Medicare’s Merit-based Incentive Payment System (MIPS) program recently passed an important milestone: October 2 was the date by which providers must have begun collecting – but not reporting – quality measures to be eligible for a MIPS bonus in 2019.
While the calendar has already moved past that date, it is likely that many providers still have not taken the steps necessary to succeed under these new regulations imposed by the federal government. A number of surveys earlier this year illustrated that, while the deadline was fast-approaching, many medical practices still were not prepared.
For example, a 1,000-physician survey in June by KPMG and the American Medical Association found that fewer than one in four physicians felt well-prepared to meet quality reporting requirements in 2017. Further, among respondents participating in MIPS in 2017, 90 percent felt MIPS requirements were slightly burdensome or very burdensome. Respondents indicated that the time required to report is the greatest challenge. Other major challenges include understanding reporting requirements, understanding the overall MIPS scoring process and the cost required to accurately capture and report data.
Other recent surveys have revealed similar levels of provider frustration and apprehension with the new regulations. Clearly, a number of providers need assistance with MIPS readiness and participation. The good news is that there are technology vendors and practice management consultants that can help provider groups do just that.
For practices in more advanced stages of MIPS readiness, the prognosis is even better. For those organizations that have already begun collecting data, the last couple months of 2017 are a great time to begin preparing for next year to ensure that they do not leave any MIPS funding on the table next year.
How we got here
It would be easy to write thousands of pages of background on MIPS and quality reporting – and the federal government already has – but here is an abridged version: The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 created the Quality Payment Program (QPP), which began measuring performance on January 1, 2017. In 2019, payment rates will be adjusted under the QPP for physicians choosing one of two tracks: MIPS or Alternative Payment Models (APMs).
Under MIPS, providers can earn a bonus or penalty of up to 4 percent of their Medicare reimbursement in 2019. Providers have several options for reporting performance measures to the Centers for Medicare and Medicaid Services (CMS), including the claims-based method that was required for the government’s previous major quality-reporting program, via an electronic medical records (EMR) system or through a CMS-approved data registry. Performance data must be submitted by March 31, 2018. To be eligible to receive the full bonus, providers must report at least 90 days of data, but providers that report a full year of data have an even better chance.
The four states of MIPS preparedness
Under MIPS’ “pick your pace” arrangement, provider groups have several options for the amount of data they would like to submit. In our experience, most provider groups fall into one of the following four stages of preparedness:
- Non-participants: Some of the providers in this category simply do not want to deal with the hassle of reporting or oppose QPP for other philosophical reasons. They have no plans to submit data and thus will incur 4 percent penalties. However, not all providers are required to enroll in QPP, such as those who bill Medicare Part B for less than $30,000 annually or those who see fewer than 100 Medicare patients per year.
- Breaking even: CMS set the bar pretty low to enable providers to avoid penalties. To do so, providers simply must submit one quality measure or one improvement activity for one patient from any point in 2017. While we certainly do not recommend this option, breaking even is vastly preferable to not participating at all.
- Participants that are actively reviewing and analyzing performance data: This category of provider groups is in the best shape to get the most out of MIPS. They know which quality measures they are planning to submit to CMS and are actively monitoring individual providers’ performance against the necessary benchmarks. For these fortunate organizations, the rest of 2017 is about guiding providers’ performance towards maximizing MIPS incentive payments.
- Participants that are not reviewing performance data: These are the groups that have the greatest opportunity to improve and avoid leaving MIPS money on the able. Generally, they have identified which quality measures they are planning to submit and have communicated that information to relevant providers. However, where these groups are falling short is in monitoring provider performance and analyzing data to identify lower-performing providers. Essentially, these groups have an excellent opportunity to close the gaps at an individual provider level that could prevent their organizations from meeting their goals at an aggregate level. As we close in on year-end, now is the time for these groups to focus on providers who are not performing well, coach them on ways to improve and communicate what the effect will be if they do not meet the organization’s chosen quality measures.
Partners are here to help, regardless of your readiness stage. They can assess where you currently stand, advise you on the best course of action, and provide technology to advance your position. Dashboards and analytics make it clear how each provider is performing across each quality metric so you can close any gaps and correct your path, if necessary.
If there is one key message to communicate to provider groups about MIPS, it is this: Know what your options are, and whatever you do, don’t leave money on the table. Trusted partners are willing and able to guide provider groups through the MIPS process to help providers receive full incentive payments. There is still time in 2017 to begin on the path toward achieving organizational performance goals. Do not let the opportunity slip away, because 2018 MIPS reporting requirements become even more stringent.