For years, we’ve heard that the Merit-based Incentive Payment System (MIPS) will provide a noticeable incentive for participants in this Medicare FFS program. And for years, there have been reasons why that has not occurred. First, CMS wanted to ‘start slow’ with the MIPS program in 2017 and 2018, so the caps on penalties and incentives were small. Then the potential penalties and incentives were raised, but the threshold for qualifying for an incentive remained low. This, coupled with the program’s budget neutrality meant there was not much revenue to distribute to high performers. Then COVID-19 negated much of the program for the last two years. So here we are, in year five, and we see that the program, for the first time, will have a significant downside and upside potential.
The quick answer is NO!
There has been quite a bit of discussion, and some press, about the reporting period for MIPS for 2020. I have seen a few articles saying that no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in the Center for Medicare & Medicaid Services (CMS’s) calculations for the Medicare quality reporting and value-based purchasing programs. However, if you read the Quality Payment Program – COVID-19 Response, Updated 6/24/2020, there is no mention of an all-inclusive change to the reporting period.
We know the current regulatory updates for the Quality Payment Program (QPP) program. To date, the Centers for Medicare & Medicaid Services (CMS) has issued many changes. The 2019 MIPS reporting requirement had an extended deadline and options for hardship exemptions. The 2020 MSSP program reporting period had many changes in both of the interim final rule with comment periods (IFCs) issued by CMS, at the end of March and the end of April. CMS has also added a COVID-19 improvement activity to the 2020 program, that provides full credit for the Improvement Activity category for MIPS, if an individual or 50% of a group (TIN) participates in clinical trial reporting. No changes to the reporting window or other parameters of the program have been issued.
Are you wondering how MIPS reporting in 2020 will be affected by the COVID-19 pandemic? Are you holding off reporting because you are uncertain as to the requirements for 2020? Has the responsibility of MIPS reporting shifted with the impact of the pandemic on your organization?
As public health experts determine that it is safe to see patients, and governments lift stay-at-home restrictions, physician practices are challenged to strategically plan when and how best to reopen. As the AMA points out, there are many components of reopening.
When the time is right, it will be critical to be prepared to reopen, ready to communicate and live a new practice “normal”. In these uncertain times, making sure physical practice changes, staff training, workflow and supplies align, will be important for a successful reopening. Filling your schedule in safe and meaningful ways will help the practice sustain itself and your team. Marketing and communication to patients will help restore confidence and build trust.
Physician practices are confronting new operational and business challenges as a result of the COVID-19 pandemic. There is a mounting financial and administrative toll this pandemic has placed on practices, forcing all to adapt in a variety of areas. Much of the conversation around COVID-19 has appropriately focused on addressing the pandemic and treatment of COVID-19 patients, however, we are also keenly aware of the other impacts on practices.
The Centers for Medicare & Medicaid Services (CMS) continues to relax regulations to enable hospitals, clinics and other providers to boost their front-line medical staff during the COVID-19 pandemic. This pandemic has created an urgency for expansion of the use of virtual healthcare to reduce the risk of spreading the virus. It has also created a need to relax practice restrictions and allow more flexible care practices to meet the needs of patients.
The Centers for Medicare & Medicaid (CMS) is working rapidly to update policies and allow healthcare providers to flexibly apply best practices in response to the COVID-19 pandemic. Programs such as Hospitals without Walls and the existing Patients over Paperwork have been deployed. Removal of barriers have resulted in exponential growth of telehealth and remote patient monitoring. Advanced payments to healthcare providers are being provided to counter the effects of changing patterns of healthcare use, reduction in elective procedure, increase in ICU utilization and other ongoing unanticipated changes.
The Center for Medicare & Medicaid Services (CMS) is paying for a wider range of telemedicine services during the coronavirus pandemic as of March 6, 2020. These remote medical services are available for all patients, not just those receiving coronavirus treatment. Telehealth services now include remote patient monitoring for both chronic and acute conditions, and allow doctors to collect Medicare payments for making phone calls to patients.
There is a tsunami of information coming at us all about COVID-19, the impact to healthcare practices, the business climate, and the federal government response. On Friday, we saw monumental legislative changes. I haven't read the entire 887 page document yet, but here are a couple of the best recaps I've seen.