years will weight quality higher, and resource use lower):

  • Quality (PQRS and QCDR measures) – 30 percent
  • Resource use (cost measures and patient attribution) – 30 percent
  • Meaningful use – 25 percent
  • Clinical practice improvement activities (care coordination, patient satisfaction, access measures) – 15 percent

With MIPS, scores in each category are totaled for a composite score, which can range from 0 to 100 points. The HHS Secretary will set a threshold each year that equals the mean of all EPs’ composite scores from the prior year. The mechanism that will determine the first year’s threshold has not yet been specified.

MIPS payment adjustments

To calculate annual payment adjustments under MIPS, each EP’s score will be compared to the threshold. EPs with scores above the threshold will receive positive payment adjustments, and those below the threshold will incur penalties. Scores equal to the threshold will receive no adjustments.

Because MIPS is budget-neutral, all bonus payments within a given year will be offset by penalties for that year. The range of maximum positive/negative adjustments will steadily grow in the first four years of MIPS, from +12 percent / -4 percent in 2019 to +27 percent / -9 percent in 2022 and thereafter.

Keeping an eye on future developments

This is what we know so far about Merit-Based Incentive Payment System, MIPS; we will relay additional program aspects as they become defined, and will supply our clients with what they need to know to prepare for this coming shift. Coming up in this space: The elements of APM, and how it differs from MIPS.

Read earlier posts from our 2016 Anesthesia Quality Series:

Post #1 CMS Quality Reporting Changes: Market Myths vs What You Really Need to Know
Post #2 2016 Claims-Based Quality Reporting: Simpler Than You Might Think

The information provided is intended to be a general summary and reflects information that is current at the time it was issued. This information is not intended to take place of either written law or regulations.


abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

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