By Peggy Losey, Manager of Ambulatory Incentive Programs, ehealthcare Consulting Inc.
Twitter: @ehealthcareorg
MIPS. The emerging Medicare payment model where MU, PQRS and VBM intersect, and the construction of the payment system focusing on providing value and quality, begins.
How are you doing with Meaningful Use, PQRS and VBM? Are you using your QRUR as a roadmap to help get you there? Accepting a little road trip advice now will help you prepare for a safe arrival at your destination with minimal detours. CMS recently announced that the implementation of this program has begun. Are you on the right road?
So, what is this MIPS?
On April 16, 2015 the “doc fix” bill permanently repealed the Medicare Part B SGR reimbursement formula. In its place, and with bipartisan support, the pay-for-performance program, MIPS became law.
MIPS, Merit-Based Incentive Payment System is the “roll up” of currently familiar value based programs, Meaningful Use, PQRS and Value Based Modifier. It focuses the fee-for-service payment model on value and quality. The program is set to begin in performance year 2017, with subsequent positive or negative payment adjustments in payment year 2019. The final rule for the program is anticipated for release in 2016.
MIPS will assess the performance of EPs in 4 categories:
- VBM Measured Quality (30 points);
- VBM Measured Resource Use (30 points);
- MU participation (25 points);
- Clinical Practice Improvement (15 points).
Composite scores will be compared to a performance threshold. Upward or downward payment adjustments will be determined through a linear distribution based on mean or median performance of all MIPS for EPs during the performance period.
EPs will select the participation option that best fits their practice environment: CEHRT, qualified data registry maintained by specialty organization, “virtual” group, or hospital or facility-affiliated group.
Bonus payment options for participation in alternative payment models (APM) may also be achieved.
For the first two years of the MIPS program your payment will, in part, be determined by the work you are doing today with MU, PQRS and VBM. So, MU, PQRS and VBM efforts now will impact your performance score in the early years of MIPS!
Successful participation in these programs today will help ensure a smooth ride through the “construction zone” and onto the MIPS highway. And, if you dare to risk, you could even earn some bonus “gas money” along the way.
You’ve purchased the “new car”, or at least had a good tune up by a “certified mechanic”, studied the owner’s manual and consulted experts for route options. It’s now time to restock your mental toolbox in anticipation of any bumps along the road!
So what can you do now to ensure a smooth journey?
- Continue to improve performance in MU, PQRS and VBM programs
- Use your QRUR reports as a forecasting tool to benchmark progress
- Consolidate program tasks to create efficiencies (ie: use eCQMs for MU & PQRS)
- Consult with an industry expert to help you navigate the journey and keep an eye on road conditions ahead!
Treat this pending transition as you would a new roundabout in a previously familiar intersection.
The concept is new. The entry rules are confusing. You don’t get it! It’s fine in someone else’s neighborhood, but not in yours!
You will not be going in circles forever. You will catch on to the technology and you will eventually accept the change. You may even learn to like it!
Here are a few rules of the road to get you started.
- Become familiar with the rules. It’s a different way to get you to the same place.
- Yield at the entries and merge with traffic…slowly at first, but increase your speed as you settle into the flow.
- Stay in the safety of the inner circle where you feel comfortable with your current skills while allowing new “drivers” to enter…one at a time.
- Once you have mastered the skills necessary to “change lanes”, merge into the “through traffic” outer lane and prepare your exit strategy from your current FFS payment strategies into the new destination of Pay-For-Performance quality based payments.
- Note: Left turns and U-turns are correctable. If you miss your exit, it’s not difficult to get back on the right track! Jump back in the inner circle again if you need to, or stop in at the nearest “service station” for some expert assistance. This dealer is open 24/7.
- Road rage can result in stiff penalties! Pack your patience!
Keep your eyes on the road ahead. Slowdown in the construction zone. Maintain your forward progress and when the project is complete you will enjoy improved conditions. And…should you need to stop for directions, that’s OK!
From the author
Born-and-raised in Detroit, I draw a familiar analogy between the volatile auto industry in which I grew up, and the constant flux of the healthcare environment in which I/we work today. My experiences create real world comparisons of financial, practical and philosophical struggles that are common in both industries, convincing me of their importance for long-term sustainability as well as staying flexible for the long haul. Please pardon some of my auto-related references above and accept my sincere wish for a smooth ride.
About the Author: As Central and West Coast Outpatient Meaningful Use (MU) and PQRS Services Manager, Peggy Losey brings 19 years of clinic operational expertise to the “family” and brings a true passion to her work as an avid patient and physician advocate. Her background includes supporting all aspects of physician practice EHR implementations and her recent work as a EHR Clinical Implementation Specialist working for a Regional Extension Center (REC) enables her to provide service offerings that many physician practices are in need of today.