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.
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.
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.
It felt as if the Medical Group Management Association (MGMA) Annual Conference, which we have attended for years, was smaller this year. The hall was down 10 percent, and the foot traffic was slower. Regardless, we left with plenty of insights into the state of the industry. Here are some of the highlights of what we learned:
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).
Since 2017, the Centers for Medicaid and Medicare Services (CMS) Merit-Based Incentive Payment System (MIPS) has provided eligible clinicians a score of zero -100 annually based on the clinician’s efforts and data collection in four program categories: Quality, Improvement Activities, Promoting Interoperability, and Cost. A clinician’s final score for each year’s MIPS performance ultimately dictates a payment adjustment that is applied to his or her Medicare Part B reimbursement rate two years later. In practical terms, this means that a clinician’s 2017 performance impacts all of his or her Medicare claims that are filed in the 2019 calendar year.
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.
Today, CMS posted CY 2020 Updates to the Quality Payment Program to the Federal Register. Many clinicians are still trying to wrap their heads around how to report MIPS in 2019, but the release of the 2020 proposed rule is advantageous in deciding what to conquer both this year and in the future. As the title suggests, this document also covers other Quality Payment Program tracks, like Advanced APMs; however, for now we will just focus on the MIPS component of the proposed rule.
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.