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Don’t Take the Easy Way Out with MIPS Until You’ve Reviewed Your Options

By now you’ve probably read several articles about MACRA legislation and the Quality Payment Program (QPP). Most likely you’ve been hearing or reading about MIPS, the Merit-based Incentive Payment System that affects most physicians, PA’s, NP’s, CNS’s, and CRNA’s. If you’re feeling overwhelmed by all the program details or confused about the requirements, you’re not alone.

Several recent surveys show that most providers are unprepared for MIPS and many are confused by the program. Those feelings are understandable; MIPS is a complicated program. The program is complicated enough that CMS is pouring over $100 million into provider education. Additionally, professional societies and organizations across the country are regularly holding MIPS education sessions. Given the complexity of this program, it may be tempting to take the easiest path to meet the minimum requirements and be done with it (at least for this year). Here’s why that decision may not be to your benefit.

Take the Long View

In 2017, the MIPS requirements have been dramatically lowered to make it easier for eligible providers to participate and prepare for the full program. CMS has identified 2017 MIPS as a transition year and introduced a set of reporting options they call “Pick Your Pace.” Even with this starter version of the program, there are significant questions that should be considered before deciding on a MIPS reporting option. One consideration is the likelihood of the program being around for several years and the fundamental changes that a practice needs to make to be successful in the program. It is easier to develop strategies for data collection, feedback, correction, and submittal during the transition year than it will be when the program takes full effect.

CMS has committed to paying for value and is shifting away from payment on volume alone. There are similar trends in commercial and Medicaid payment models as well. A 2016 survey by the Healthcare Transformation Taskforce showed that 41 percent of provider and payer business was in the form of value-based care reimbursement contracts (read the Healthcare Transformation Taskforce article). Given these trends across all payer markets, gearing-up for value-based reporting makes sense.

Choose Your Options Wisely

Pick Your Pace has three reporting options for participating in MIPS. There is also the choice not to participate and take a 4% penalty on 2019 Medicare Part B payments. The first option is to “test” submit data. Test submissions are the absolute minimum level of data needed to avoid a negative payment adjustment in 2019. A second option is to submit 90 days of data, which for some providers will be enough to score well in MIPS. The final option is to submit up to a full year of data which should provide the greatest opportunity for providers that are seeking incentives and bonus payments through the program. Each of these options involve costs and benefits.

Estimating the Costs and Benefits of Each of the Participation Options

Foregoing 4% of Medicare Allowable Charges in 2019 could be costly, especially to practices that have a large portion of Medicare patients and/or multiple providers. The impact would be $1,000 for every $25,000 in Medicare allowable charges. For some specialties and providers, this might not be a big impact, for others, it would be. There are also indirect negative impacts to this decision that should be considered, I’ll discuss these later.

The minimalist or test option to avoid a penalty looks attractive but should be weighed against its costs and benefits. The cost to this decision is the potential incentive and bonus dollars left unclaimed.

The 90-day data submission, also known as partial participation, could be the best choice for many providers. With a solid 90-day submission, high performing providers and practices could be in the incentive and bonus payment range in MIPS scoring.

The last option is submitting up to a full year of data to identify those periods where performance was highest and having the greatest opportunity for qualifying for an incentive, bonus.

Indirect Costs of Low MIPS Scores-it’s not only about the penalty or incentive

One area that hasn’t been discussed, but should be considered, is the impact of public reporting of MIPS scores on a provider’s public profile.

Beginning in 2019, CMS will use its Physician Compare website to publish MIPS performance scores. Physician Compare has been used for publishing performance data for years now but it has largely gone unnoticed. MACRA is likely to change that. Recent articles in several publications like Health Affairs (read the Health Affairs article) and the Huffington Post (read the Huffington Post article) have pointed out that comparative performance ratings in healthcare services are being used more frequently by consumers. This trend is likely to increase as more consumers with high- deductible health plans shop for quality providers and use rating sites in those decisions. Through lower co-pays, payers are incenting their plan members to choose high-quality providers. Payers are also interested in attracting quality providers into their networks. Public reporting of healthcare quality and efficiency is growing in importance and use by consumers and payers. Consider the potential impact of how your public professional profile would be impacted by minimal reporting of quality.

Don’t Get Fooled by The Partial Participation Option, It’s What’s in the Data That Matters

Providers and practices that participate in pay-for-performance programs want their best performance represented. The 90-day submission or “partial participation” works for most providers but the reality is, what 90-days are best? You won’t know the answer until all your quality data is fully analyzed. In other words, you may only be submitting the best 90 days of data, but you’ll want a full year’s worth to get it. Reporting for a full year could give you the widest choice of measures as you may not have enough eligible instances within a 90-day period to meet the 20-case minimum needed to earn more than three points per measure.

Succeeding in MIPS is a Strategic Decision

MIPS is a pay-for-performance model. To succeed you’ll need to know your performance and adjust if needed. Providers and practices will come out ahead using a system for monitoring quality performance and improving in areas that are lagging. If you are among the high-performing providers or practices, MIPS reporting costs will be mitigated by qualifying for an incentive.

Is the Effort Worth the Investment?

For most eligible providers, the answer is “Yes.” The Quality Payment Program, which includes MIPS, is a foundation for payment reform. In addition to Medicare, the program was designed to accommodate commercial and Medicaid payers that are aligned on quality and meet the alternative payment model criteria. By taking the long view and recognizing that value-based purchasing is the new payment model, providers will be better positioned to succeed by implementing a system of quality monitoring and performance improvement. Investing in solutions for MIPS will likely pay off in other pay-for-performance contracts as well.

Choose an Experienced Vendor That Understands Healthcare Quality and Performance Improvement

If your practice or organization is considering using the services of a professional quality reporting vendor for MIPS, consider the following in making your choice:

  1. Healthcare quality reporting experience – Look carefully at the vendor’s actual experience and whether the vendor has participated in quality reporting of performance to CMS before.
  2. Healthcare experience – Some vendors are little more than IT solutions. Look for a vendor that understands and is experienced in healthcare.
  3. Quality reporting performance – Experienced vendors should be able to give you an indication of their error rate in reporting.
  4. A solution that meets your needs – Quality reporting comes in all sizes. You should choose a product that meets your practice or organizational needs and understand why.
  5. Confidence and comfort – Hiring a quality reporting vendor begins a relationship between a client and a vendor. The client should feel confident that the vendor is working in their best interests and be comfortable communicating any questions or concerns.

Jim Leonard is Manager of Strategic Initiatives at Mingle Health. Jim has more than 30 years of experience in healthcare and government administration.

Mingle Health provides comprehensive quality reporting and consultation services. The organization serves clients of all sizes in every state. We specialize in CMS quality reporting and have been doing so since 2012. Our professional consultation team consists of physicians, clinical informaticians, healthcare administrators, IT professionals, and business consultants.

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