Healthmonix Advisor

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. 

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.

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.

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.

The new proposed rule for 2019 features a lot of changes to the Quality Payment Program, but CMS has also announced changes impacting Medicare reimbursement in general. One big change proposed would affect how much money a clinician receives for billing office or outpatient Evaluation and Management (E&M) visits for new and existing patients.

Hospital executives have to make tough decisions during the shift to value based care, especially when it comes to software. What systems are worth investing in, and how can you ensure your hospital is getting the most out of its money? In MIPS reporting, for example, it can feel like an impossible task to weigh the pros and cons of reporting via EHR or working with a registry.