MIPS: Proposed changes may have a big impact on Pain Medicine practices
UPDATED
This post was written based on information in the 2017 Proposed Rule. Here are some highlights of what is different now that the Final Rule is published:
Cross-cutting measures, and the inclusion of them in your quality reporting submission, will not be carried forward from the prior PQRS program into the Merit-Based Incentive Payment System (MIPS). Even though you will report on all payers, you can earn incentive by reporting for just 90-days making reporting less burdensome. The opioid measures introduced in 2016 PQRS are still available for 2017 MIPS reporting, making it achievable for pain specialists to reach the six-measure reporting goal for full-participation.
For more information about the 2017 Final Rule, watch our on-demand webinar, The 2017 Final Rule: MIPS and the Quality Payment Program. If you have specific questions regarding pain specialists and how they can successfully report under MIPS and the new Quality Payment Program, contact one of our knowledgeable Consultants, we are ready to assist you with your quality reporting needs!
The 2017 Proposed Rule includes several changes that may have a big impact on pain practices in 2017. Under MIPS, the Quality Performance category will require every quality measure submission to include a cross-cutting measure. On the proposed measure list, Measure 131: Pain Assessment & Follow-up, along with several others, will no longer be a cross-cutting measure.
Our goal with Quality Reporting has been to help providers report on measures that are meaningful to them—Measure 131 certainly fits that bill for pain specialists.
Many pain practices use this measure to satisfy the requirement for a cross-cutting measure because there are few other cross-cutting measures that are specifically applicable to the specialty of pain medicine.
Under PQRS, pain specialists have also relied on the MAV (Measure Applicability Validation) process as it is hard for them to find nine measures pertaining to the care they give. While under MIPS, the measure requirement has decreased from nine to six, if a provider or group doesn’t have six measures that are applicable to their scope of practice, the proposed rule does not spell out the validation process they will use to determine how the missing measures will be scored.
Practices will receive quality points for the measures they are able to report, but it is unclear under the proposed rule if they will be able to achieve enough points in the Quality Performance category without reporting six measures. Further complicating the measure choice equation is that each measure will be scored based on a benchmark that compares the performance on that measure to others reporting the same measure. Providers will only want to report measures where they score favorably against the benchmark.
The proposed Specialty Measure Sets help identify meaningful measures for specialties. The Specialty Measure Set for Physical Medicine, appears to have solid measures that will apply to Pain Specialists, and it includes some new measures introduced in 2016.
Here are the proposed measures in the Specialty Measure Set #15 for Physical Medicine that might apply:
- 109 Osteoarthritis (OA): Function and Pain Assessment
- 131 Pain Assessment and Follow-Up
- 182 Functional Outcome Assessment
- 312 Use of Imaging Studies for Low Back Pain*
- 408 Opioid Therapy Follow-Up Evaluation
- 412 Documentation of Signed Opioid Treatment Agreement
- 414 Evaluation or Interview for Risk of Opioid Misuse
*Measure 312 can only be reported via EHR.
Another change that will impact providers is the proposed reporting requirements
- Qualified Registry, QCDR, EHR-90% of patients eligible for the measure for ALL payers. Under PQRS it was 50% of Medicare Part B, only.
- Claims-80% for Medicare Part B FFS (was 50% Medicare Part B)
This new reporting requirement will result in a significant increase in the number of patients that will need to be reported on. As it is now, there are many practices that may be on paper records or do not have good reporting from their EMR. This means that they must go into the chart for each patient to determine if the measure is “Met” or “Not met.” With cross-cutting measures, this can mean abstracting data from thousands of charts, a laborious process that takes significant staff and physician time that could be better spent with patients.
If you feel any of the new requirements will affect you adversely, we encourage you to comment on the Proposed Rule.
In the spirit of Measure 131, “Pain Assessment and Follow-Up,” let’s address the issue…your pain assessment is positive, and a follow-up plan is to tell CMS about how the proposed rule will affect you. CMS is encouraging you to comment. They want to hear from the clinicians who are directly impacted by these proposed changes. They are listening…let your voice be heard!
For more details on the proposed rule and how to comment, please see Dr. Mingle’s recent blog post, “Why you should comment on the 2017 Proposed Rule for the Quality Payment Program.”
The 2017 Final Rule is expected in November of 2016. Rest assured Mingle Health is preparing now to guide you through this process. We look forward to serving you.
For more information about the 2017 Final Rule, watch our on-demand webinar, The 2017 Final Rule: MIPS and the Quality Payment Program. If you have specific questions regarding pain specialists and how they can successfully report under MIPS and the new Quality Payment Program, contact one of our knowledgeable Consultants, we are ready to assist you with your quality reporting needs!
This eBook will help you prepare for the transition to MIPS and APMs.