Medicare’s new pay system launched in January. However, participation is not mandated until later in the year. The new system, called QPP or Quality Payment Program, offers two engagement tracks or pathways: MIPS and APM. There is also a hybrid option called MIPS/APM for practitioners who belong to particular ACOs. Since many of the APM options are only available to only a small number of Ophthalmology practices, at first most practices will be participating in the MIPS pathway.
Overview of MIPS
With the increased governmental involvement in healthcare, watchdog groups and so-forth it was just a matter of time before fee-based payment models became more scrutinized and finally replaced. MIPS, which stands for Merit-based Incentive Payment System is just the newest iteration of value-based or quality-based payment in healthcare.
The overall goal of this new payment system is to reign in the cost of healthcare, improve the patient outcome, and reward physicians for providing consistently contentious care. Of course, you’re still going to get paid for what you do, but the fee can go up or down according to your scores. Moreover, physician’s scoring in the 75th percentile of the performance threshold will split another $500 million per year.
During this first year, Centers for Medicare & Medicaid Services (CMS) is attempting to ease the transition, increasing flexibility and reducing some of the reporting requirements, as well. Also, there are resources available to help you break the learning curve more quickly. For those who were involved in CMS previous quality reporting programs like PQRS, you will find many similarities, especially in the reporting requirements and procedures.
The 4 Components of Your MIPS Score
These are quality, resource utilization, clinical practice improvement activities, and meaningful use of certified EHR tech.
Of the four components, quality makes up 50 percent of the total MIPS score. For each patient, you see there is a required number of quality measures you need to implement to receive your total points in this category. These can include things like:
- Cross-cutting – Smoking cessation or alcohol counseling
- Process measures – Diabetes dilated eye exam, Antioxidant counseling
- Outcomes measures – Successful procedures
There are bonus points awarded for picking actions that are outcome related and high priority. An example of this would be Cataract Surgery with improvement in vision within 90 days of the procedure.
- Advancing Care Information
ACI counts for 25 percent of the MIPS score. The scope has been reduced from the meaningful use requirements. However, the condition did not go away completely. This takes the place of the EHR. It requires that participants have an obligation to use updated EHR technology in a way that protects patient data while allowing for information exchange and related data collection, storage, and delivery.
- Improvement Activities
This is an entirely new requirement. Currently, it counts for 15 percent of the final MIPS score. This category is sometimes called “clinical practice improvement activities.” These are things like expanding access to your practice. Think along the lines of adding evening or weekend hours. Offering telemedicine is an area for consideration, as well. Participation in a qualified registry also counts toward this requirement.
This is based on the individual practice as well as to others in your field. Unfortunately, benchmarking data that is used to compare costs, is not available promptly, from the government. If you have access to data analytic tools or dashboard technology, you could more reliably keep up with your real and comparative costs. Costs do factor heavily into the scoring model at 30 percent for 2018.
Scoring will be used on the four components to determine whether a practitioner receives a 4 percent bonus or a 4 percent penalty the following year. These upward or downward adjustments will increase each year through 2022 when the total amount that can be earned or lost is equal to 9 percent. This is designed to allow each practice the time it needs to come up to speed and into compliance while rewarding those who are able to do so faster.
Who is Exempt From Taking Part in MIPS
This year, CMS introduced a new term—“the MIPS eligible clinician.” These are clinicians defined as physicians, optometrists, PAs, NPs, clinical nurse specialists, and CRNAs, as well as practices that include these clinicians. However, not all MIPS eligible clinicians have to participate in MIPS. If you meet one of the following exclusions you may not have to participate.
Exclusion #1—Clinicians who are new to Medicare. If you are practicing through Medicare for the first time in 2017, and have never submitted claims to Medicare, you are exempt from the MIPS regulations for the first year.
Exclusion #2—Clinicians who do not meet the volume threshold. If, over the last 12-month period:
Bill Medicare Part B for $30k or less.
You have no more than 100 Medicare Part B recipients.
Exclusion #3—If you are already participating in an advanced APM, you might be exempt from the MIPS regulations.
The Physician Compare Website
It is important to remember that in 2019, your MIPS score will be made public on the government’s website.
MIPS was created with the ambition of achieving the best patient-centered outcomes while collecting and sharing data, utilizing the most advanced technology, in the most cost-efficient way possible. The focus on quality is an important step to ensure your practice is MIPS compliant and that your score doesn’t suffer.
Tip#1 Consider creating a team to help with the transition.
Tip#2 Consider automating business processes, to reduce some of the everyday hassles of the new reporting requirements.
Tip #3 Instead of the bare minimum to avoid penalties work with us to get your practice up to speed right now.
Connect with us today to learn how we can help your practice score.