MIPS questions every practice should answer

To succeed under the Meritbased Incentive Payment System (MIPS), physicians must embrace transforming how their practice does business to succeed with value-based pay. While government regulators have made MIPS participation easier in 2017, allowing physicians to ease into the program via a “pick your pace” plan, in 2018 physicians will have to fully participate, and could face reimbursement penalties if they don’t.

The proposed 2018 rule for MIPS is proof that Medicare’s focus on value-based pay is not going away. “I think you have to accept the fact that this is reality and make your battle plan from here,” says Owen Dahl, FACHE, CHBC, a practice management consultant based in Texas. But diving headlong into MIPS before taking a hard look at what is required and performing a cost-benefit analysis would be a mistake, healthcare consultants say. Here are some questions that physicians should answer to prepare for MIPS.

 Am I exempt?

The first step physicians in solo and small practice should take is to learn whether they even have to participate in MIPS. In 2017, physicians with 100 or fewer Medicare patients and $30,000 or less of Medicare charges are exempt from the program. That exemption expands in 2018, to 200 patients and $90,000 or less in charges, if the proposed rule is approved.

Physicians should visit the Quality Payment Program website (https://qpp.cms.gov/participation-lookup) and use their National Provider Identifier to check whether they are exempt in 2017, says Elizabeth Woodcock, MBA, CPC, FACMPE, a healthcare consultant in Atlanta, Georgia. 

 What level of participation makes sense for my practice?

A good financial and practice management strategy means evaluating potential programs on a cost-benefit basis, Woodcock says. Under MIPS in 2017, doctors can either receive a payment penalty, which maxes out at 4%, or a bonus that can reach as high as 12%. Physicians will fall along that spectrum based on their performance. The key is whether competing for this bonus-or avoiding the penalty-is worth it.

“I think this is very important before we move on down a potential path,” Woodcock says. “If at the end of the day we are talking about a potential $500 gain, then it makes absolutely no sense to stroke a check to your [electronic health record (EHR)] vendor for $3,000 to get some upgrade you need to connect to a registry, and then stroke another check to a registry and another check to a consultant.”

Examine your Medicare collections for 2016 and find out how much is at stake. Second, determine the costs of complying-such as EHR upgrades, registry access and consulting help-at the level you’re comfortable with. And then do the math to see what makes sense, Woodcock says.

 What’s the easiest way to avoid a penalty?

Under the “pick your pace” program in 2017, reporting just one data point under MIPS allows physicians to avoid a penalty. (It will not earn a bonus, however.) Woodcock suggests that physicians look at the practice improvement activities, which include many things physicians likely are already doing, including patient satisfaction surveys, test results notifications or care coordination training. There are 92 activities to choose from, and reporting only one is necessary, Woodcock says.

 Is my EHR system ready?

Not all EHRs are ready for MIPS. Often, physicians will need to purchase third-party software or registry access to be able to report quality measures and attest to the Advancing Care Information (ACI) portion of MIPS. Physicians will need to check with their vendor on the EHR’s level of readiness, then factor that into their participation decision, Woodcock says. 

Under the proposed rule for 2018, small practice physicians who can prove their EHR is not up to the task of meeting ACI can obtain a hardship exemption and have their points for ACI reallocated to the MIPS quality category, says Cindy Dunn, a consultant and director of client services at IntrinsiQ Speciality Solutions in Titusville, Florida. 

It’s unclear, however, whether these same EHRs will be ready to handle quality measures. While there are over 200 quality measures for physicians to choose from, physicians must identify the ones they want to report on and find out if their vendors can supply the data, Dunn says.

“If you have an EHR, you really have to talk to them about reporting capabilities for quality,” Dunn says. “I want to make sure I can get that report out of my EHR without pain. Can my EHR vendor do that? Or is the EHR vendor going to say, ‘we didn’t build that into the EHR; you’re going to have to pay.’”

 How do I plan for the future under MIPS?

Even if physicians don’t participate in 2017, Dunn says practices should be focusing on the future by prepping for the two most challenging sections of MIPS: quality and cost.

Cost is difficult because often there is little physicians can do to control it, and the fact that cost is not included in the score in the early years of MIPS can lull physicians into a false sense of complacency, Dunn says. The best thing physicians can do now is review their Quality and Resource Use Reports to become aware of how costs are allocated. Instructions for how to obtain these reports can be found on here: bit.ly/QRUR-101.

When it comes to quality metrics, it will be tempting or physicians to choose the route of least resistance-essentially choosing the simplest of roughly 200 measures identified by the government. But that may not be the smartest choice. Dahl says physicians should closely study their panels and pick the metrics that will help them improve care for their patients.

“You can look at this thing from two different perspectives,” Dahl says. “One is, ‘I want to comply with this as easily as I can.’ The other perspective I try to encourage folks to think about is, if you are going to go through this, think about the long-term impact on your practice and the metrics you can foresee coming down the road. Don’t always pick the easiest one, pick the one you want to monitor.”