Preparing for MIPS – What clinicians can do now

The election of a candidate whose mantra regarding the Accountable Care Act (aka Obamacare) was “Repeal and replace!” and whose choice for Secretary of Health and Human Services has been a boisterous opponent of the same  After a Presidential campaign that did not focus on many healthcare policy issues beyond the Affordable Care Act (ACA), many clinicians and healthcare administrators are wondering what the future holds for the Medicare and CHIP Reauthorization Act (MACRA).  Indications are that while there are many components of ACA  the Trump Administration will work to repeal, MACRA is a completely separate law that isn’t likely to be included in those deliberations.    MACRA enjoyed both bipartisan and bicameral support, passing with 91 percent support in the House and 92 percent in the Senate,and House of Representatives Budget Committee Chairman Tom  Price (R-GA)—the Secretary-Designate of the Department of Health and Human Services—was among those who voted for it. 

Under the MACRA/Quality Payment Program (QPP) Final Rule, the majority of providers will have some time to prepare for the changes introduced by MACRA.  CMS estimates fewer than 25 percent of eligible clinicians will be eligible to participate under an Advanced Alternative Payment Model (APM); all others will subject to the Merit-Based Incentive Payment System (MIPS).  MIPS eligible clinicians will have the option of participating or not in the 2017 reporting year; however, effective January 1, 2018, all eligible clinicians must participate.

From the CMS QPP website.

Your first step is determining if you are an eligible clinician.

  • Is this your first year participating in Medicare Part B?  If so, you are exempt from MIPS during this first reporting period.
  • Do you care for at least 100 Medicare Part B patients and bill at least $30,000 annually for Medicare Part B services?  If your answer to either of these questions is no, you are exempt from MIPS.

Neither of these bullets apply?  Consider the following:

  • How well do you know your population?  Do you know which of your Medicare Part B patients are most likely to require medical treatment throughout the year?  Do you have systems and processes in place for monitoring these patients and intervening at the earliest point to ensure they receive the most effective care in the most efficient way in the most appropriate setting? 
  • Do you know how your practice patterns compare with those of your peers within the same organization or community?  If not, do you have access to a specialty organization or commercial carrier that might be able to provide you with this information?
  • Are you able to track and report on the metrics required under MIPS?
  • Do you have on-going process-improvement processes in place?

The more of these questions you are able to answer in the affirmative, the better prepared you are for MIPS. It is important to note that you do not have to do all of these things on your own.  Help may be available through your medical or specialty society or local Quality Improvement Organization (QIO).  CMS provides a number of resources through its Quality Payment Program (QPP) website, and the HIMSS MACRA Resource Center contains a variety of fact sheets and resources as well.  In addition, HIMSS is offering a series of MACRA webinars.  Recordings of past webinars and information about upcoming webinars can be found on the MACRA Resource Center web page.

These are challenging times for our healthcare delivery system.  Taking time to be sure you fully understand your individual situation and respond accordingly will be critical to containing costs and improving your opportunities for success.  

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