As an urgent care owner, you juggle lots of priorities. You have to decide which are most important to the vitality and growth of your business. Some items on your to-do list have a clear operational or financial benefit. Those go to the top of the list. Others are simply non-negotiable responsibilities of doing business. And finally, there are things on your list that you would like to accomplish, but the benefits are unclear and not guaranteed to get you farther ahead. For many of you, submitting MIPS documentation falls in that last category, mostly because it feels complicated and time-consuming.
Don’t be discouraged. MIPS is not nearly as complex as you think. Yes, it’s changed. But it’s actually brought together three CMS initiatives into one.
Under MACRA (Medicare Access and CHIP Reauthorization Act), three programs—the PQRS (Physician Quality Reporting System), the Value Modifier Program, and the Meaningful Use Program—are streamlined into one: MIPS (Merit-based Incentive Payment System). MIPS allows Medicare physicians to be paid for providing care based on four performance categories: cost, quality, clinical practice improvement activities, and advancing care information. In addition to MIPS, MACRA gives a second option with bonus payments for participation in eligible alternative payment models (APMs).
And here’s the good news. There’s a really good chance you will earn an incentive when you participate in MIPS.
Your Medicare payments in 2019 depend on the data from the 2017 reporting year that must be submitted by March 31, 2018.
You have choices:
- Submit a full year of data in multiple quality categories, and you earn a positive MIPS payment adjustment (up to four plus percent). You also earn a CPS (Composite Performance Score) you can be proud to share with the public.
- If you submit a small amount of data (i.e. one quality category), you may avoid negative payment adjustments in 2019 and get a very low CPS of three out of 100.
- If you submit nothing, the law requires CMS to assign a CPS of zero, and you are subject to a minus four percent payment adjustment in 2019.
- If you participate in the Advanced Alternative Payment Models (APMs) path, you qualify to earn up to a five percent incentive in 2019. Some restrictions apply.
- Exemption: Clinics billing less than $30,000 in Medicare Part B or seeing fewer than 100 Medicare Part B patients are exempt.
The best way to get the maximum payment adjustment is to submit a full year of data. You have more quality measures to pick from, and the ability to get bonus points. That may sound like a lot of work, but it’s much less complicated than it appears.
Out of a total of CPS 100 points, here’s how the categories break down:
- Advancing Care Information (formerly Meaningful Use) – 25 points
- Quality (Physician Quality Reporting System – PQRS) / Value-based Payment Modifier -VBM) – 60 points
- Cost – 0 points
- Clinical Practice Improvement – 15 points
A higher CPS score could help you attract top talent on a healthcare landscape where every advantage matters. And these scores follow providers over time. Because CPS quality scores will be posted publically on the CMS website, they can help you get new patients and leverage your reputation for providing quality healthcare.
On the flip side, a low CPS can cast a longstanding shadow on future prospects. And if you score a zero, that sends a negative message about your clinic.
So the simple answer as to whether you should move your MIPS submission closer to the top of your priority list is yes. It’s good for your reputation, and it’s good for your bottom line.
And because healthcare policy wouldn’t be healthcare policy without constant change, 2018 will look a little different than 2017 when it comes to MIPS.
Here’s what you need to know now about MACRA/MIPS for 2018.
CMS’s Final Rule for MACRA 2018 includes some changes that offer increased flexibility for urgent cares and a bonus for smaller healthcare providers across the board. Despite some pushback by providers, the 2018 rule also requires that MIPS payment adjustments be made to payments for both items and services under Medicare Part B, including part B drugs, which could have a huge effect on clinicians with a high volume Part B drug practice.
The entire CMS document is more than 1,600 pages, so here are a few of the highlights:
- Small practices with 15 or fewer clinicians will get five bonus points automatically for submitting data in at least one performance category.
- That bonus increases to 10 points if the patient population served is especially complex (as defined by a combination of HCC (Hierarchical Conditions and Categories) risk scores and the number of dually eligible patients treated.
- In areas of the country affected by natural disasters such as this summer’s hurricanes, providers are not required to submit for 2017, and will not assess a penalty. They are still encouraged to submit for MIPs to qualify for the incentives.
- Solo practitioners and small groups can form a virtual group, and participate in MIPS together through that group. Get the Virtual Groups Toolkit from CMS if you want to know more about this option. December 1, 2017 is the deadline for registering as a collective entity for MIPS in 2018.
- The quality category will be measured for a full year.
- Finally, fewer clinics will be required to submit in 2018. Those with fewer than 200 Medicare Part B patients, and those whose revenue from Medicare Part B is less than $90,000 will be exempt in 2018.
This all may seem a little complicated, but it’s simpler than it seems. Your EMR provider should be able to offer you some help in submitting your MIPS documentation and offer options that make the most sense for your urgent care. It all starts with a conversation.
At DocuTAP, we’re working with a certified partner to help us facilitate submission for our clients and can help you meet the deadline and qualify for your incentive. Contact us soon get started.