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MIPS 2019, MIPS 2019 reporting, MIPS & MACRA, MIPS in healthcare, Quality payment program 2019

5 Key Takeaways from the Quality Payment Program by Year’s End

Before we go into the details, the Merit-based Incentive Payment System (MIPS) comes under the direct obligation of the Medicare Access and CHIP Reauthorization Act (MACRA), the law that regulates the incentive program across the US.

Eligible clinicians who have a responsibility to report MIPS 2019 include physicians, osteopathic practitioners, chiropractors, physician assistants, nurse practitioners, and registered dietitians or nutritionists among others. They have to fulfill the low-volume threshold to qualify for MIPS 2019 reporting apart from their assigned job in healthcare.

MIPS in healthcare gauges a clinician’s performance in terms of care delivery and reduced expenses. In this article, we come to an understanding of five key elements that have surfaced as a result of this program. This data correlates with the preliminary data findings released by CMS on July 11, 2019.

  1. Two Branches for Positive Payment Adjustments

The Quality Payment Program (QPP) 2019 branches out into MIPS and Advanced Alternative Payment Models (APMs). Which branch to choose is at the disposal of clinicians, clinician groups, and virtual groups. However, MIPS & MACRA go side by side making it the next famous incentive branch after the Physician Quality Reporting System (PQRS).

The system divides into four performance categories such as Quality, Promoting Interoperability (PI), Improvement Activities (IA), and Cost. Each category has certain measures that have to be reported through a MIPS Qualified Registry, CMS Web Interface, EHR, or Qualified Clinical Data Registry (QCDR). Not to forget, there is another catch to it in the form collection types which are the actual measures according to their submission systems.

  1. Participation Level Increases Each Year

Since the start of the program in 2017, the participation level has gradually increased. The program showed an increase from 95% in 2017 to 98% in 2018. And, MIPS 2019 is only going to give us more eligible clinicians participating in it. The whole program suggests progression with higher participation levels across the country.

  1. Small Practices Clinician Participation Status

According to the Centers for Medicare & Medicaid (CMS), 90 percent of clinicians from small practices engaged in MIPS 2018 which was 81 percent in 2017.

The primary flexibilities introduced in the Physician Fee Schedule rule for the 2018 performance year included an increase in Medicare patient count and Medicare Part B allowed charges which meant fewer clinicians from small practices would be eligible to report MIPS in 2018. However, they decided to report it anyway. It also goes to show that the system has adjusted itself with the practitioners’ convenience.

It was mentioned in a blog post by Seema Verma, Administrator CMS on July 11, 2019.

  1. Advanced APMs Are Not Far Behind

Alternative Payment Model (APM) participation level isn’t far behind that of MIPS. CMS reports twice an increase of participants in 2018 as compared to 2017. There were 99,076 total participants in 2017, while the number doubled to 183,306 in 2018. This sudden jump was attributed to new participation opportunities in 2018, especially through ACOs in the Medicare Shared Savings Program.

Even if we are out there to condemn this program, I can’t see any downside to these opportunities and hope they continue for clinicians.

  1. Spectacular Results So Far

The program collects incentives for the participating clinicians year after year, but the payout occurs one year after the performance year. For example, the payout for MIPS 2017 happened in 2019 in which 93 percent of the participants received positive payment adjustments.

Similarly, MIPS 2018 participants will receive a payout in 2020 which is almost here. CMS reports that 97 percent of the clinicians will be the owner of positive payment adjustments in 2020 based on their performances in 2018.

P3 Healthcare Solutions, Ontario, CA keeps an eye on what goes around as the MIPS performance period 2019 enters the final stages.

MIPS Qualified Registry, Qualified Clinical Data Registry, MIPS, QPP, QCDRs, CMS, MIPS 2019 reporting process, MIPS submission methods

MIPS Qualified Registry VS Qualified Clinical Data Registry

There are not many agencies in the US healthcare system that earns the status of MIPS qualified registry. Each of the seven MIPS submission methods has its own advantages, and eligible clinicians can choose to submit data via anyone.

However, healthcare organizations or physicians often confuse MIPS qualified registry and Qualified Clinical Data Registry (QCDR). Particularly, physicians who don’t have much knowledge about the MIPS 2019 reporting process and mechanism, find it difficult to decide the submission strategy.

P3Care being the MIPS qualified registry for three years now has the expertise and knowledge to know how things work with different submissions methods.

Here’s a quick overview of the two most confusing terms in the MIPS QPP.

A MIPS registry reports clinical data on behalf of eligible clinicians or healthcare organizations.

While QCDR is a CMS-approved entity that collects clinical data for CMS on physicians’ behalf. This entity is generally not managed by an individual. It also differs from the former submission method, as it is not restricted to certain measures for data submission.

The qualified clinical data registry is also allowed to host non-MIPS measures, which are approved by CMS.

The categories for QCDR reporting measures are as follows:

  • National Quality Forum (NQF) endorsed measures
  • Current 2019 MIPS measures
  • Measures in regional quality collaborations
  • Other measures approved by CMS
  • Measures used by boards or specialty societies
  • Clinician and group consumer assessment of healthcare providers and systems (CAHPS), measures reported by CAHPS certified vendor
  • National specialty societies administer or endorse registries/ QCDRs

Reporting Mechanisms

Depending upon the reporting type and category, physicians can submit data via any mechanism.

Either as a group, individual, or virtual group, there are four performance categories to report on, Quality, Improvement Activities (IA), Promoting Interoperability (PI), and Cost.

For the cost category, you specifically don’t need to submit data, but CMS will use administrative claims data.

Both submission methods, qualified registries for MIPS and QCDRs can report for a total of six measures and all-cause readmission measures for groups of sixteen or more.

Which Method to Choose?

Either whatever method you choose to report, the decision should not be supported by the number of available measures. Instead, it should be well thought of to score high in the final score of MIPS in healthcare.

Think of the following points before finalizing the submission method.

  • If measures are related to your practice
  • The benchmark for available measures for each submission method
  • Performance rate achievable for selected measures
  • If there are bonus points available for the selected measures
  • Information about which measures are topped out

A correct decision can make all the difference. The path to get incentives and bonuses leads to improved revenue cycle management.

Medical practices when improving the quality of healthcare services move towards progression, and MIPS QPP is a way to measure and judge the performance of how far we have come across.

Either you report via a MIPS qualified registry or any other method, the thing is to clear mind, put forward pros and cons, and then strategize to report clinical data to MIPS via the most suitable method.