As we race toward the start of the Merit-based Incentive Payment System (MIPS), one of two major value-based tracks defined by the Medicare Access and CHIP Reauthorization Act (MACRA), there are specific activities your organization, large or small, should be doing now to ensure you are prepared:
1.Educate your organization: How familiar are you, your executives, your clinicians, and other team members with the financial, operational, and reputational impacts of MIPS?
Without a sound understanding of the genesis and future direction of MIPS, organizations risk being left behind in this competitive program where every performance point translates into dollars. MACRA combines the existing Medicare Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Value-Based Modifier (VBM) programs into MIPS. MIPS payment adjustments will be applied two years after each performance year and will drive (for the first performance year) an estimated 18-26% difference in reimbursement between the highest and lowest performing clinicians.
2.Estimate your MIPS Composite Performance Score: Do you know how your current performance translates into a MIPS score?
Your MIPS Composite Performance Score for the first performance year is derived from four categories: Quality, formerly PQRS/VBM, is 50%; Advancing Care Information (ACI), essentially renamed from Meaningful Use, is 25%; Clinical Practice Improvement Activities (CPIA) is 15%; and Resource Use, often referred to as “Cost”, is 10%. Performance within each category is calculated differently under MIPS than it has been historically. Knowing your estimated score is key to understanding where to focus.
3.Optimize MU & PQRS/VBM Quality to maximize your MIPS Composite Performance Scores: Do you know what activities to implement now to prepare your organization for success under MIPS?
The Quality and ACI categories account for 75% of the MIPS Composite Performance Score. Understanding where your organization has opportunities for improvement within these categories, and implementing best practices to address, will establish effective processes that will carry into 2017 when every MIPS performance point will have financial and reputational repercussions.
4.Evaluate staff, resources and structure: Is your organizational structure optimized for MIPS?
Under MIPS, the four categories are input into a single score. The decision to report for MIPS as individual clinicians versus as a group of clinicians, which can greatly impact the MIPS score, must be applied equally across the Quality and ACI categories. Is your organization best structured to effectively manage these programs under a single umbrella, while also managing performance for the CPIA and Resource Use categories as well? We see organizations consolidating Meaningful Use/ACI and PQRS/Quality under a single senior leader to centrally manage the MIPS performance portfolio.
Under the PQRS/VBM Program, the vast majority of organizations avoided penalties simply by participating. However, under MIPS practically all organizations will either be assessed a penalty or receive an incentive. This competitive program is designed such that the penalties applied to low performers essentially pay for the incentives paid to high performers. Organizations that are prepared to “hit the ground running” the day the program begins are those that initiate preparations today.
About the author: Matthew is an experienced healthcare advisor who has worked with some of the largest healthcare systems in the US. At SA Ignite, he provides guidance to thousands of providers navigating value based programs. Prior to SA Ignite, Matthew held senior positions with Crowe Horwath, Accretive Health, and Accenture.