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When thinking about a solid MIPS strategy there are multiple things to consider. Read part one of our three-part series.
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.
When thinking about a solid MIPS strategy there are multiple things to consider. One of the first considerations is to weigh the value of the program to the practice. Are you interested in merely coming in under the wire to avoid penalties, or can your practice benefit from capitalizing on available incentives?
Here we narrow in on five topics: eligibility, measure selection, penalties and incentives, and information availability. The 2019 proposed and final rulemaking as well as the information available on the QPP portal have revealed a great deal about these topics and how they should be considered within the scope of a practice’s MIPS strategy for 2019 and for years to come.
These five topics will be covered in a three-part series – welcome to part one.
Eligibility
For 2019, the QPP rule established that physical therapists, Occupational Therapists, speech-language pathologists, audiologists, clinical psychologists, and dieticians/nutritional professionals would be considered MIPS eligible specialties, if they otherwise meet MIPS-eligibility criteria for volume and Medicare billings. The final inclusion/exclusion decision is good news for some while bad news for others. For those excluded specialties that have been gearing up to report for MIPS for 2019 but now don’t have to, those efforts can feel like a waste. On the other hand, some excluded providers will be happy to be off the MIPS hook for another year. The addition of a 3rd criterion for the low-volume threshold makes it more difficult to be automatically considered MIPS eligible but opens a third pathway for non-MIPS eligible clinicians who want to opt-in to the program, to be eligible to do so.
For the newly eligible specialties, CMS decided to implement a slower transition to the program, CMS is automatically weighting the 2019 Promoting Interoperability (PI) category to 0% for the new MIPS eligible specialties. The intent is to allow them to focus their attention and efforts on Quality and Improvement Activities (IA) to start. For their 2019 MIPS strategy, many of the new specialties will need to be tactical when it comes to measure selection. The large number of measures that were retired for 2019 will force many of the newly added specialty groups to think strategically about which measures they can report on.
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 solution, 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.
Learn why mid to large sized healthcare organizations turn to ReportingMD for powerful tools that help improve patient care, improve quality outcomes, and maximize reimbursements.