MIPS Mastery is a seven-part series on optimizing performance under the Merit-Based Incentive Payment System, originally produced by PYA.
How Will CPCs Be Calculated?
For the 2017 performance year, the four categories of the CPS will be weighted as follows:
- 50% quality
- 10% resource use
- 25% advancing care information
- 15% clinical practice improvement activities
For the 2018 performance year, the quality and resourceuse categories will be weighted at 45% and 15%, respectively. Thereafter, these categories will be weighted equally at 30%; advancing care information and clinical practice improvement activities will remain at 25% and 15%, respectively, as required by statute. CMS is ramping up the resource use category from 10% to 30% over three years as it defines specific clinical episodes of care to be used in evaluating provider efficiency.
Will CPCs Be Assigned at the Individual Clinician or Group Level?
CMS will assign CPSs at the individual Clinician level (identified by NPI). If a Clinician bills for services under more than one group (identified by Taxpayer Identification Number, or TIN) during a performance year, CMS will assign a different CPS for each NPI/TIN combination. Then, during the adjustment year (the first such year being 2019), CMS will adjust the Clinician’s MPFS payments based on the TIN under which the service is billed.
If, during the adjustment year, the Clinician bills under a different TIN than he or she did during the performance year, the Clinician’s CPS from the performance year will follow the Clinician to the new TIN. If the Clinician has multiple CPSs from the performance year (i.e., the Clinician billed for services under more than one TIN during the performance year), CMS will calculate and apply a weighted average CPS based on the percentage of allowed charges between the TINs.
Although CPSs are assigned at the individual level, they can be calculated at both the group and individual levels. A group may report its overall scores on specified performance measures, and a Clinician (or the group on the Clinician’s behalf) may report on the Clinician’s individual scores (which may be based on different measures than the group’s scores). In this case, the Clinician’s individual performance on the performance measures reported by the group will be included for purposes of calculating the group-level CPS.
If a Clinician reports individually and his or her group also reports, CMS will calculate two CPSs for the Clinician, one based on the Clinician’s individual performance and one based on the group’s performance. CMS will then use the higher score to determine the Clinician’s payment adjustments for services billed under that TIN.