It's Time to Prepare for MIPS Implementation

Decisions, decisions. As if physicians don’t have enough of them to make on a daily basis, now comes word that beginning in 2019 there will be new options for Medicare physician payment. Do physicians go with a new Merit-based Incentive Payment System (MIPS), or participate in a qualifying alternative payment model (APM)?

But hold on. Laura Wooster, vice president of public policy for the American Osteopathic Association, points out that what actually starts in 2019 is the payment adjustments. Mid-January 2017 is when physicians should start collecting data because that’s when measurement begins. And very few physicians, she believes, will qualify for the advanced APM the first year.

“Everyone is encouraged just to prepare to be in MIPS,” Wooster says. “So it’s not as much of an either/or in terms of a decision process.”

However, Wooster further explains that with these new payment options comes added flexibility for specialists to choose the measures that best fit their particular patients and practice.

Reward Potential

Wooster says that understanding all the new requirements under MACRA (Medicare Access and CHIP Reauthorization Act of 2015) will be challenging for physicians during the first year. However, she points out that had Congress not passed MACRA, physicians would only be eligible for penalties if they didn’t perform well in the three quality programs—meaningful use, PQRS, and VBM (Value-Based Payment Modifier).

“With the new program,” she explains, “they’ll still be eligible for penalties if they do really badly, but they’ll also be eligible for incentives—bonus payments if they perform, well. So it does create opportunities for physicians to gain access to some potential new bonuses.”

The greatest challenge in understanding the new rules is the timeline, Wooster says. Rules are not expected to be finalized until September 2016 at the earliest, with measurement starting up in mid-January 2017. That doesn’t leave much time to jump on these potential opportunities before measurement in the new performance system goes into effect.

But the fact that three existing programs—meaningful use, PQRS and VBM—have been rolled into MIPS should allow some familiarity.

“They’re a good on-ramp to the new system,” Wooster says.

For example, the advancing care information category, which is the old EHR meaningful use, is no longer going to be scored with the same, strict, an all-or-nothing approach.

“In the old system, if you had 95% of everything correct, you still would fail and get a penalty,” Wooster says. “With this new system, if you got 95% correct, you’d probably get a bonus on that section of your score.”

Professional Assistance

Wooster suggests physicians consider hiring a consultant to help them ramp up all the changes to their practice. Being ready by January 2017 is a bit ambitious, she adds, but certainly a strategy that makes sense in 2017. That latter point will allow the practice enough time to properly vet all consultants and ensure they bring on someone who understands the new system.

In addition, the new system still requires certified EHR technology, so this is a good time for physicians to make sure that their current system is up to speed regarding tracking all the required data. That could enable practices to take what Wooster calls the next step.

“The proposed rule includes the proposed menu of what’s called the clinical practice improvement activities,” she explains. “That’s that fourth category of quality score that’s all new. And I think looking at those activities are good roadmaps for practice improvements that you can do to try to really transition to this new system and excel in it.”

Group Time

Wooster says that one element that wasn’t addressed as fully as hoped in the new rules from CMS is the concept of the virtual group, which she said would be a benefit to small medical groups. In the original legislation, Congress included a way for small practices to join together in virtual groups, even if they weren’t in the same geographic area, and report their MIPS information together.

“They could basically take advantage of running around their risk,” Wooster explains. “You can join these virtual groups and maybe take advantage of how large groups report and quality and sometimes get better scores.”

Congress determined that it wasn’t able to develop an implementation plan in time for January 2017, so the virtual group option was delayed until 2018. But, Wooster says, even though that proposed rule is on hold, it’s something that medical groups can begin to prepare for.

“And in the law itself it suggests that these virtual groups could be formed by geography, specialty, or some other shared characteristic,” she says. “So even though it can’t be implemented in January 2017, groups can begin to prepare for it.”