The term “neither fish nor fowl” is an old English term to describe something or someone which is not easily categorized; something or someone that does not rightly belong or fit well in a given group or situation.
Track 1 Accountable Care Organizations (ACOs) find themselves in a neither fish nor fowl position with MIPS. Yes, they are Alternative Payment Programs (APMs), but they are not Advanced Alternative Payment Programs (AAPMs). This makes them “MIPS eligible APMs,” but they also share many of the same attributes as their fellow Medicare Shared Savings Program (MSSP) participants. So if you are a Track 1 ACO, and over 90 percent of all MSSPs are, what do you do to report for 2017?
Composite score will add up.
As you know by now – if you do not know this by now, go here – MIPS reporting is a composite score of four categories totaling 100 percent: Quality, Advancing Care Information (ACI), Clinical Practice Improvement Activities (CPIA) and Cost. Most of us also are aware that the cost category will be calculated completely by CMS and will not be in use in 2017, so it will be worth 0 percent or points.
For non-ACO MIPS participants, Quality is worth 60 percent of the score, Advancing Care Information is worth 25 percent and Improvement Activities are worth 15 percent.
For MIPS-eligible APMs, Quality is worth 50 points, Advancing Care Information is worth 30 points and Improvement Activities are worth 20 points.
All MIPS-eligible APMs must report as a group. No individuals. No surprise.
Quality reporting is the same group quality reporting procedure performed under PQRS (with 15 measures this year) and if you reported in 2016 under the old GPRO option, you are automatically signed up again for group reporting under the CMS Web Interface option. For those groups, there was no need to register again by last week’s June 30 deadline.
For CPIA, all MIPS-eligible APMs get full credit for CPIA, or 20 percent. No need to do anything.
What about all these TINs?
Beginning to see the light at the end of the tunnel?
Not so fast. You still need to comply with ACI measures. For ACI, each eligible provider, by NPI needs to report on 11 to 15 measures, depending on the “certification edition” of your EMR (most of these will be the 2014 edition) and consists of 11 measures. These measures are then rolled up to the Tax Identification Number (TIN) to create a score.
If your ACO consists of more than one TIN, then an APM score is calculated using each practice’s score and weighted by number of physicians.
The measures themselves consist of a combination of attestation and performance measures. The cornerstone item is the Security Risk Analysis. If you do not complete this analysis for each TIN, you get a zero for base measures and if you get a zero for base measures, you get a zero for the entire category – no exceptions.
A new species.
For more detailed information, check out MIPS APMs in the Quality Payment Program and Medicare Shared Savings Program in the Quality Payment Program.
MIPS-eligible APMs are neither fish nor fowl, but a new species created by MIPS with their own rules and challenges.
Getting through the maze to a MIPS composite score of 100 percent is no simple feat. If you are a Track 1 ACO, what’s your plan? Let’s compare notes.