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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.

CMS, QPP, MIPS, MIPS quality measures, quality payment program, healthcare organization, MIPS reporting, MIPS 2019

How MIPS Can be an Acceptable Program For Clinicians?

The argument that CMS needs to improve MIPS is a thing in the past. Now, the focus is on “how to devise ways that actually implement the change and stands true to its promise of a better healthcare system.

Let’s admit there is no standard way for any quality payment program to hit bull’s eye in its starting years. When a program is initiated and tested in a real-time environment, it gives insight on the actual performance and capability of the program; the same is the case with MIPS. Since, its first year in 2017, physicians are raising questions against its payment model.

Many leading healthcare organizations have proposed ideas that might help CMS to overcome related issues.

Reduce Un-Necessary Administrative Work

It is observed that there is a lot of administrative work associated with MIPS reporting. There is a lot of data that needs to be collected and managed to submit to CMS. One reason is the primary care and the value-based medical services that quality measures cover. This program can serve to be more physician-friendly if clinicians are not burdened with extensive administrative work.

MIPS solutions consist of elements from three major programs:

  • Physician Quality Reporting System (PQRS)
  • Value-Based Payment Modifier (VM)
  • Meaningful Use (MU)

CMS is working in this context and simplifying this quality payment program with the easy amalgamation of all elements.

However, clinicians are not satisfied and still face administrative burdens while quality reporting. Most of the physicians have reservations regarding the relevance of MIPS quality measures to the program. Quality measures have been a special concern for surgeons because they have been evaluated on patient’s immunizations. This approach is particularly un-necessary for surgeons and reflects poorly on the intention.

The past president of The American Medical Association (AMA) David O. Barde, has provided a list of suggestions in this regard.

  • Reduce the number of measures for which a physician can report.
  • Re-expand the definition of a facility in MIPS reporting to include all healthcare service providers; no matter wherever they are, such as post-acute care centers.
  • Set a 90-day performance period for all MIPS measures.
    This way, physicians will be able to invest their energies in the right direction that is, on their patients.

Rethink and Modify Promoting Interoperability (PI) category for MIPS

Promoting Interoperability (formerly known as Advancing Care Information (ACI)) performance category tests physicians’ patience the most. Via this category, CMS has tried to encourage physicians to incorporate certified usage of EHR technology.

According to some physicians, this category focuses entirely on EHR technology, instead of actual advancement in the healthcare system. However, they need to shift their focus on the actual usage of technology and to translate digital health information on the patient level. Only this way, the PI category will stand true to its name.
The reporting requirements for this quality measure should also be modified to make this category more useful for physicians.

Here’s the good news, right from this year MIPS 2019, certain changes are observed for the PI category, which is expected to improve the overall performance of this category.

If physicians strive to score high in this category, they must take measures to perform well in the following sectors.

  • E-Prescribing: Computerized generation, transmission, and filling out of medical prescription
  • Secure health information exchange
  • Giving easy access to patients to their healthcare information
  • Public health and clinical data exchange: Exchanging data between different stakeholders/healthcare organizations.

Eligible clinicians don’t need to invest a fortune to excel in specific categories. But, a little improvement can add huge points to the MIPS total.

Implement MIPS to its True Potential

MIPS has the potential to bring advancement in the healthcare industry. However, with the final rule of QPP for MIPS 2019, around 58% of the physicians are already excluded to even participate in this program. It will result in fewer payment adjustments for physicians who improved their healthcare quality.

According to the CMS, with higher reporting criteria, non-eligible physicians will have more time to improve their quality to the maximum level. Nevertheless, the question remains that the purpose of this program is to pay clinicians for their investment in medical practice, not to judge their improvement rate until it reaches a certain level.

In addition, small medical practices have fewer resources, therefore; their performance should be analyzed separately from large healthcare organizations. This will stir the air in the healthcare industry and encourage physicians to move towards valuable healthcare.

Many healthcare organizations want to target incentives and bonuses but due to the inflexibility of the program, they can’t strike on the right target. By acknowledging the resources and the improvement made by the medical practice, MIPS should recognize the efforts one made to comply with the burdensome MIPS reporting.

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