CMS Guidance on the MIPS 2019 Opt-In Process

The following update pertains to practices who submit MIPS data via a registry

The opt-in process for practices who submit MIPS data via a registry will take place on the side of the registry.   Said differently, our QCDR (Quality Clinical Data Registry) will communicate which TINs and NPIs are opting into MIPS for 2019.  The QCDR will communicate this information directly to the CMS.

Opt-in timing will be around the actual submission date, which means you can wait until after 12/31/19 to decide if you are opting into MIPS for 2019 or not.

“Technically,” if a therapist satisfies three MIPS’s eligibility criteria, they are automatically opted into MIPS.  We recommend opting in via your registry in January, just to be sure.

This is All Good News for Systems 4PT Practices

  • As was the case after Q1 and Q2, Systems 4PT practices will receive their Q3 trending MIPS score in the first half of October 2019
    • You should study this and make any necessary adjustments
  • You will receive your year-end Total 2019 MIPS Status and Score after January 1, 2020
    • You will receive this before you are required to commit to opting in
    • In other words, you can verify that “you’re in the money” (qualify for MIPS rewards and bonus dollars) before committing to opt into MIPS for 2019

The above is in stark contrast to the position that other practice owners are in.  No other EMR has communicated quarterly MIPS trending score status.

The devil is in the details. While other EMRs may communicate “MIPS submission status” or “% MIPS submitted,” THIS DATA IS DIFFERENT THAN THE TRENDING MIPS SCORE.  Trending scores result from  calculations that include applicable bonus points and reweight status for “promoting interoperability” and “cost.”

No doubt, there are thousands of therapists who think they’re complying with MIPS, but because they have received zero scoring feedback from their EMR, they’ll be paying takebacks that will fund your rewards!

For a year we’ve said:

“MIPS will segregate the market into those who are compliant and those who aren’t.”

As we observe how other EMRs are acting, we’d like to change the emphasis of this statement to:

“MIPS will segregate the market into those who use a compliant EMR and those who don’t.”

And practices that fail to comply will fund the practices that do comply.

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