2018 MIPS Performance Feedback – Scaling, Scoring, and Supplemental
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) replaced the Medicare Sustainable Growth Rate (SGR), which was how CMS previously controlled the cost of Medicare Payments to physicians. MACRA is aimed at strengthening Medicare access, improving physician payments, and encouraging better patient care among other improvements. Under MACRA, CMS is required to implement a Quality Payment Program (QPP), which offers clinicians and practices two separate tracks: (1) the Merit-Based Incentive Payment System (MIPS) track; and, (2) the Advanced Alternative Payment Model (Advanced APM) track. Both tracks can result in penalties for not meeting certain requirements/benchmarks or incentives for meeting and exceeding requirements/benchmarks.
The 2018 final MIPS scoring, and performance data has been released, so what do you and your executives need to know? Here are 3 topics that your key stakeholders should be aware of in regard to this latest news:
- Scaled Payment Adjustments – How does a 15% potential payment adjustment turn into 1.68%
- MIPS CPS Scores – A few examples to learn from
- Supplemental – what else is there to know about
Scaled Payment Adjustments
The question remains, “how does a program touting a maximum of 15% incentives for top performance get finalized to only achieve a maximum of 1.68% incentives? The answer is that the program is budget neutral. Budget neutrality means that the incentives are based on the amount of penalties. The payment adjustment, which for 2018 was +/-5%, gets scaled based on the amount of money in the penalty pot to pay out in incentives. For 2018, we know that only 3.2% of the roughly 600k clinicians who were MIPS eligible will actually be penalized in 2020 based on their performance being below the avoid penalty threshold. Those penalties will serve to pay out to the 537,531 clinicians who reported and achieved scores above the avoid penalty threshold. The other aspect of the payment adjustments is the exceptional performance incentive. The $500 million set aside per year for the 1st 5 years is split up and scaled based on the number of clinicians who reached that level of exceptional performance.
As a practice stakeholder, you don’t need to wait until 7 months after the performance period ends to get an idea of your estimated payment adjustment. Working with subject matter experts, who are well-versed in the program, can help to educate you throughout the year on how much the real payment adjustment will likely be. In regards to the scaled payment adjustment rates, don’t be the last to know.
MIPS CPS Scores
MIPS scoring and the resulting payment adjustments revolve around performance thresholds. There is a penalty avoidance performance threshold score and an exceptional performance threshold score. Both of these performance thresholds will continue to increase each year of the MIPS program until they are ultimately based on the mean or median MIPS CPS scores of the entire MIPS eligible clinician community.
Avoiding a penalty from the 2018 MIPS performance period was 5 times harder than it was to avoid a penalty from the 2017 performance period. A score of 15 was required to avoid any downward adjustment in the 2020 payment year. A score of 70 was required to receive any exceptional performance incentives in 2020.
As a practice stakeholder, a MIPS strategy of just avoiding the penalty was tricky but not impossible in 2018. That tactic will not work in 2019 as the avoid penalty threshold score increased from 15 CPS points in 2018 to 30 CPS points in 2019. That means it will be 10 times harder to avoid penalty in 2019 as it was in 2017. Get ready for this program to ramp up and for your practice to either saddle up or get hammered with large negative payment adjustments in the future.
What other items and aspects of the 2018 MIPS performance feedback is important to know? In 2018, the MIPS cost category actually started to have some weight. MIPS eligible clinicians and practices, who met case minimums on the Total Per Capita Cost (TPCC) and Medicare Spending per Beneficiary (MSPB) measures, were scored based on how their cost levels compared to the national averages. Even those who only met the case minimums for one of the two cost measures had their entire cost category score based on the single measure.
After having spent several hours on the phone with CMS following the 2017 performance period, pleading for insight into the beneficiary level data that was used to calculate cost scores, CMS has answered our wishes. As part of their final performance feedback, CMS has provided beneficiary level cost data for practices and clinicians to review. That being said, the cost category and the specifics that go into how the actual measure score gets calculated is complicated. Make sure to listen for ReportingMD webinars on the cost category as well as other topics for more detailed insight on these topics.
The final message to be gleaned from the 2018 final performance feedback being released is that the incentive rates were underwhelming (to say the least) and the program is not getting any easier. The good news is, however, for those who have continued to work at their reporting but have seen less than stellar incentive rates, the tides are changing. 2019 is the first year where top performers will likely see the benefits of their hard work from all years prior under PQRS, Meaningful Use, and now MIPS.
Don’t give up yet, as MIPS is just getting started!
The criteria which determine MIPS eligibility are multi-faceted and complex. ReportingMD understands these criteria’s and works with client organizations to optimize incentive performance in the MIPS (and other value-based care programs.)
With the proven experience of our client services team and Total Outcomes Management (TOM™) a powerful measure calculation engine, ReportingMD can help you navigate the complexities of the MIPS program.
We were invited by CMS to help develop the MIPS program, which provides our team with unique expertise and a depth of experience that’s unmatched.
Using TOM™, practices can gain operational visibility to the quality performance of their physicians and avoid CMS penalties for non-compliance. TOM™ aggregates data from multiple sources to identify and manage patient care gaps.
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