How to simply avoid the 2018 MIPS penalty
Eligible Clinicians may have difficulty finding the time and resources to fully participate in the 2018 MIPS reporting year – especially if you are part of a small practice. CMS has made 2018 another “Transition Year” for the new Quality Payment Program, meaning, they are still allowing different participation options to satisfy reporting requirements to avoid the 5% penalty.
Avoiding the penalty is different if you are a small practice
For 2018, practices and eligible clinicians need to earn a Final Score of 15 points out of 100 to avoid a penalty – up from just 3 points in 2017. Practices with 15 or fewer providers, called “small practices,” are scored differently than groups with more than 15 providers so there are different options for earning the 15 points.
Here are some scoring differences that makes it easier to avoid the penalty as a small practice:
| Advantage | 15 or fewer providers | Over 15 providers |
| Small Practice Bonus | 5 points added to Final Score | |
| Improvement Activities | Points doubled for each improvement activity | |
| Quality Measures: when not meeting case minimum or data completeness | Minimum of 3 points per measure | Minimum of 1 point per measure |
There are different ways a small practice can earn the 15 points
Small practices can earn the required 15 points to avoid a penalty in a few different ways, depending on which performance category and measures they report on. Here are some reporting examples that will provide the minimum of 15 points:
| MIPS Performance Category | Minimum Reporting Requirement | Category Points Earned | Small Practice Bonus Points | Final Score |
| Quality | 4 measures X 3 =12 points | =12/60*50= 10 |
5 | 15 |
| Promoting Interoperability | Base score measures to earn 50 points | =50/100*25=12.5 | 5 | 17.5 |
| Improvement Activities | One high-weighted activity=20 X 2 OR Two Medium Activities 10 X 2 X 2=40 |
15 | 5 | 20 |
What if you’re not a small practice but want to report the minimum?
Many practices with 15 or more eligible clinicians also struggle with successful quality reporting. Even these practices and clinicians can meet reporting requirements by reaching a Final Score of 15 points. Here’s how:
| Category | Minimum Reporting Requirement | Final Score |
| Improvement Activities | 2 High-weighted activities OR 4 Medium-weighted OR1 High-weighted activity 2 Medium-weighted activities |
15 |
Mingle Health can help!
Even after reading countless articles about MIPS and quality reporting, we understand it can still be overwhelming and confusing. We are here to help.
MIPS Solutions by Mingle Health® provides several editions for you to choose from, depending on at what level you want to participate in MIPS. If reporting the bare minimum, simply to avoid the 5% penalty for 2018, our Essentials Edition is the choice for you.
The goal of the Essentials Edition is to avoid the penalty by earning 15 points with the least amount of effort and resources. You’ll also have reassurance from a Mingle Consultant to help guide you every step of the way.
Don’t make a hasty decision.
If you’re feeling overwhelmed by all the requirements of MIPS and the Quality Payment Program, you’re not alone. But that doesn’t mean you should take the easy way out of Medicare quality reporting by doing just the bare minimum.
Keep in mind that requirements and penalties will continue to increase. The minimum score needed to avoid a penalty in 2017 was 3 points and it has increased to 15 points for 2018. It’s scheduled to increase to 30 for 2019. This is one example of CMS’ push towards value-based payments and requirements getting more stringent with each reporting year. There’s still time to fully participate in MIPS. Full participation allows you to avoid a 5% penalty, increase your chances for an incentive, and improve your preparedness as there’s more money on the line.
Read our blog post, Don’t Take the Easy Way Out with MIPS Until You’ve Reviewed Your Options, for a closer look at why the long view matters in Medicare quality reporting and performance management.
Dr. Dan Mingle and members of the team share their insights on how to maximize your success and payments for MIPS and APMs.