By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
Maybe there was no other way to do it. Reign in the high cost of healthcare by boiling it all down to one easy to digest number. Rate each eligible Medicare Part B clinician on a 0 – 100 score. Take all the complexities of four categories (Meaningful Use, Cost, Improvement Activities, Quality Reporting) mix them thoroughly and shove them in the oven until golden brown. Out comes a Composite Score for every Medicare Part B clinician in the MIPS program. Repeat once a year. Base reimbursement on the score and take money from the low scorers and give it to the high scorers. Make the scores public. Unintended consequences? You bet, but we will have to wait to see what they are.
The Final Rule defines the composite score by stating: “Final score means a composite assessment (using a scoring scale of 0 to 100) for each MIPS eligible clinician for a performance period determined using the methodology for assessing the total performance of a MIPS eligible clinician according to performance standards for applicable measures and activities for each performance category.” By definition there will be low scoring providers because they have to balance high scorers as the neutral reimbursement score floats from year to year in this zero sum program.
An entire wave of consultants is gearing up to assist affected providers with the necessary steps and strategies to score higher on the scale. I should know, I am one of them. The fact that money has been set aside in the Final Rule to assist small practices and those that struggle to improve their score is proof that the competitive advantage will be going to large and high volume Medicare practices in this new world of competition. Make no mistake about it, there will be winners and losers, and we are on the cusp of a reimbursement world based on what appears to not be a level playing field. Larger and wealthier practices will have the compliance and regulatory staff to gain an advantage from Day 1. This is not your Daddy’s Meaningful Use program.There is a high possibility this group will be receiving money that comes from the smaller and more rural practices. What will this mean in the long run? We simply don’t know as this is an experiment that has the potential for unpredictable outcomes and unintended collateral damage.
The CMS EHR Incentive programs were adjusted and tweaked on a regular basis to bring sanity to the process by modifications, exemptions and exclusions. I hope this will be the case in the MIPS program. The risk that a subset of the provider community could be damaged is very real unless critical oversight leads to prompt program adjustments. There is too much at stake to do otherwise.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: Inquiry@meaningfuluseaudits.com.