MIPS: What is it and what do prescribers need to know?The Merit-Based Incentive Payment System (MIPS) is a system for value-based reimbursement under the Quality Payment Program (QPP) which CMS was required by law to implement. The goal of the program is ongoing improvement and innovation to clinical activities as well as costs saving initiatives. MIPS streamlines the three previous pay-for-performance programs: Value-Based Modifier (VBM), Physician Quality Reporting System (PQRS) and Medicare Meaningful Use (MU) and creates four performance categories : Quality, Promoting Interoperability, Improvement and Cost.
CMS provides additional information here.
The four categories of the Merit-Based Incentive Payment System (MIPS)
QUALITY: This replaces the former PQRS category. It covers quality of care, based on selected performance measures. Providers pick six measures of performance from the applicable choices.
PROMOTING INTEROPERABILITY: This is the former Advancing Care Information performance category, focusing on patient engagement and electronic exchange of health information using certified electronic health record technology (CEHRT). This performance category replaced the Medicare EHR Incentive Program for EPs, also known as Meaningful Use (MU). The focus of this initiative is the coordination of care via the sharing of information either with other clinicians or with patients themselves.
IMPROVEMENT ACTIVITIES: This new performance category includes an inventory of activities that assess how care processes are improved as well as how patient engagement and access to care are improved.
COST: This replaces the formers VBM category. This category calculates the cost of care based on a provider's Medicare claims.
CMS has an 8 page Performance Improvement Categories Fact sheet that can be downloaded here. Here's a glimpse of the overview page:
How does this impact my PMPD use?
According to CMS, PDMP utilization falls under Improvement Activities. In 2018 Improvement Activities count for 15% of a provider’s final score.
Participants must submit collected data for a combination of high- and medium- weighted activities for 90 days or more during 2018.
The full program outline can be found here.
How does PDMP in my practice impact my MIPS score?
Annual registration in the Prescription Drug Monitoring Program is listed in subcategory Patient Safety and Practice Assessment. It’s activity weighting is medium.
CMS states: Annual registration by eligible clinician or group in the prescription drug monitoring program of the state where they practice. Activities that simply involve registration are not sufficient. MIPS eligible clinicians and groups must participate for a minimum of 6 months.
*It is important to note that registration is not sufficient. Participation is a crucial element.
Consultation of the Prescription Drug Monitoring Program is also in the Patient Safety and Practice Assessment category, and is weighted as high.
CMS states: Clinicians would attest to reviewing the patients’ history of controlled substance prescription using state prescription drug monitoring program (PDMP) data prior to the issuance of a Controlled Substance Schedule II (CSII) opioid prescription lasting longer than 3 days. For the transition year, clinicians would attest to 60 percent review of applicable patient’s history. For the Quality Payment Program Year 2 and future years, clinicians would attest to 75 percent review of applicable patient’s history performance.
Template that documents PDMP usage
The American Society of Anesthesiologist has published the template we have included below to outline the documentation of PDMP usage.
The template disclaimer states in part: The template and recommended actions below contains suggestions from the American Society of Anesthesiologists® (ASA) for physician anesthesiologists and their practices to use when documenting a specific Merit-based Incentive Payment System Improvement Activity. Practices may use this template to document certain actions described by CMS Validation Criteria.
This template has not been validated or approved by the Centers for Medicare & Medicaid Services (CMS). Practices may also wish to include additional data or actions not listed below to meet CMS validation criteria.
Other measures in the Patient Safety and Practice Assessment category that have specific reference to opioid or benzodiazepine prescribing or related activities include:
- Completion of the CDC Training on the CDC's Guideline for Prescribing Opioids for Chronic Pain
- Completion of Training and Receipt of Approved Waiver for Provision Opioid Medication-Assisted Treatments
- Implementation of Fall Screening and Assessment Programs (patients on Benzodiazepines are mentioned in the description).
- And if physicians order urine drug testing or other laboratory or radiographic services: Cost Display for Laboratory and Radiographic Orders
We will dig into these and more related to pain management in another upcoming blog post. Stay tuned!
- The Harris County Medical Society provides a 2018 MIPS Step-by-Step Guide to the Clinical Practice Improvement Activities (CPIA) Category, which can be found here.
- The 2018 CMS MIPS Resources Guide can be found here.
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