We all know how quickly time passes. With a key milestone in the transition to the Merit-Based Incentive Payment System (MIPS) looming on the horizon, it’s time for your practice to evaluate where you stand.
In 2017, you can opt for partial participation in MIPS and earn a "neutral or small positive payment adjustment" for 90 days, the Centers for Medicare and Medicaid Services states. Practices can start anytime now through October 2 (with performance data due by March 31, 2018).
Set achievable goals for 2017
Deciding at what level your practice will participate in MIPS this year is important, especially if your practice has not participated in other quality reporting programs, such as the Physician Quality Reporting System (PQRS) or Meaningful Use (MU). As you evaluate your current practice readiness, put together a plan for learning about MIPS requirements.
A team approach is critical to MIPS success, which requires documenting and collecting all appropriate data and ensuring requirements are reported by CMS deadlines. If your practice has successfully participated in quality reporting, decide if you want to focus on achieving the maximum score to be eligible for the largest payment adjustment, or ease into the process in 2017 to potentially be eligible for a modest payment adjustment, concentrating on preparing for future years. One key factor when choosing your participation level is the readiness of your electronic health record (EHR) system to collect and report MIPS data. Engage with your EHR vendor early to understand your system’s MIPS capabilities and any functionality training they offer.
Quality — 60% of the MIPS composite score
Many of the measures included in the MIPS Quality category are the same or similar to PQRS reporting measures. Each clinician must report at least six measures, with at least one being on outcomes.
Improvement activities — 15% of the MIPS composite score
The improvement activities category requires practices with 15 or more physicians, to report on up to four improvement activities. Practices with fewer than 15 physicians must report on two activities. Improvement activity data must be collected for at least 90 days, and since this category accounts for 15 percent of the 2017 MIPS composite score, it’s important to make sure your practice is prepared to start documenting all chosen activities long before the October 2 deadline.
Advancing care information — 25% of the MIPS composite score
If your practice is interested in maximizing the opportunity for a positive payment adjustment, the advancing care information (ACI) category is a great place to start, especially because this category counts for 25 percent of the MIPS composite score. The ACI category also replaces MU, so practices that performed well under that program and have the technology in place have a head start. Practices must report on five measures, but can report on all 14 available measures to increase their scores.
The ultimate goal of the Quality Payment Program authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is to encourage clinicians to participate in an Advanced APM that includes two-sided risk. Currently, there are no advanced APMs specifically for rheumatology, but there is an opportunity to submit ideas for an APM to a committee developed as part of the MACRA legislation. The Physician Focused Payment Model Technical Advisory Committee (PTAC) was created to evaluate and recommend new payment models to CMS. You can submit ideas here.
There is a substantial upside for practices that participate in the MIPS program. First, the program encourages clinicians to expand upon the care they provide through better use of technology and a more team-based approach, which in turn, improves overall patient care. The opportunity for adjusted payments is also significant, especially for practices with high volumes of Medicare Part B patients. These key incentives mean you shouldn’t delay your participation.
While reducing costs and improving quality are common themes of MIPS and other value-based care programs, these initiatives also call for patients to be at the center of the decision-making process. This is a new concept to many patients and might also be a departure for how your physicians and staff operate. Patients should understand the changes you are making in providing care, and how they can and should participate in that process. Ultimately, the outcome will be beneficial to both patients and providers.
Linda Pottinger is director of Payer Initiatives, Innovative Practice Services, for McKesson Specialty Health
(Click on the image below to view MIPS quality measures in rheumatology.)