MIPS | MERIT-BASED INCENTIVE PAYMENT SYSTEM
The Practice of Medicine has always been both art and science. Over the last several years there has been a serious effort to try to make it a process, to standardize and measure it. Now along comes MIPS.
WHAT IS MIPS?
The Medicare Access CHIP Reauthorization Act of 2015 (MACRA) repealed the Medicare Part B Sustainable Growth Rate (SGR) reimbursement formula and has instituted a new reimbursement system called the Quality Payment Program (QPP). The QPP consists of 2 major tools, the Merit-Based Incentive Payment System (MIPS), and the Advanced Alternative Payment Models (APMs). We will focus on MIPS and how it affects your practice.
The new math is that the former evaluation and payment plans, Medicare Meaningful Use (MU) + Physician Quality Reporting System (PQRS) + Value Based Modifier = MIPS. The payments will apply back two years to the previous reporting period, i.e. you will receive payments in 2019 for the 2017 performance.
WHO DOES MIPS APPLY TO?
MIPS will initially apply to Doctors, Dentists, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists in 2017-2018. Starting in 2019 it will also apply to physical and occupational therapists, speech/language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, and dietitians and nutritionists.
WHY SHOULD YOU CARE?
Why is it important to play along with the MIPS requirements? Because 1) it’s mandatory, and 2) if you do nothing, your reimbursements will not stay the same, they will actually decrease. Further, the deduction is not static, but cumulative, so the increase or decrease will compound. In 2017 your reimbursements will be + or – 4% based on your compliance with MIPS. In 2018, it’s + or – 5%. In 2019 it’s + or – 7%. In 2020 it’s + or – 9%. With bonuses points built in the swing can be up to 37% of your reimbursements. 37%!
The goal of many of these laws, rules, regulations, and programs such as MIPS, meaningful use, HIPAA, and the like is to improve patient care and access to information. The methodology of is an attempt to gather information and use it to try to prevent things like re-admissions and recurrent conditions. MIPS is essentially a scoring system for the evaluation of patient care and satisfaction.
There are 4 categories for evaluation: Quality, weighted as 50-60% of your score; Advancing Care Information, weighted as 25%; Clinical Improvement Activities, weighted as 15%; and Resource Use, which will grow in weighted value over the years.
Quality is just what it sounds like. The question is, how do you measure it?
Advancing Care Information contains patient information and interactions.
Clinical Improvement Activities reporting will focus on what your practice is doing with the information generated by surveys to improve patient care, satisfaction, and outcomes.
Resource Use, is actually cost, i.e. how much are your patients using health care resources or, how much are they costing the system.
HOW READY ARE YOU?
Is your practice a Leader, a Follower, or a Wanderer? If you’re a Leader, then you are probably already planning and getting ready to implement actions to capture all of the increases every year. If you are a Follower, you likely know that you need to do something, but may not know what or how to do it. A Wanderer is going to need help not just to capture the revenue increases, but to avoid the penalties.
Of these 4 categories, Patient-Centered surveys like those from Testimonial Tree will have the greatest impact on the ones you have the most control over, the first three. They also happen to be the ones that carry the greatest weight. Your ability to influence Resource Use really comes from what you do with the first three.
How can you use surveys to increase your reimbursements, revenues, and profits? You can come closest to measuring Quality in MIPS by utilizing patient Testimonial Tree surveys that detail outcomes and satisfaction. The results will even give you the ability to modify the surveys to get the most accurate reporting.
Surveys are critical to Advancing Care Information, as they are the singular methodology for gathering that information.
You will use the results to implement the Clinical Performance Improvement Activities, and then follow up to show that your activities have been effective.
Using that type of multi-lateral approach will lead to less Resource Use by your patients, which will mean a higher score, and higher reimbursements.
Why this type of survey/information gathering? Because it is real-time. If you use the “default” method, CG-CAHPS, your will not know your results for 180 days! Then you have to evaluate and implement the changes, then try to discover whether you’ve made any improvements, all within the next 180 days, but you can’t even meet that deadline because the results are not available for 180 days. You will forever be behind the curve.
The merits and likelihood of success of quantifying and systematizing medicine are unknown. What we do know is that we can use these tools to meet these mandatory requirements. Since you’re being forced to participate, you should use the best tools at your disposal.
You can increase your reimbursements and not just avoid a decrease by utilizing the Patient-Centered surveys that Testimonial Tree has developed to 1) gather information about patient perceptions of the quality of care; 2) evaluate the patient interactions; and, 3) use that information not only in reporting to CMS, but in creating plans for improvement. If you do that properly, in all likelihood, you will gain as much reimbursement increase as possible, including bonus points, and even decrease the costs associated with your patients’ use of the system.
For more information, visit CMS.COM
DISCLAIMER. This information is presented as a general matter and is based on statements made and information provided by the Centers for Medicare and Medicaid (CMS) as of December, 2016. It is not intended as legal advice, or to apply to any particular or specific situation or set of facts.