Preparing for the 2018 Final Rule Cost Category
When CMS announced the final rule for MIPS CY2018 in early November, it came with a surprise in the form of a weighted score for the Cost category. Initially, the expectation was that cost would be weighted at 0% as it had been in the 2017 transition year with three other categories equaling 100% – Quality, Improvement Activities (IA), and Advancing Care Information (ACI).
In the 2017 transition year, cost did not factor into the overall performance review for Eligible Clinicians (ECs) and it wasn’t expected to be included in 2018. But with a mandated weight of 30% for cost by reporting year 2019 (payment year 2021) and beyond,1 CMS chose to implement the 10% weight in reporting year 2018 to avoid a significant jump over a short period of time.
ECs do not need to report any data for cost; it’s calculated by CMS. Cost calculation takes into account the entire performance year as does Quality, while ACI and Improvement Activities are based on reporting 90 consecutive days. Cost is based on two measures, Medicare Spending per Beneficiary and Total per Capita Cost.
Three ways to improve your Cost Category score and increase bonus opportunities
Currently, ECs may believe they have little control over their Cost Category score as calculated by CMS. But there are things that can be done now to improve cost scores down the road.
- Understand your Quality and Resource Use Report (QRUR)
- The Quality and Resource Use Report (QRUR), produced by CMS for group practices and solo practitioners that have billed Medicare Part B fee-for-service during the reporting year, shows how payment will be adjusted based on quality and cost measures. Practitioners may request an informal review if they suspect an error. However, the deadline to do so is fast approaching. You must contact CMS and request a review by December 1.2
- Use Data to Drive Improvements
- The cost category report compares an EC’s score to national benchmarks. Use this comparison to see where improvement activities can be implemented or enhanced now to affect cost outcomes and overall MIPS score.
- Reliable Sources
- Data aggregation and analytics are key to reliable outcomes. Achieving higher overall scores can push cost ranking up in future years. Access to reliable data will help with earning a positive payment adjustment and, hopefully, the exceptional bonus threshold.
Lastly, consider MIPS’ effect on professional reputation. CMS will begin to report scores on their Physician Compare website.3 Earning a neutral or negative score compared to peers can result in patients choosing another care provider. It may also influence choices made by hospitals when hiring and in referrals.
ECs must be ready to accept the challenge from day one. The transition year was meant to help prep ECs for the future with value based care.
Raj Lakhanpal, MD, FACEP, CEO, SpectraMedix
Member, HIMSS Clinical & Business Intelligence Committee;
Member, Governance Board – MITA