As we near the end of 2017, you may think you’ve missed the chance to participate in the Merit-Based Incentive Payment System (MIPS), and thus resigned yourself to a 4% cut in your Medicare Physician Fee Schedule payments in 2019. That translates to thousands of dollars in lost revenue for most physicians.
What if we told you just 15 minutes could save you from that 4% penalty?
Spend that 15 minutes completing individual claims-based reporting on a single quality measure using the test path.
A detailed, thorough explanation of MIPS can wait for another day. Here are our seven-step instructions to successfully participate in MIPS for 2017.
Step 1: There are 74 quality measures that may be reported by including additional information on your claims for payment submitted to Medicare. Review the list available at https://qpp.cms.gov/mips/quality-measures (use the filter for “Data Submission Method,” and check the box for “Claims”), and select one measure relevant to the physician’s practice. For example, let’s use “Documentation of Medications in the Medical Record.” 
Step 2: In the drop-down box for your selected measure, make note of the measure’s Quality ID listed under the heading “Measure Number.” For our example, the Quality ID is 130.
Step 3: Navigate to the https://qpp.cms.gov/resources/education page. Scroll down to the “Documents and Downloads” section, and click on “Quality Measures Specifications.” It’s a large zip file, and may take several minutes to load.
Step 4: Open the file folder labeled “QPP_quality_measure_specifications,” and then click on “Claims-Registry-Measures.” Scroll down to find the .pdf for your measure’s Quality ID. For most measures, there will be two .pdfs, one labeled “Claims,” and one labeled “Registry.” Be sure to use the .pdf labeled “Claims.”
Step 5: Review the document’s description of the measure’s denominator (the specific patient population to which the measure is relevant) and its numerator (the specific action the physician must take with regard to a patient included in the denominator to meet the measure’s requirements).
In our example, the denominator is each patient age 18 and older for whom the provider furnishes specified services during the measurement period (listed by CPT® and HCPCS codes). The numerator is attesting to documenting, updating, or reviewing the patient’s current medications using all immediate resources available on the date of the encounter.
Step 6: In the same PDF document, locate the section entitled “Numerator Quality-Data Coding Options.” Here, you will find the QDC code, which is a tracking code that is paired with a “cost” of $0.00 or $0.01 on the claim. You may include this code on the claim for a specific service if (a) the patient is part of the denominator, and (b) the billing practitioner has performed the work specified in the numerator. In our example, the QDC code is G8427.
Step 7: To meet the requirements for test path reporting (and thus avoid the MIPS penalty), you must include the appropriate QDC code for one of the 74 MIPS quality measures eligible for claims-based reporting on one Part B claim filed for a service performed before December 31, 2017, for each physician and non-physician practitioner in your group practice. Claims processed by your Medicare Administrative Contractor (MAC) (including claims adjustments, re-openings, or appeals) must get to the national Medicare claims system data warehouse by March 31, 2018.
We strongly recommend submitting more than one claim with the correct code to ensure success and doing so well before March 31, 2018, to ensure the claims are received on time.
In future years, this simple test path reporting will not be an option for avoiding MIPS penalties. As you will see from the measure specifications sheet, significantly more work is involved if one is tracking performance on a specific measure over a period of time. For 2017, however, following the seven steps for each physician or non-physician practitioner in your practice is sufficient.
