Monitoring MIPS: Act Now or Wait and See?
You survived 501(r), ICD-10, the changes that came with the Affordable Care Act and the implementation of healthcare exchanges. Just when you began understanding the Physician Quality Reporting System (PQRS), and how it impacted your reimbursement currently and in future years, now here comes more Medicare payment reform. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) brought 2,398 pages of proposed governmental reimbursement reform right to your exam table.
Put simply, the new rule further moves from paying Medicare health professionals for volume to paying them for value through the Quality Payment Program (QPP) set forth by MACRA. The Merit-Based Incentive Payment System (MIPS) is the default path that will apply to almost all providers. The new rule, published by the Centers for Medicare & Medicaid Services (CMS) in May 2016, paves the way for new healthcare performance measurements. Clinicians treating Medicare patients will be required to report to CMS specific measurements, with one of the components being similar to those in the Physician Quality Reporting System (PQRS). Participation is no longer enough; rather, it’s about how you compare to your peers. CMS will use provider-reported measurements to reward or penalize clinician reimbursement starting as early as 2019.1
Pick Your PaceSince the federal government issued its final rule Oct. 14, 2016, many providers are wondering exactly how MACRA will modify how they will care for Medicare patients. CMS had shed some light in September when it announced it would ease MACRA implementation by offering clinicians four options so they could “pick their pace” in 20172 to comply with the new Medicare Part B payment reform system. There are three options under MIPS: test the QPP, participate for part of the calendar year, or participate for the full calendar year. A fourth option is participating in an advanced Alternative Payment Model (APM).
Regardless of whether or not you know now which option best fits your future, one thing is certain: Medicare payment reform will put your practice at a crossroads related to quality measurement and reporting.
All the while, on the front lines of providing care, physicians are finding it more difficult to meet the quality reporting standards. So is it time for your practice to find a Qualified Clinical Data Repository (QCDR) to invest and participate in? Will doing so now for PQRS guarantee that you will be ready for MIPS?
A Defining MomentPerhaps your practice is sizable and profitable enough to build — and to certify — your own QCDR to submit clinical metrics to CMS. When providers build an independent QCDR, they control their own quality data. This allows for individualized decisions around what you want to monitor and measure that not only meet the MIPS standard, but also align with your own view on quality. Or if you’re part of a smaller practice, is now the time to look to join forces with a larger entity to help manage the move to providing value-based care?
You’re not the only provider asking these types of questions — and feeling uncertain of the appropriate answers. Frankly, it’s because there is no one right response as the MACRA rules and new payment guidelines under MIPS are not yet final. Despite this, the ruling as it stands right now presents a defining moment for all types of clinicians to carefully and thoughtfully form a perspective on quality care measurement and reporting within their own clinical care settings.
Your individualized viewpoint on clinical quality — once formed and well-articulated — should provide a foundation to evaluate your options and the related potential investment and expenditures associated with participation in MIPS. You may determine that your full participation in MIPS can wait, and simply testing the quality program for now may be your best avenue. This is especially true if you’ve not established your own perspective on clinical quality.
References1. National Center for Policy Analysis. The “Doc Fix” Is In: An Initial Assessment of Medicare’s New Rule over the Practice of Medicine.
2. The Centers for Medicare & Medicaid Services. The CMS Blog: Plans for the Quality Payment Program in 2017: Pick Your Pace.
Conifer Health offers a comprehensive portfolio of solutions to help clients make informed decisions that reduce cost and deliver quality outcomes as healthcare organizations, employers and unions adapt to new realities in the fee-for-value era.