What is MIPS?

At Comiere we have gathered all the information you need to take full advantage of MIPS, the Merit-based Incentive Payment System.

This bonus/penalty scheme is determined by a physician’s performance in four different categories:

  • Quality
  • Advancing Care Information
  • Clinical Practice Improvement Activities
  • Resource Use/Cost

The resulting bonuses or penalties could represent as much as 9% of your eventual Medicare reimbursements, so it pays to be informed.


Quality is the most important MIPS measure, representing 60% of the overall weighting when MIPS comes into effect. Physicians choose six options that best represent their specialty or practice from a menu of 200 sub-measures. One must be an outcome measure, and one must be “cross-cutting” (relevant to all specialties).

Advancing Care Information (ACI)

The Advancing Care Information (ACI) measure replaces Meaningful Use for Medicare. Physicians must adopt measures that focus on information exchange, in addition to security and interoperability. This includes Comiere-enabled functions such as the ability to prescribe electronically. To score well, ensure your Electronic Health Record (EHR system) is secure and communicates effectively with others.

Clinical Improvement Activities

You have a choice of 90 activities targeted at assessing your capabilities in patient safety, beneficiary engagement, and care coordination. They range from the percentage of women aged between 40 and 69 who have had mammograms to the extensiveness of strep testing for children with pharyngitis.

Resource Use & Cost

Data on resource use and cost are not reported by physicians but are gathered from claims sent to Medicare throughout the year. This measure is not included for 2017.

Practices should ensure that they are using their resources efficiently, examining their latest-used codes, and requesting that patients submit their explanations of benefits. This would help them to decide which hospital provides the best value for specific patient procedures.

MIPS Checklist


Find Out If You Are Eligible

Not all physicians and roles are eligible for MIPS yet. Enter your ten-digit National Provider Identifier Number on the Quality Care Program website.


Choose Either Individual or Group Reporting

CMS automatically registered your group for MIPS 2017 if you registered as a group for PQRS in 2016. The group’s performance will determine your payment adjustment.


Pick Your Pace

You have a choice of submitting a partial year to receive a small incentive and avoid the penalty, or you may avoid the penalty by submitting a minimum amount of data.


Select Your Reporting Period

For partial year, submit any consecutive 90 days. (The last day to start is October 2, 2017). For a minimum submission, report any data from 2017.


Select Your Reporting Measures from Your Certified EHR

The reporting categories as outlined above are weighted as follows:

  • Quality Measures (60%)
  • Advancing Care Information Measures (25%)
  • Improvement Activities Measures (15%)
  • Resource Use & Cost is not included in 2017.


Carry out a Security Risk Analysis

To ensure your patients’ data is secure, be eligible for MIPS, and comply with HIPAA requirements, you must conduct a risk analysis.


Enhance Your Workflow

Ensure your certified EHR facilitates seamless incorporation of data collection into your workflow, without the need to use a second application.


Watch Your Progress

Keep monitoring the dashboards in your certified EHR to ensure satisfactory levels of completion. Watch overall performance rates and the extent to which patients meet selected measures. It should be easy to determine why certain patients are not meeting a measure, so that you can reassess a patient encounter.


Build an Audit Folder

Collect supporting information for your 2017 MIPS attestation, including reports, policies, enrolment forms, and your security risk analysis.


Save the Date

Submit your performance data by March 31, 2018. Access the Quality Payment Program website (qpp.cms.gov) and subscribe for the latest CMS updates.

Frequently Asked Questions

+What is the Quality Payment Program?

The QPP replaces the current Medicare Meaningful Use, PQRS, and value-based modifier schemes and is divided into the Merit-Based Incentive Program (MIPS) and Advanced Alternative Payment Models (APMs).

+Who Is Governed by the QPP?

The following must subscribe to the QPP in either MIPS or Advanced APMs:

  • Physicians
  • Physician Assistants
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists

+Who Is Excluded from the QPP in 2017?

  • Providers in their first year of Medicare
  • Providers with fewer than 100 Medicare patients annually
  • Providers who bill no more than $30,000 in annual Medicare claims
  • Providers availing of an Advanced APM

+What Are the Approved Advanced APMs for 2017?

  • Comprehensive ESRD Care (CEC) – Large Dialysis Organization (LDO)
  • Comprehensive ESRD Card – Non-LDO
  • Comprehensive Primary Care Plus (CPC+)
  • Next Generation ACO Model
  • Shared Savings Program – Track 2
  • Shared Savings Program – Track 3
  • Oncology Care Model (two-sided risk arrangement)

+What Are the Criteria for MIPS?

Under MIPS, providers’ Medicare reimbursements will be determined on their performance across 3 categories:

  • Quality (60%)
  • Advancing Care Information (25%)
  • Improvement Activities (15%)

+Do you need a certified EHR to participate in the QPP?

Yes. From 2018, the EHR must be 2015 Edition certified.

+How do I know if my EHR is certified?

Search the list at www.healthit.gov.

+What is the MIPS Quality requirement?

You must report as many as six quality measures, including an outcome measure, for at least 90 days. Web interface users must report 15 quality measures for 12 months.

+How many Quality measures may I choose from?


+What are the Improvement Activity requirements for MIPS?

For most participants, the requirement for Improvement Activities for MIPS is to attest that you completed up to four improvement activities. For groups with fewer than 15 participants or if you are in a rural or health professional shortage area, you must complete up to two activities for a minimum of 90 days. If you are in a certified patient-centered medical home, you automatically get full credit.

+How many improvement activities are there to choose from?

There are 93 improvement activities to choose from.

+What is the Advancing Care Information requirement for MIPS?

Complete the following measures for at least 90 days:

  • Security Risk Analysis
  • e-Prescribing
  • Offer Patient Access
  • Issue Summary of Care
  • Request/Accept Summary of Care

For extra credit, submit up to nine measures for at least 90 days. Bonus credit is available if you:

  • Report Public Health and Clinical Data Registry Reporting measures
  • Submit certain improvement activities using certified EHR technology

Note: Only applicable Advancing Care Information will be required.

+What is the choice of measures for Advancing Care Information?

There are 15 measures in the 2015 edition certified EHR and 11 in the 2014 edition.

+How can I apply for MACRA?

The MACRA Quality Payment Program is divided into MIPS and Advanced APMs. For MIPS, you just report your data during the relevant period. Members of Advanced APMs report through that group. A penalty of 4% in 2019 applies to those who do not report at all.

+How do I report MIPS data?

For the 2017 year, report MIPS data using the same methods as for the Meaningful Use and PQRS programs.

+Is Medicare Advantage included?

Only Medicare Part B is included

+Will I continue participating in Medicare Meaningful Use through 2017, as well as MACRA?

No, Medicare Meaningful Use ended at the start of 2017.

+Will I participate in MACRA as well as Medicaid Meaningful Use?

If you also accept Medicare Part B and have more than 100 Medicare patients or bill more than $30,000 in Medicare Part B claims, you are eligible.

+Who are ineligible clinicians?

  • Non-physician mental health providers are not eligible yet
  • PT/OT/SLP providers are not eligible yet

+Are similar incentives and penalties on offer from commercial payers?

Many commercial payers are turning to value-based care programs.