MIPS 101 for Anesthesia Providers

Are you an anesthesia provider participating in the Merit-Based Incentive Payment System (MIPS)? Let us tell you how the SurveyVitals solution might help you fulfill certain reporting requirements.

What is MIPS?

The Merit Incentive Payment System (MIPS) is one of two tracks in the QPP, the quality payment incentive program implemented by CMS. A small percentage of clinicians will qualify to participate in the Alternative Payment Models (APM) track, but most anesthesiologists will fall under the MIPS track.

You will receive a performance-based adjustment to your Medicare fee schedule in 2021 based on your MIPS performance in 2019. The amount of the adjustment, either positive, negative, or neutral, is based on an eligible clinician or group’s Composite Performance Score (CPS). The CPS is calculated using data across four categories of measurement.

Who participates?

If you bill Medicare Part B more than $90,000 in allowed charges per year and provide over 200 covered professional services under the Physician Fee Schedule for more than 200 unique Medicare patients a year, then you are part of the QPP. If you do not meet all three criteria, you could be exempt from participating in the program in 2019 under the the low-volume threshold exemption. Beginning in 2019, clinicians who meet the low-volume threshold may still opt in to MIPS if they meet at least one criterion.

To determine if you are required to participate in MIPS, CMS has provided a resource to check your status by entering your NPI into an eligibility “calculator.”

How are measures reported?

Anesthesiologists have the option to report as an individual, within a group, or within a virtual group.

Individual	Single NPI tied to a single Tax Identification Number (TIN)
Group	Single TIN with two or more eligible clinicians, including at least one MIPS-eligible clinician, as identified by their National Provider Identifiers (NPIs), who have reassigned their Medicare billing rights to the TIN
Virtual Group	Combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of ten or fewer eligible clinicians

Reporting mechanisms vary based on reporting type and measure category. You can find more information on reporting mechanisms here.

How are measures selected?

Anesthesia providers and groups can select measures from the list of CMS-approved MIPS measures at the QPP website. Alternatively, they may select to report on Quality performance using specialized measures developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDR measures must be approved each year by CMS.

Quality Category

Anesthesiologists are required to report on six measures of their choosing for the quality category. One of those measures must be an outcome measure.

SurveyVitals is equipped to help anesthesia clients utilizing a QCDR to meet an outcome measure (AQI48 – Patient-Reported Experience with Anesthesia) in the Quality category. You must sign a disclaimer in order to report your patient experience data to a QCDR. View the reporting checklist, quick facts, and important deadlines here.

Improvement Activities (IA) Category

Anesthesia providers are required to participate in a combination of IA measures totaling 40 points. “High-weighted” activities are worth 20 points, while “medium-weighted” activities are valued at ten points. Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at info@surveyvitals.com to learn more.

Reporting requirements for Improvement Activities are reduced for non-patient facing clinicians, which are defined as either:

• An individual clinician that bills 100 or fewer patient-facing encounters (including Medicare telehealth services), or
• A group that provided more than 75 percent of the clinician’s billing under the group’s TIN

Those considered non-patient facing must participate in one high-weighted activity or two medium-weighted activities to satisfy the Improvement Activities category (for a total of 20 points rather than 40).

Always remember to check the eligibility calculator on the QPP website to confirm you are considered non-patient facing.

Promoting Interoperability Category

The Promoting Interoperability (formerly Advancing Care Information) category places an emphasis on interoperability and patient engagement with certified EHR technology. Eligible clinicians must meet five required measures in the Promoting Interoperability category, with the opportunity to earn additional bonus points for up to 9 total measures.

Many anesthesiologists are exempt from fulfilling the Promoting Interoperability requirements due to having hospital-based special status. CMS defines a hospital-based clinician as a MIPS-eligible clinician who furnishes 75 percent or more of his or her professional services in a site of service identified by the following Place of Service (POS) codes used in HIPAA standard transactions:

• Inpatient hospital (POS 21)
• On-campus outpatient hospital (POS 22)
• Emergency room setting (POS 23)

Always remember to check the eligibility calculator on the QPP website to confirm you are considered hospital-based.

Cost Category

The score for the Cost category is calculated using administrative claims data. No data submission is required.

Interested in meeting MIPS measures with SurveyVitals?

Want to learn how SurveyVitals can help you prepare for MIPS? Email us at support@surveyvitals.com. You can also send us a message using the blue chat icon below to speak to a member of our support team.

*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.

admin June 3rd, 2018 Categories: Anesthesia, MIPS Information

Tags: anesthesia, anesthesiologist, CRNA, improvement activities, macra, MIPS, QPP, quality category, quality payment program