In 2018, ACI (Advancing Care Information, or as it’s now known, Promoting Interoperability) is worth 25 MIPS (Merit-based Incentive Payment System) points. However, to avoid getting a penalty this year, practices only need to earn 15 MIPS points. You can reach that goal by performing your Improvement Activities. (INSTRUCTIONS HERE).

Is more effort for MIPS worth the payout?

Only you can decide the effort your practice makes for MIPS payouts. However, we can provide you with some information to consider while making that decision.

In 2017, 91% of MIPS eligible clinicians successfully participated in MIPS, which means only 9% failed to meet 3 MIPS points. Because the payout for MIPS is budget neutral (i.e. the money taken via penalties is what’s available for bonuses), it was a very small penalty pool to draw from for bonuses.

Here are the 2019 fee schedule adjustments for 2017 participation:

0 MIPS points = -4%
3 MIPS points = neutral
15 MIPS points = +0.05% (now +0.04%)
40 MIPS points = +0.16% (now +0.11%)
100 MIPS points = +2.02% (now +1.88%)

The fee schedule adjustments for 2019 are going even lower. On September 13, CMS (Center for Medicare/Medicaid Services) announced there were errors and they inappropriately penalized people for 2017, and inappropriately missed exclusion applications, so they are rescinding some penalty money, so the bonuses are dropping. The review will continue until October 15, so those rescinded penalties may increase. CMS is expecting 93% participation in 2018, and 95% participation in 2019.

From a financial standpoint, it might make sense to just go neutral in MIPS to avoid a penalty. However, a practice’s MIPS score is public information – meaning that private insurances might take this into account and potential patients might interpret low scores to mean that they wouldn’t receive good care, which wouldn’t necessarily be true.

If you want to do better than just avoiding a penalty, you should still consider not doing ACI. Since ACI is only 25 MIPS points, you can still earn at least 65 MIPS points through TRAKnet.

Most of our TRAKnet clients have 15 or less providers and those practices can exclude themselves from ACI, which would shift the 25 MIPS points over to a different portion of MIPS, called Quality. Quality is easy to perform and has not changed from 2017. Most of TRAKnet providers have already been doing Quality. Excluding your practice from ACI would make Quality worth up to 75 MIPS points. If you then add in Improvement Activities, that’s up to 90 MIPS points. Medicare considers you to be an “exceptional performer” if you get over 70 MIPS points, so it’s very easy to go above and beyond the call of duty without ever touching ACI.

If your decision is to remain neutral for MIPS, you can download our how to document for TRAKnet HERE. You can also watch our videos:

Need to check your MIPS eligibility? https://qpp.cms.gov/participation-lookup

Want to apply for ACI exclusion? Go here: https://qpp.cms.gov/mips/exception-applications?py=2018