The last 90 days of the year. Many might be ready to say goodbye to 2020 as a year filled with challenges, adjustments and ever-shifting expectations in our personal and professional lives. For those clinicians who are eligible for participation in the Merit-Based Incentive Payment System (MIPS), the last 90 days of the year also represents the beginning of some measurement periods and the final opportunity to improve in others.
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.
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.
Health systems face a unique challenge when navigating the CMS Quality Payment Program (QPP). All currently available options to comply with the QPP require the submission of some form of clinical quality measures. With multiple specialties and often multiple sources for tracking billing and clinical data, aggregating all available data in a coherent, efficient, and centralized way can seem nearly impossible for the average health system. This case study demonstrates how MIPSPRO assisted one of their health system clients by streamlining their quality reporting process.
The 2018 MIPS reporting year is finally behind us, and you know what that means: time to plan for 2019!
Although this may seem like the last thing you want to think about in the days following the 2018 deadline, MIPS can be very rewarding for those who optimize their scores—and devastating for those on the other end of the spectrum. 2019 is no longer considered a transition year, unlike the first two years of MACRA, 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. In other words, there will be winners and losers, and if you want to stay ahead of the curve it’s imperative to strategize as soon as possible.
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.