Wednesday, 23 November 2016 03:45

Ready, Set, MIPS! – Pace Yourself for Participation

Written by Stephanie Doran, RHIA


The clinician community has faced the task of maintaining adherence to the incrementally implemented and distinct Center for Medicare & Medicaid Services (CMS) quality reporting program requirements for close to a decade now. As the collective provisions of the Medicare Access and CHIP Reauthorization Act (MACRA) streamline to form the Quality Payment Program (QPP), the idea of trying to take off participating full speed in a marathon seemed nearly impossible.

Thankfully, CMS has responded in its final rule with an alternative strategy within the first year of reporting for eligible clinicians that will allow them to avoid negative payment adjustments by reducing the obstacles that would make it more difficult for to prove that they are practicing good care. In maintaining forward progression of the value-based care model, the Merit-Based Payment System (MIPS) path reinstates “go at your own pace” participation for performance-year 2017. The ultimate goal is to place patient outcomes at the foreground of a program designed to help clinicians care for patients smarter and report quality care better. Clinicians are now faced with the task of identifying which course will guide them to future success.

Determining Pathways for Success

As the details of MACRA unfolded, many clinicians grew wary of the impact it would likely place on their time and money. Beginning in 2017, MACRA will affect those clinicians who see more than 100 Medicare patients or accrue more than $30,000 in Medicare Part-B allowed charges annually. This increased reimbursement rate for inclusion means that MACRA will still apply to clinician practices both large and fairly small. Concerned feedback on the proposed regulations made CMS well aware that the clinician community was less than fully supportive of the consolidation of the standalone quality reporting programs on such a compressed and aggressive implementation schedule. In fact, with so many operational factors to adjust, the prospects of QPP loomed as a daunting task for any clinician eligible for participation – and, more importantly, there was the question of how they could best prepare themselves to perform well enough to avoid hurting their practice. Truth be told, eligible clinicians of varying practice sizes and their diverse methods of delivery of care are two important factors that will largely contribute to careful planning strategies.

In recognition of this, CMS has made the 2017 performance year a transition period by developing essential flexibility within the final rule, offering three distinct courses to report under MIPS. If clinicians are geared up, they can begin collecting performance data as early as Jan. 1, 2017, or they can plan to get in motion at any time between Jan. 1 and Oct. 2, 2017, whereby the latteris the latest date on which to begin collecting data. Figure 1 merely serves as a reminder for clinicians to mark these important dates on their calendars. If following the MIPS path, setting the pace of participation is crucial to building the structure for successful participation in future years. Clinicians must then ask themselves when preparing for participation, which option will support their journey through MIPS? 

Option One: Test Participation

If clinicians are not quite sure they can devote the proper resources to their new quality reporting routine, the first pace allows clinicians the option to report “some data.” Under this option, as long as clinicians submit data on the bare minimum (one quality measure, one improvement activity, or the required measures of the Advancing Care Information category), starting on or after Jan. 1, 2017, they will not receive a negative payment adjustment in 2019. This novice approach to the program is intended not for clinicians to worry about how many quality elements they are reporting, but rather focusing on engaging in further education about the newest requirements and preparing the necessary modifications required to accommodate full reporting under MIPS. 

Option Two: Partially Participation

The second option is to report performance data for less than the full year for those clinicians who that are somewhat prepared, but may not be advanced enough to report the comprehensive requirements immediately. Through this option, clinicians must report for a full 90-day period (more than one quality measure, more than one improvement activity, or more than the required measures under the Advancing Care Information category) beginning any time between Jan. 1 and Oct. 2, 2017. Clinicians who choose this option will avoid a negative payment adjustment and position themselves on track to receive a neutral or bonus payment in 2019. This approach offers clinicians the ability to cover a bit more ground in the inception of the MIPS program, aligning themselves to undergo an above-average experience.

Option Three: Full Participation

If a practice is all ready to hit the ground running, ideally they could opt to   participate in reporting performance data for the for a minimum of 90 days, all the way up to a full year, beginning Jan. 1 through Dec. 31, 2017. Although slightly more challenging, as it requires reporting on all of the required measures, the third option of participation places clinician practices in proper position to critique all aspects that affect their performance. Clinicians can most certainly anticipate avoiding the negative payment adjustment, alongside with maximizing their opportunity for a positive adjustment. Furthermore, full participation, wherein performance submissions evoke exceptional performers, mandates eligibility for an additional positive adjustment for each year of the first six years of the program.

Alternatively, eligible clinicians should be aware that their choice not to report a single measure or activity will automatically result in receiving the full negative 4-percent adjustment. Figure 2 displays the three available participation options for those seeking to avoid a negative payment adjustment, according to the budget neutral component of MIPS. Clinicians choosing this option have the ability to get themselves into an adaptable routine rather than scrambling to find a makeshift solution.

Is There a Cost to Slowing Down?

Let’s get down to the results. Clinicians can gather a sense of the pace they can sustain from start to finish given the unique circumstances of their practices’ resources. Experts are advocating for clinicians to pick up speed early in the program and learn the rhythm of MIPS as they go, but clinicians must determine their pace based on their preparation. A large part of the clinician community has been accustomed to the collection and reporting of quality performance data to CMS for some time now, but there are still many with little to no experience, given such instances where the programs may not have formerly applied. In any case, not all practices are at a similar point in terms of their reporting capabilities, and navigating the route to MIPS will present a challenge at any pace in the program’s initial participation period

The demands of any pace will require a significant amount of clinical and administrative resources to implement, with each year impacting the expanding and evolving requirements of MIPS. With that being said, there is still no time to waste determining which starting pace to which your practice should be assigned. All practices must remain aware, seek continuous education and engagement, and make the most of their time by aligning themselves today to report to best of their ability. MIPS shares an anticipated opportunistic goal for clinicians to ultimately earn more by focusing on quality patient care, and regardless of which option clinicians choose to tackle to accommodate reporting, Jan. 1 marks the opening gun – at that point, they’re off!

About the Author

Stephanie Doran is a health information management (HIM) consultant and project manager for HealthAdvanta, a health information and technology company. She is a graduate of Temple University, where she earned a bachelor’s degree in health information management and was honored with the Health Information Management Professional Excellence Award for her distinguished development and achievement.

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Last modified on Wednesday, 23 November 2016 04:57