Practice Management

How to Gain Benefits and Avoid Penalties with MACRA & MIPS

By Peter J. Cass, OD

New legislation will impact how you get paid this year. Prepare for these changes, and prime your practice for continued profitability in a changing healthcare environment.

Many practitioners have heard the MACRA and MIPS acronyms, but there is still confusion about this new CMS payment model, and how it will affect our practices this year. MACRA is the Medicare Access & CHIP Reauthorization Act. It establishes a new incentive payment program called the Merit-Based Incentive-Based Payment System (MIPS), which creates a scoring system to compare the quality and cost of care given by providers.

MACRA and MIPS are an attempt to fundamentally change the way doctors get paid to deliver health care. The goal is to move away from a fee-for-service model to a model where quality and value, rather than volume, are emphasized.

>>Click HERE to Download a MACRA and MIPS FAQs and Tip Sheet>>

In my own practice, the new payment system could affect the bottom line by almost $7,000 based on my performance in the new MIPS program. If I earn a higher MIPS score than other eyecare providers, I could earn an incentive of $3,400, or if I earn a lower MIPS score than other eyecare providers, I could see my payments reduced by $3,400.

This new MIPS payment system was passed as part of MACRA, in an effort to fix the issues with the old payment system which used a Sustainable Growth Rate (SGR) formula. SGR was passed in 1997, but was flawed almost from the beginning, and has needed 17 separate Congressional fixes to prevent significant decreases in payments to Medicare physicians. MACRA is intended to permanently fix the problems with SGR by establishing a new way to pay doctors who treat Medicare patients.

Under MACRA, the base physician payment will be increased annually by 0.5 percent from 2015-2019. After that, the base physician rate will be frozen, but eligible providers will have the opportunity to receive additional payment increases through the new Merit-Based Incentive Payment System (MIPS). Conversely, providers who perform poorly will see their payments reduced.

Beginning in 2017, MIPS will sunset the three separate incentive and penalty programs you are most likely familiar with:
1.    Physician Quality Reporting System (PQRS)
2.    Electronic Health Reporting (EHR)-Meaningful Use (MU)
3.    Value-Based Modifier (VBM) Program

MIPS will replace these programs with a single incentive and penalty program (MIPS), which will assess the performance of providers in four areas:
1.    Quality (Similar to PQRS) (60% of MIPS score 2017, 50% 2018)
2.    Resource Use (not scored in 2017, 10% of MIPS score 2018)
3.    Advancing Care Information (Similar to EHR Meaningful Use) (25% of MIPS score)
4.    Clinical Practice Improvement Activities (15% of MIPS score)

In MIPS, providers will receive a composite score of 0-100 based on their performance in each of these four areas. MIPS scores will be compared to a performance threshold (established by statistical analysis of MIPS scores of similar providers) and:

•    Those exceeding the threshold will be eligible for a payment increase.
•    Those below the threshold will receive a decrease in payment.

MIPS is budget neutral, so the penalties assessed to poor performers will be used to fund the incentives for good performers. You can view your performance on the Physician Compare Site where CMS publishes some of this information.

For 2017, you will need to decide how you report Quality data and EHR data. Options include:
•    Claims-based reporting,
•    Directly through an EHR using Certified EHR Technology (CEHRT), or
•    Through a Qualified Clinical Data Registries (like AOA MORE)

Properly gathering and reporting quality and Meaningful Use data will help your practice avoid payment penalties in 2019.

Action Plan
PARTICIPATE. Providers do not necessarily need a high score to earn an incentive payment. Incentives are based on performance compared to other providers. Since many doctors are expected to ignore MIPS, doctors who choose to participate in the MIPS program will likely have a significant advantage over those who chose not to participate. This means that in the first few years of the program it will probably be relative easy to earn an incentive by simply participating, even if the efforts do not result in a high score.

GET THE RIGHT SOFTWARE. One of the most important actions you can take to prepare for MIPS is to install registry software on your EHR server. Registry software will automate much of the reporting requirements of MIPS. The automation will save you time and money through reduced staff time to comply with the regulations.

DOUBLE CHECK DOCUMENTATION. My practice is reviewing the quality measure requirements in MIPS to make sure that we are properly documenting them. We are also reviewing the EHR Meaningful Use (aka Advancing Care Information) measure under MIPS to make sure that our software is capable of properly recording those measures.

AUTOMATE REPORTING. We have signed up with the AOA MORE registry to automate reporting of quality measures.

LEVERAGE PQRS & MU PROCESSES. Practices that are familiar with, and successfully meeting, the measures of PQRS and MU can apply that knowledge to MIPS and ease the transition from one system to the next.

TRACK YOUR PROGRESS: Use an EHR or Registry, like AOA MORE, to view reports on quality measures and Meaningful Use. Registries will also allow you to compare your performance to averages.

Taking action now will help you achieve a higher MIPS score in 2017. If your score is better than the average, you could see as much as a 4 percent increase in your Medicare payments in 2019.

For more information on MIPS, visit https://qpp.cms.gov/, and feel free to e-mail me your questions.

 

 

Peter J. Cass, OD, owns Beaumont Family Eye Care in Beaumont, Texas, and he is a partner withPractice Compliance Solutions / Optometric Business Solutions. To contact: pcassod@gmail.com

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