By David Spellberg MD, MBA, FACS, Independent Consultant and Strategist
Twitter: @DSpellberg
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During the recent Radiological Society of North America conference at McCormick Place in Chicago, a session titled, “Will MACRA and MIPS Kill Your Practice?” pretty much summed up the consensus feelings of most physicians. But as usual, with chaos and disruption of the status quo, an opportunity is present for the prepared and willing. And now, given the flexibility of the program, it’s hard to formulate a good reason why providers would not elect to participate in the new payment program in 2017. More importantly, as long as providers participate at some level, they can avoid reimbursement penalties in 2019.
Under MACRA’s Merit-based Incentive Payment System (MIPS), providers can submit as little as one quality measure improvement activity for any time period in 2017 and avoid a financial penalty. Medicare Part B eligible providers are currently being measured annually in four performance categories to derive a MIPS score between 0 and 100. That score will determine positive, neutral, or negative future adjustments to each provider’s annual Medicare reimbursement.
The more data submitted the more potential to earn a payment incentive. Not submitting any data will result in a 4% payment penalty two years from now. There are three options under MIPS to avoid punishment: 1) submit minimal data and avoid penalties; 2) submit 90 days of data, have the opportunity for small upside; or 3) submit a full year of data, and have the opportunity of a potential bonus for high performance. Hidden in the details, however, is that future penalties dramatically increase both monetarily and will also damage a provider’s reputation.
The Centers for Medicare & Medicaid Services (CMS) will set a performance threshold score each year. In 2017, the performance threshold is 3. In 2018, and beyond, CMS will use the mean or median of eligible clinicians’ MIPS scores from a prior period. There is an incentive to be a high performer. Clinicians or groups that achieve a MIPS performance score of 70 or higher, can earn an additional higher positive adjustment up to an estimated 2.4%, funded from a separate pool of $500 million.
While financial incentives for the program can be big, more importantly the Medicare Quality Payment Program lets the CMS publish each physician’s annual score (as well as scores for all participating physicians) on its Physician Compare website. Furthermore, it will also share that data with other third-party ratings sites including HealthGrades, Yelp and Google. That means patients and others will see physicians’ scores online, likely without the context included. So a low score, either due to poor performance or just simply doing the bare minimum to meet quality metric requirements will essentially look the same. The score also follows physicians who switch organizations–becoming, a part of that physician’s permanent file. While a poor score will be a negative mark, a top score has huge potential. This now becomes a new and easy marketing opportunity for those first adopters, especially those with electronic health records that are already pulling out the needed data. Many advisors suggest that physicians make their data work for them by selecting the measurement of activities that they already do and want for their patients. This can make the process relatively painless for the provider and office staff.
The window for participation is closing sooner than you think, so now is the time to plan and execute how your practice can become highly rewarded with each provider gaining the coveted 100 MIPS score. Remember, this is a great opportunity for the prepared. Don’t be left behind!