CMS is offering you a go at your own pace alternative to full merit-based incentive payment system (MIPS) participation in 2017 — but experts warn that if you take the slowest route, you’ll wind up worse off.
CMS Acting Administrator Andy Slavitt said in a Sept. 8 blog post that providers would not need to perform complete MIPS reporting or participate as an advanced alternative payment model (APM) for 2017 and offered two alternatives:
Provide “some data.” While the proposed rule put forward penalties that would reach a maximum of 4% in 2017, under this option “as long as you submit some data to the Quality Payment Program, including data from after Jan. 1, 2017, you will avoid a negative payment adjustment,” Slavitt says.
Participate for a “reduced number of days.” The proposed reporting period is a full year from Jan. 1 to Dec. 31, but Slavitt said providers could report for an unspecified shorter period within that year and still receive “a small positive payment adjustment.”
Many providers will be tempted to ride out 2017 with the easiest “some data” choice — because the reduced days option appears to require reporting on three of the four MIPS components: quality, advancing clinical information and clinical practice improvement activities — or avoid attesting altogether, if a Part B News survey of providers when CMS delayed ICD-10, showing that many providers just stopped training, is any indication (PBN 4/14/14).
Experts say that’s a terrible idea, and if you can’t get all the way up to speed, you should at least go for the reduced days choice because of the chance of a positive payment adjustment and as practice for years to come.
0 effort equals 4% loss
If you bail on MIPS in year one, the breaks Slavitt instituted won’t make any difference — you will automatically receive a 4% pay cut, just as if the program were operating normally, says David Zetter, president of Zetter Healthcare Management Consultants in Mechanicsburg, Pa.
While it’s nice that “some data” — which probably will get a more formal description in the final rule — gets you out of the pay cut, and “the decision as to which option will be chosen will depend on the unique circumstances of each provider and practice,” Zetter reminds you that some practices that can’t do the full monty at least can get the modest bonus offered by option two.
“I have a client who had EHR [electronic health record] issues, got a hardship exception last year and is changing EHRs prior to January,” says Zetter. “Will they be prepared by Jan. 1? Probably not, so they’d probably take reduced days — also because they can possibly earn a small bonus.”
Get on the treadmill
But you should participate to the best of your ability because it’s good practice and with MIPS you’re going to need it.
MIPS is a value-neutral program — meaning that, once CMS has enough scores to create a performance threshold, the high performers will set the bar for payment adjustments and low performers will have to work harder just to keep up, notes Tom Lee, CEO of consulting firm SA Ignite in Chicago.
“Think of it like a treadmill that starts on Jan. 1, 2017,” says Lee. “You want to hop on for the first time when it’s slower, not when it’s going fast, because health care organizations are competing for a limited number of points nationally. If you hibernate and do the bare minimum, you will be forced onto a treadmill that’s going very fast.” That’s because in value payment programs, “generally the national average goes up,” says Lee.
You’ll also want to get used to processes with which you might be unfamiliar — such as tracking care partners’ performance, which can affect how you’ll be scored via hospital readmission scores on your quality resource and use reports (QRURs) (PBN 3/21/16).
Also, providers’ scores or lack thereof will become “public knowledge” via the Physician Compare website, says Michael Sherling, M.D., chief medical officer of Modernizing Medicine in Boca Raton, Fla. Health care organizations and commercial payers “will use this data to adjust compensation and even choose future care partners. It’s important to get ahead of the game to gain [an] advantage,” Sherling says.
“If you get in now, you’ll be way ahead of your peers,” says Zetter. “My guess is less than 25% of providers even know about MIPS and the details of the reporting requirements. Those who’ll make money on this will be those who educate themselves and implement sooner than later.” — Roy Edroso (firstname.lastname@example.org)