MIPS 101 for Mental Health Practices

By Tolu Ajiboye  |  March 11, 2019

A recent policy change made to the Quality Payment Program (QPP) now makes clinical psychologists eligible to participate in MIPS. As of the January 1, 2019, clinical psychologists now join psychiatrists in being eligible to participate in CMS's value-based incentive program. All eligible specialty providers receive a positive, neutral or negative payment adjustment to their Medicare Part B claims. Are you ready for MIPS?

Here are the important things you, as a mental health clinician, need to know about MIPS and reporting for it.

An Overview of MIPS

The Merit Incentive-Based Payment System (MIPS) is one of the two tracks under the Quality Payment Program (QPP), and it was established to help clinicians focus more on caring for their patients. Clinicians are rewarded (or penalized) under MIPS based on their values and patient outcomes.

MIPS has four divisions known as ‘Performance Categories’, under which you’ll submit data. Your performance in these categories determines your MIPS final score and the upper score limit is a 100 points. Your score then determines whether your earnings will be subject to a negative or positive payment adjustment, and to what extent. For the performance year of 2019, the maximum you can receive as an incentive/positive payment adjustment is +7% while the maximum reduction is -7 %.

Here are the four performance categories and what they measure:

  • Quality: This measure is centered on the quality of the care you provide to your patients and it makes up the largest portion of your final score- 45%. There are many performance measures and CMS allows you to choose 6 you feel are best suited to your practice from them. You can find the measures here.
  • Improvement activities: This performance category, 15% of your score, concentrates on the ways you improve your methods of care and patient engagement. You can learn about the performance measures here.
  • Promoting Interoperability: It’s 25% of your final score and you can learn more about the performance measures here.
  • Cost: This category is 15% of your final score and you will not need to submit any data in this category at all. This is because CMS will gather and utilize data from Medicare to grade your performance. You can learn more about the 10 cost measures against which your performance will be assessed here.

Kareo Sr. Training Specialist and MIPS expert Marina Verdara advises, “ You should select measures that are within your specialty. The quality payment program website is a great resource where you can find out details about the different performance measures listed out- with filters so that you can easily narrow it down to what applies to you.

Q&A: What Mental Health Clinicians Should Know about MIPS Reporting

Do I have to participate in MIPS?

As a clinical psychologist, there are specific criteria called Low Volume Threshold Criteria that you must meet before you will be required to participate in MIPS.

As specified by Centers For Medicare and Medicaid Services (CMS), in order to be MIPS eligible, you must:

  • Bill more than $90,000 in Medicare Part B allowed charges for covered professional services payable under the Physician Fee Schedule (PFS)
  • Provide covered professional services for more than 200 Part B-enrolled beneficiaries
  • Provide more than 200 covered professional services to Part B-enrolled beneficiaries

If you don’t meet all three of these criteria, but meet 1 or 2, you can decide to voluntarily join MIPS and let your practice’s earnings be subject to the payment adjustments.

To what extent do I have to participate?

To avoid any negative payment adjustment, if you are required to participate in MIPS, you simply have to submit the minimum points for the performance year. For 2019, you’ll need to submit 30 points to land safely in the neutral payment adjustment area.

Are there any particular requirements I must fulfill to participate in MIPS?

The major requirement you should know of is that you must be using Certified Electronic Health Record Technology (CEHRT) in order to participate in MIPS. CEHRT are clinical software certified by the Office of The National Coordinator for Health information technology (ONC), and for the purposes of MIPS, it must be the 2015 edition (most recent).

So if you’re a clinical psychologist, that meets all three of the Low Volume Threshold Criteria, and you’re not already using a 2015 Certified EHR platform, you should make plans to migrate onto one expeditiously.

Are there any specific challenges I could face as a mental health clinician when reporting for MIPS?

It is possible that you may face some difficulties with some of the performance measures in the Promoting Interoperability category, especially the ones that relate to patient engagement.

“Several of the measures and objectives require patient engagement. They require that the patient create an account (log in and password) for the patient portal and go in there, view their medical records and communicate with their provider via secure messaging,” Verdara explains. “if you have a lot of patients with intellectual disabilities who are not able to manage a computer or a smartphone, for instance, and as such cannot log into their patient portal, you may struggle with meeting these requirements."

Also, sometimes the patients’ caregivers, if they have any, may also not be interested in navigating and managing the patient's health via a patient portal, and that can be a further impediment in scoring high in those areas.

When is the submission period for MIPS reporting?

Data for the performance year must be submitted within the first three months of the next year. This means that, for instance, data for the performance year of 2019 must be submitted between the January 1, 2020 and March 31, 2020. If you don't submit the data during that time period, and you are compulsorily required to participate in MIPS, your earnings will be subject to the negative payment adjustment.

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To learn about how the Kareo Clinical 2015 edition Certified EHR can help you manage your MIPS documentation and reporting: 

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