July 14th, 2017
Time is running out for physicians to form their MIPS strategy for 2017. But while many physicians have a high-level-overview understanding of MIPS, many haven’t yet determined their approach—and this puts them at risk financially.
Most eligible clinicians (ECs) are expected to take MACRA’s MIPS performance track this year, according to the CMS final rule, with the financial impact hitting physicians and clinicians in 2019 and beyond.
Because the scores will be made public, determining the right strategy for participation is critical not only to the financial health of physicians and their practices, but also their reputation. The time for action is now, while physicians and their practices are able to adjust their approach in response to the data they are seeing and better position themselves for success.
Choosing the Right Path for Participation
MIPS will adjust Medicare payments based on a composite score for three performance categories in 2017:
- Quality (60 percent of the composite score in 2017)
- Clinical Practice Improvement Activities (15 percent)
- Advancing Care Information, formerly Meaningful Use (25 percent)
A fourth MIPS performance category, Cost, will not be evaluated in 2017 and was reweighted to 0 percent.
When it comes to setting the pace for MIPS participation in 2017—the test year for participation—physicians and their practices have four options to choose from.
- Test the program by meeting requirements for minimum participation, reporting on at least one quality measure, one improvement activity or the required advancing care information measures to avoid a negative payment adjustment.
- Report on more than one quality measure, improvement activity or advancing care information measure for at least 90 days to qualify for a neutral or small, positive payment adjustment.
- Submit MIPS data for a full calendar year, potentially qualifying for a moderate positive payment adjustment and even an “exceptional performance” bonus.
- Refuse to participate—a decision that will automatically result in a negative 4 percent payment adjustment in 2019.
But the clock is ticking. The deadline to register to participate in MIPS through the CMS Web Interface and CAHPS Survey was June 30, 2017. If physicians plan to take the minimum path for participation—reporting on one quality measure for 90 days this year—they will need to start by October 2, 2017. By March 31, 2018, physicians and their practices will need to report the quality data they have collected.
First Steps Toward MIPS Success
Physicians and their practices should consider the following four strategies to achieve success under MIPS.
- Fine tune MACRA readiness related to quality. Because 60 percent of the MIPS composite score for 2017 is based on quality performance, physicians should adopt evidence-based, integrated approaches to care that reduce variation, strengthen clinical outcomes and contain costs. Also critical: enhanced discharge planning, which is proven to reduce readmissions—a major indicator of quality.
It’s important to note that most participants will report up to six quality measures, including an outcome measure, for a minimum of 90 days in 2017. Physician groups using the web interface will report 15 quality measures for a full year.
- Look for clinical practice improvement activities that support care coordination, patient engagement and health equity. For example, how can your physician practice use data to more effectively segment populations? Developing culturally appropriate interventions to improve clinical and financial outcomes also will be critical. Consider, too, ways to increase patient and family engagement with tools that support improved communication and collaboration with providers, such as mobile reminders for appointments, medication adherence, care regimens and more. Know that in 2017, most participants will attest they have completed up to four improvement activities for a minimum of 90 days. Groups with fewer than 15 participants or those in a rural or healthcare shortage area will attest they have completed up to two activities for a minimum of 90 days.
- Focus on the secure exchange of health information and the use of EHRs to support patient engagement and improved quality of care. Key action steps in 2017 include the following:
- Conduct a security risk analysis related to protection of health information, and implement security updates, as necessary, with a focus on correcting security deficiencies.
- Meet the base score for e-prescribing by enabling drug query functionality for e-prescriptions transmitted through a certified electronic health record technology (CEHRT).
- Provide patients with the ability to view their health information online, download it, and share it with a third party.
- Use the CEHRT to transition or refer patients to another physician, clinician or care setting. Create a summary of care with the CEHRT and transfer it electronically to the receiving provider.
- Examine the practice’s cost. After 2017, CMS will compare cost—Medicare costs of attributed patients—for similar care episodes and conditions across physician practices. Although resource use won’t affect MIPS scores in 2017, preparing now to be evaluated in this category in 2018 is a smart approach. Look for ways to leverage predictive analytics to avoid scheduling tests and procedures that are either unnecessary or of limited benefit.
Setting the Pace
No matter how you participate in MIPS—whether individually or as part of a group—the cost of being unprepared for the challenges ahead will cause great anxiety. As younger generations in particular place heavy emphasis on physician ratings, it is critical that a physician’s score under MIPS accurately reflects the quality of care provided. Consider partnering with an expert or seeking support from an EHR vendor in developing the right approach for 2017 and beyond.