2019 MIPS Final Rule: Changes the Player & The Playing Field
- January 4, 2019
New Year, New Rules
In November, 2018, CMS released the final rule in its Quality Payment Program for the Merit-based Incentive Payment System (MIPS) program. With each passing year, CMS pulls providers uphill toward ever-greater risk, with less guarantee of reward. For calendar year 2019, eligible clinicians have been added, points and percentages changed. It’s part of the Affordable Care Act that is unlikely to go away soon.
Leveling the Payment Field
The MIPS program is a net-sum game. Losers pay winners. Over time, as performance improves and costs decline the payment pot from losers also declines. Fewer poor performers, less money in the pot. Eventually the payment schedule will level off with a new standard of performance, risk and payment. The playing field may become a bit more level, but the players must adjust in the interim.
Rookies on the Sidelines
Hospitals and providers who have participated in the phase-in years of MIPS already know that gains can be made with careful tracking of the right quality measures. In 2019, a number of new clinician types have become eligible to report. Newly-eligible clinicians, especially those employed by hospitals or in large practice groups, may become a weight pulling down scores across the board, if health systems aren’t careful.
Bring Your A Game
With more than 270 quality measures, hospitals and clinicians must choose carefully. Report on measures where there is a high probability for improvement. Start tracking from January 1, because you’ll want to report your best continuous Performance Improvement and Improvement Activities for a 90-day period, and it may happen to be that Q1 will be your best improvement period. And, quality and cost are tracked for a full year. Don’t wake up in October only to realize you don’t know which measures you intended to follow.
Check your Equipment
For hospitals and high-billing providers the days of paper charts and filing cabinets of bills and lab reports are over. Or should be. But providers may still find their records are in multiple EHR files and formats that need to be sorted, explained, properly attributed, and then reported. Not every EHR is capable of that level of communication, aggregation and reporting; the sooner you know whether you need an IT intervention, the better.
4th and Goal
CMS does all the heavy lifting when it comes to assigning your cost score. They’ll use your billing data. That doesn’t mean you can’t improve your cost score. Know what you regularly bill and which procedures may be duplicative or not producing the desired outcome – think efficiency measures that reduce cost. Not every case of leg pain is a broken leg in need of x-rays or MRIs. Simple preventive measures that don’t add a large cost burden, such as flu shot or mammogram reminders, increase Improvement Activity scores. Once more, you may need an IT intervention to be certain preventive and efficiency measures are contributing to overall cost savings.
It’s all About the Fans
The MIPS program appears onerous but in fact is meant to increase care quality. At the epicenter of every measure, bill or chart notation, there is a patient. CMS wants to reduce Medicare costs, but not at the ultimate expense of your physician-patient relationship. Patient satisfaction, after all, is a MIPS measure.