As we find ourselves midway through 2020, there is much uncertainty about successfully reporting to avoid penalty under MIPS. Since 2017, CMS has offered too many “easy” reporting techniques that result in no penalty. This course will result in many clinicians and practices being ill-prepared to reach the 45- and 60-point thresholds needed to avoid penalty for the 2020 and 2021 performance periods. The penalty threshold is increasing by 15 points every year, so any clinician or practice that has not reported with the goal of perfect MIPS performance could be left facing penalties.
Looking to the 2020 Final Rule and to the requirements established by Congress, we can see what the future holds regarding the penalty threshold… more uncertainty. Starting in 2022, the performance threshold must be set at the mean or median of the final scores for all MIPS Eligible Clinicians from a prior reporting period. This translates to roughly half of all participating practices falling below the penalty threshold, regardless of the actual designated point. This is a far cry from the required 3 points for 2017 and 15 points needed in2018. Many practices will be left on the wrong side of the penalty threshold if proper groundwork doesn’t begin now. ReportingMD has the tools, team and years of experience to help your practice navigate the muddy MIPS waters of today to success in the coming payment years.
Failure is a part of the MIPS program; it is required for the program’s success and survival as a budget-neutral program. The practices penalized will fund those who score above the threshold. Without failure, there is no funding. Not every practice can be above average, and CMS will no longer be in the habit of handing out participation trophies. There will be some winners and some losers as the threshold continues to climb in the coming years.
This may sound like catastrophizing but there is a point. Many practices have been “asleep at the wheel” so to speak when it comes to the topic of increasing difficulty. Preparedness will help a practice come out on the right side of the MIPS problem of mounting difficulty. Practices must be better clinically and be better at reporting in order to avoid penalty.
The COVID19 pandemic is not the only challenge practices are faced with. CMS continues to top-out and cap many measures at a max point score of 7 points due to ever-increasing historical benchmarks being established on easier (process-type) measures. Another challenge to practices is self-submitting or relying on the Medicare Part-B claims method of submission – a black box of uncertainty until the preliminary feedback is supplied. That submission method provides no way to manage or review performance until it is too late, leading to nasty penalty surprises two years after the performance period.
Practices only submitting to avoid the penalty are strategically on the defensive, without procedures in place to get ahead of the moving threshold target, will struggle as the program progresses in difficulty and will continue to play “catch-up” with scoring. This struggle is also experienced by practices using the default EMR data management and submission techniques offered by their EMR. Not having a dedicated team to help support practices and clinicians in the many pitfalls of MIPS reporting will leave points, patient care opportunities, and cash on the table.
How does a practice go about confronting and overcoming these challenges? Turn to the experts at ReportingMD. With seventeen years of experience, ReportingMD is perfectly poised to provide expert consulting in everything from measure selection to integrating your EMR more effectively. Having the Total Outcome Management (TOM) suite as a resource is a key advantage, with the ability to view each patient on a per visit level, is a required advantage when it comes to finding care gaps and spotting patterns.
Waiting until 2021 has begun, or even procrastinating further into the 2020 performance year to prepare will likely result in poor scores and minimal incentive, or even penalties for years down the line. The best approach to MIPS is a long-haul strategy with each year’s performance building upon itself to perform better and better as the thresholds increase over the course of the program. Start planning now for MIPS 2020 and beyond.
Value-based care analytics extends far beyond data aggregation and reporting. Success in value-based healthcare depends on strong clinical data expertise, deep programmatic knowledge and performance analytic solutions that are flexible and transparent.
We partner within each level of an organization to help you make the transition to value-based risk smoothly, with less administrative burden and no disruption to the delivery of care.
ReportingMD has more then 17-years’ experience in this category and is uniquely positioned to create a value-based care analytic management program that allows:
- Optimized quality scores
- Reduce physician, IT and administrative burden
- Enhance performance incentives and reimbursement
- Improve patient outcomes through care-gap management
Think of our team as your “plug-and-play” quality analytics department.