Healthmonix Advisor

MIPS, the Merit-Based Incentive Payment System, is evolving. CMS has laid out a plan to increase quality of care while controlling costs, and all Medicare providers are expected to participate in eligible alternative payment models by 2030.  

In this blog post, we'll discuss the changes for 2023 and how small practices can maximize their scores and reimbursement.

Back in January of 2021 our CEO, Lauren Patrick, wrote "MVPs – Will they replace ‘traditional’ MIPS?"  At that time there were a lot of questions about how CMS would implement their new reporting framework, MIPS Value Pathways (MVPs).  Starting with the 2023 Program Year (PY), MIPS eligible providers have two pathways they can take to satisfy their obligations.  In this blog, I will review what an MVP looks like and how you may want to implement them within your practice. 

The 2023 Physician Fee Schedule (PFS) Final Rule was released in November 2022, finalizing many of the promised features of accountable care organizations (ACO) quality reporting.  A couple weeks ago, I wrote about the Quality reporting requirements and Healthmonix's strategies to approach the upcoming changes. For Part 2 of this discussion, I will be introducing the new Health Equity Adjustment and why it will impact quality reporting moving forward. 

Part 3 will cover the move from all or nothing scoring to a scaled approach. 

Once again, if you are a visual learner, you can get most of this information from  our latest webinar. 

The 2023 Physician Fee Schedule (PFS) Final Rule was released on November 6, 2023 and included over 3,000 pages of the Centers for Medicare & Medicaid Services (CMS) regulations and rulings for the 2023 year. While there is a ton of information to cover the entire rule, I would like to share what you need to know about the impact on the Medicare Shared Saving Program (MSSP) for Accountable Care Organizations (ACOs). In the first of this three-part series, I will cover Quality Reporting Requirements and Strategy. Subsequent blogs will cover Introduction to the Health Equity Adjustment and The Move from All or Nothing Scoring to a Scaled Approach .

If you are a visual learner, you can get most of this information from our latest webinar.

Starting in January, 920 primary care practices will embark on the one of the newest payment models from the Centers for Medicare & Medicaid Services (CMS) via the Primary Care First (PCF) Program.  The main criteria for participation in the program are:

• 70% or more of the practice’s collective billing must be for primary care services.
• Use of a 2015 Certified Electronic Health Record Technology (CEHRT) by the practice.
• At least 125 services provided for attributed Medicare beneficiaries.

Also, for the first year of the program, there is a limited geographical area for participation.

The 2021 Proposed Rule was released last week, and there are some potential changes that you should keep your eye on. Scouring through the entire release, it’s apparent that the Centers for Medicare & Medicaid Services (CMS) kept to their two main objectives:

1. Minimize changes to reduce the burden on providers digging out of COVID-19
2. Keep the momentum of the Quality Payment program moving forward

The Merit-based Incentive Payment System (MIPS) can be rewarding for those who optimize their scores, and devastating for those who fall behind. 2019 is no longer considered a transition year, which means that the program is doing away with much of the leniency that made reporting easier in the past. The financial risk is now as high as 7%, while the performance threshold has increased to 30 points.

As the stakes continue to rise, it’s more important now than ever before that organizations strategize about their MIPS reporting process for 2019 and beyond. And in the course of that effort, one major decision they will need to weigh carefully is whether to report as individuals (at the NPI level) or as a group (at the TIN level).

In last week’s blog I laid out the case for opting into MIPS, an option that allows clinicians and groups to still receive a MIPS payment adjustment if they exceed 1 or 2, but not all, elements of the low-volume threshold. Although this option can be beneficial for a wide range of clinician types depending on their situation, today I want to focus on psychologists in particular. Because in my experience, they provide some of the most striking examples of this “MIPS hack” in action.

Beginning in 2019, otherwise-eligible clinicians, groups, and APM entities can elect to opt-in to MIPS if they exceed 1 or 2, but not all, elements of the low-volume threshold. That means that for the first time, these previously ineligible clinicians have the opportunity to participate in the QPP and earn a payment adjustment.

Now maybe you haven’t had the time to pay close attention to policy minutiae, and this is the first you’re hearing of the opt-in option. Or maybe you’ve heard of it, but haven’t looked seriously at what it could mean for you or your organization. After all, on the surface it just sounds like work that isn’t required--and could it really make enough of a difference to your bottom line to be worth it?

Well, we highly recommend you do the math to find out. Because depending on your situation, you might be very, very glad you did.

I speak with many organizations who are planning to report MIPS individually, only for their eligible providers. What they fail to realize is that they can achieve significant additional revenue by reporting as a group for all providers in their practices, even those that are deemed ineligible. In these cases I like to do a simple cost comparison to show what organizations are missing out on, and while each case is unique, the results are often striking.