By Susan Clark, Health IT Solutions Executive, eHealthcare Consulting
Twitter: @ehealthcareorg
Now that we have had time to digest (choke on?) the MIPS 2300+ page final rule, the picture is becoming clearer. We have begun preparation efforts with the practices that we work with and you know what we are finding? PQRS and MU 2016 are way harder to meet than MIPS 2017. Therefore, if you are already participating successfully in these programs, your transition, and subsequent chance at incentives, looks promising. Here are some highlights of the reprieve to brighten your day:
- Providers who bill less than $30,000 OR less than 100 patients will be exempt. This is an improvement from the proposed rule which was less than $10,000 AND less than 100 patients. And a huge improvement from the current PQRS and VBM program. This will help in many cases, for instance, practices who have team members who are largely hospital-based, but do not qualify for the hospital-based accommodations and may be bringing down current PQRS group outcomes.
- Several Advancing Care Information objectives have gone from having a percent threshold under Meaningful Use to now requiring a minimum of ONE patient to meet. This is especially helpful in achieving the ACI base score of 50 points. Some of these measures include e-prescribing, patient timely access to electronic health information, patient education, secure messaging, and medication reconciliation.
- Knowing that the EHR vendors will, in most part, not be ready to deliver their 2015 standards certified product in 2017, there are less measures for those still using 2014 CEHRT because the technology will not be able to meet some of the advanced objectives.
- They have removed the Resource Use category for the first year of reporting. Yep, you heard me, that means no Value Based Modifier (VBM). Don’t forget about watching your costs and those of your network and referral partners though, and use the time to make a strategy for 2018.
- If you do not succeed for a full 365 days of reporting it does not mean you are out of the running for incentives. Don’t hold back efforts by any means, but know that you will not be penalized if you have made a solid effort. One of the best things about MIPS is that it is not all-or-nothing. There are opportunities to score higher in the areas that do well and apply most to your practice.
- The new CPIA (Clinical Practice Improvement Activities) category is not as daunting as first appears. You have to demonstrate participation in only 4 of the 90+ measures for 90 days. And, for small practice and rural health providers, that number is only two. Additionally, when you see all of the options for these measures, you will likely find several items you are already doing in your practice in the interest of good patient care. The more you are doing or can quickly implement, the more points you will get.
I certainly don’t recommend that you lay back in your lawn chair with a cold beverage and put your feet up for 2017. What we have been given is an opportunity to transform care in a thoughtful and incremental manner as we move into the world of value based care. Now, go hit that EASY button and get to work!