It seems like not so long ago I was writing a very similar blog about Meaningful Use and how it was going to change the adoption of Electronic Medical Records. Since 2011 we have seen some major changes in the industry. Some of them good and some of them not so good. Now, five plus years later, here we are again discussing another change. The 2017 calendar year will mark the first reporting period for the proposed MIPS (Merit-Based Incentive Payment System) program. This program will bring significant change to how providers care for their patients.
MIPS or Merit-based Incentive Payment System – What Is It?
MIPS and APM (Advanced Alternative Payment Models) are products of MACRA (Medicare Access & CHIP Reauthorization Act) which was signed into legislation in 2015 to address the Sustainable Growth Rate (SGR) formula issue.
Currently, we have several programs that could impact a clinicians reimbursement from CMS. The process is confusing and complicated for many groups to know when to attest for which program and how it impacts them. We have Meaningful Use, PQRS, Value-Based Payment Modifiers, etc that need to be implemented, reviewed, tracked and attested for. The implementation and maintenance of these programs can be overwhelming to many groups and often results in unexpected loss revenue.
MIPS is changing the existing model but I actually believe that things will not get simpler for the average outpatient physician group but in fact perhaps more complicated as we move through this significant change in the process. There will be a combination of programs, so in theory, the overall attestation process should be simpler. However, with the combination of programs, you have all of your “eggs in one basket” so to speak. This might be concerning but it’s a little too early to know until we see the final rule which won’t be released until sometime in the 4th quarter of 2016.
This program will cause providers to receive either an incentive or a penalty depending on several key elements. It will also give patients the ability to see how their provider(s) are doing compared to other physicians in the country by using Physician Compare website. Now is the time to begin reviewing all of the program details so that your practice can be one of the organizations that receive an incentive instead of a penalty.
How Does It Work?
The final ruling for MIPS has not yet been released. However, we do have a fair amount of information that we can pass along and begin to analyze and plan for. As more information is released we will continue to explore the details of the program with you.
MIPS basically takes several programs that we have already done in the past such as Meaningful Use, PQRS, PCMH and in some cases ACOs and combines them into a score. Eligible providers will have the ability to earn a number of points in each category. These points will then be tallied up to a total score for that provider.
The program scale will be from 0 to 100 total points. CMS will release a CPS (Composite Performance Score) annually before each performance/reporting period. This number will represent the baseline. In the simplest term, if you fall below that number, you will receive a penalty. If you are above the number then you will receive an incentive. There are other factors that may also allow for extra incentive bonuses. I will dive into those in subsequent blogs.
Below is a brief description of the components that make up the 100 points.
- 50% Quality
- 25% Advancing Care Information (Formerly Meaningful Use)
- 15% Clinical Practice Improvement
- 10% Resource Use
Depending on how well you do with the above categories, your score will determine if you will receive an incentive or get a performance penalty from CMS. In some instances, if you perform very well you can even receive an additional incentive. The better you prepare your practice for the change, the more you have to gain. The scale below provides an outline of how the incentive/penalty program will work. There will also be some additional performance bonuses available that we will explain in subsequent blogs.
Planning for MIPS is going to be key to making this program work for your practice and avoid hefty penalties. This may seem overwhelming but there are many things that you are already doing. It is just a matter of fine tuning the work you have already done and making sure that you are hitting all the key areas. Every point in this program will count toward making you successful.