The CY 2019 Medicare Physician Fee Schedule Final Rule involves a slew of regulatory changes that will apply to the 2019 performance year. Of course, wading through the final rule to find and understand the most important features of the policy can be grueling; but you’re in luck, because we’ve already done it so you don’t have to! In today’s blog, we’re focusing on how MIPS final scores will be calculated, as well as factors that may lead to reweighting, in 2019.
If your organization invested significant money and time into achieving a high MIPS score in 2017, the final incentive payment you received may have felt… well, disappointing. As easy as it may be to recognize the ideological importance of shifting from fee-for-service to value-based care, many clinicians and organizations feel unable to practically justify such an investment in the absence of a meaningful financial incentive.
But there’s good news: incentives will continue to rise in coming years, and those achieving the highest scores will soon find their efforts rewarded on a much larger scale. Here’s why.
Note: This article will update as we learn more, and to reflect any changes that may happen before the rule is officially published to the Federal Register on November 23, 2018. To view the entirety of the final rule, view the unpublished pdf version.
There’s no doubt that MIPS involves a learning curve. The program’s rules can be complex and can require cumbersome initial investments of time and money, leading many doctors to try to avoid it altogether. But MIPS matters, and the most successful doctors in coming years will be those who invested wholeheartedly in the reporting process. Here’s why.
The Centers for Medicare & Medicaid Services (CMS) released the 2019 Proposed Rule for the Medicare Physician Fee Schedule on July 12, 2018. The release of the 2019 proposed rule is advantageous in deciding what to conquer under the Quality Payment Program for both this year and in the future, which is why we published a series of posts summarizing the major proposed changes you should be aware of. But what if you have a suggestion that would improve the rule?
In 2018, CMS is pushing even harder for the shift toward value based care. The minimum MIPS reporting score has increased from 3/100 to 15/100, and failing to report results in an automatic 5% reimbursement penalty. But if your practice or organization isn’t in a position to invest the kind of time, money, and resources that it takes to really go all in on VBC, you might be wondering: “what’s the minimum I can do to avoid the penalty?”
There is no one answer to this question, but the good news is that your practice has several options for how to report to earn a score of at least 15/100.
For many practices, one of the biggest differences between MIPS reporting for 2017 and 2018 is the amount of information that needs to be reported to achieve a high score. Gone is the test option that allowed clinicians to simply report on 90 days worth of patient visit information for the Quality performance category—now clinicians need to report on 60% of eligible patient visits per measure for all payers. This is typically a phrase I repeat a few times when discussing MIPS with practices who reported minimally for 2017.
As we make our way through year two of the Quality Payment Program (QPP), it’s clearer than ever that simply reporting quality data is no longer enough. CMS penalties and incentives reach 5% in 2018, and in future years payment adjustments will continue to increase along with the percentage of patients you will be required to report on. Meeting quality standards and cutting costs are also increasingly important as measures are assessed against benchmarks and peers. Choosing the best reporting method for your practice is therefore an increasingly important step toward reporting efficiency and ultimately reporting success.
We get a lot of questions from multi-specialty practices about how to get started with MIPS reporting. Measure selection can be confusing, and there are many common misconceptions, such as the assumption that different specialties cannot report together. Reporting MIPS can even seem entirely hopeless, due to the size, services, and systems used by your practice. That’s why this week we’re sharing our advice about the most significant steps your multi-specialty practice can take to set itself up for MIPS success!
Over the past year, we tracked over 11 million patients with over 2 BILLION quality actions in MIPS reporting alone! We are already back to work and developing some really cool new analytic solutions to help our clients optimize their Quality outcomes.