How to Avoid th MIPS Penalty in 2018 #PACPearls

Similar to last year, I have come up with a way to avoid the MIPS penalty in 2018 without having to use a registry OR even have an EHR.

It’s not as easy as last year, but still reasonable (if you can call anything having to do with a government program reasonable)…

So here it goes:

Here is what I have come up with for avoiding the MIPS penalty in 2020- with assumption being that you are on paper, DON’T have DataDerm (or another registry), and are in a group of fewer than 15 clinicians.
You need to get 15 MIPS points to avoid the penalty. 

(Last year it was 3 points.)

Any practice with fewer than 15 practitioners- automatically gets a Small Practice Bonus= 5 points
So, you really only need to get 10 more points to avoid the penalty.
Only way to get points- given above assumptions- is to submit quality measures via claims.
So, you will need 4 quality measures (one time, on one patient) to get 12 more points and avoid the penalty.
So, submit measure 130 (documentation of meds in chart with G code G8427)- as you did last year.
That leaves 3 more measures to submit on your claim- asterisks refer to appropriate G codes to submit on your claim (below).
Submit measures:

110 (influenza)* 

111 (pneumovax)**

and 226 (tobacco use)***

That’s it.

As I did last year, I will be submitting these on more than one patient.

My intent is to submit all 4 measures, on all new medicare patients, in one day of seeing patients.

That way, I spend no more than 1 day working to avoid the 5% penalty in 2020.

****CMS has recently stated that they will have a web interface to submit data this year, and so you might be able to do one high weighted improvement activity - and potentially submit it through the CMS web portal- and be exempt from the penalty without submitting any quality measures…but it is still unclear who and what will be accepted through this interface at this time.

Mark Kaufmann, MD

* * * *

*For measure 110 (influenza):

G codes are as follows:

NUMERATOR NOTE: Denominator Exception(s) are determined at the time of the denominator eligible encounter during the current flu season. 

Definition: 

Previous Receipt – Receipt of the current season’s influenza immunization from another provider OR from same provider prior to the visit to which the measure is applied (typically, prior vaccination would include influenza vaccine given since August 1st). 

Numerator Quality-Data Coding Options: Influenza Immunization Administered Performance Met: G8482: Influenza immunization administered or previously received

OR
Influenza Immunization not Administered for Documented Reasons
Denominator Exception: G8483: Influenza immunization was not administered for reasons documented by clinician (e.g., patient allergy or other medical reasons, patient declined or other patient reasons, vaccine not available or other system reasons)

OR
Influenza Immunization not Administered, Reason not Given
Performance Not Met: G8484: Influenza immunization was not administered, reason not given 

**For measure 111 (pneumovax):

G codes are as follows:

Numerator Quality-Data Coding Options:

Pneumococcal Vaccination Administered or Previously Received

Performance Met: CPT II 4040F: Pneumococcal vaccine administered or previously received

OR 

Pneumococcal Vaccination not Administered or Previously Received, Reason not Otherwise Specified 

Append a submission modifier (8P) to CPT Category II code 4040F to submit circumstances when the action described in the numerator is not performed and the reason is not otherwise specified.

Performance Not Met: 4040F with 8P: Pneumococcal vaccine was not administered or previously received, reason not otherwise specified 

***For Measure 226 (tobacco use and cessation)

G codes are as follows:

Numerator Quality-Data Coding Options:
Patient Screened for Tobacco Use, Identified as a Tobacco User or Tobacco Non-User

Performance Met: G9902: Patient screened for tobacco use AND identified as a tobacco user

OR

Performance Met: G9903: Patient screened for tobacco use AND identified as a tobacco non-user