Medicare’s new Merit-Based Incentive Payment System (MIPS) promises to forever change the way that the federal health insurance program—and likely commercial health plans that follow—pays specialty practices for the care they provide to beneficiaries. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 created the Quality Payment Program (QPP) of which MIPS is a part.
Despite the magnitude of the shift in reimbursement from fee-for-service payments to value-based payments based on specific performance measures, most specialty practices are still making the necessary operational changes to successfully comply with the new payment model. For example, only 8 percent of 1,000 practicing physicians recently surveyed by the described themselves as being “deeply knowledgeable” about MACRA and the QPP. Some 51 percent described themselves as being “somewhat knowledgeable” about the new payment system.
The AMA released the survey results at the end of June, which marked the end of the first six months of MIPS’ initial transition year that started on January 1st. That means specialty practices have six months left to document even a minimal amount of performance data to avoid a payment penalty in 2019.
With the days counting down, Web2pro Specialty Health prepared a mid-year checklist for specialty practices to measure their progress and provide a blueprint to follow for the final six months of 2017. The 10 must-do items on the checklist are:
1. Determine clinician eligibility and consider if you will report as a group or as individuals. Clinicians need to participate in Merit-Based Incentive Payment System (MIPS) if they bill Medicare more than $30,000 a year and provide care for more than 100 Medicare patients a year. Clinicians can also use the from the Centers for Medicare & Medicaid Services (CMS) to determine eligibility. Eligible clinicians can choose to report as a group or as individuals. Your practice does not need to decide now, rather, at the end of the year, analyze which option yields the best results and report accordingly.
2. Pick your pace. By mid-2017, decide which of the your practice will work towards and set goals for 2017. Do you want to be among the top performers or simply avoid a penalty?
3. Train staff. Your clinicians and staff should receive MIPS education and understand the role they play in helping the practice accomplish its goals.
4. Choose your quality measures. We recommend choosing eight measures and reporting on the best six. The sooner you decide which measures you will report on, the sooner you can begin monitoring performance and making improvements to achieve the highest possible score.
5. Identify and implement improvement activities. Practices with less than 15 clinicians need to earn at least 20 points and those with 15 or more need to earn at least 40 points by completing their choice of weighted activities. You can also earn 10 Advancing Care Information bonus points by choosing a qualified Improvement Activity. Consider selecting activities that will improve your MIPS composite score in other areas. Improvement Activities need to be in place for 90 consecutive days.
6. Prepare for the Security Risk Assessment. Start by accessing . Plan to have this completed in the fall, so you can complete your Corrective Action Plan during the last quarter of the year.
7. Review 2016 Meaningful Use (MU), Physician Quality Reporting System (PQRS) and Quality and Resource Use Reports (QRUR). Use your 2016 MU and PQRS results to benchmark where you are today versus last year, identify areas for improvement and implement changes. If you have not in the past, now is a good time to get familiar with how to retrieve and interpret these types of reports from CMS.
8. Determine how you’re going to analyze and report on your data. By now, you should have a full understanding of how your EHR vendor will support your MIPS participation. The next step is to determine and receive training on how you will analyze performance and report on data at the end of the year.
9. For Oncology Care Model (OCM) practices, focus on Advancing CareInformation. OCM participants will need to complete a MIPS Security Risk Assessment, which is one of the Advancing Care Information base score measures. Remember, any new clinicians that joined your practice after April 3 and are not on your OCM practitioner list must participate fully in MIPS in 2017.
10. Start implementing a set of standard operating procedures. Documented processes create consistency across the practice and between clinicians to ensure you will meet your 2017 MIPS goal.
Specialty practices that pursue and accomplish the 10 items on the mid-year checklist by the end of 2017 will position themselves for success in 2018, when all eligible providers will be required to collect and report a full year of data to CMS.Related: Read more about Web2pro’s MIPS solutions for specialty practices