MIPS Tips from Aprima to help your practice avoid MIPS pitfalls
Don’t Let High Quality Be Your MIPS Downfall
No one ever said that qualifying for MIPS incentives would be easy. Last year CMS offered providers a bit of relief with its “Pick Your Pace” program that offered practices flexibility in reporting and complying with 2017 data and performance requirements. Still, earning a positive payment adjustment is not going to be a slam dunk for any practice – especially since it’s easy to be inadvertently tripped up by one of the program’s many less-than-intuitive nuances. Read on for MIPS tips to avoid these common snags.
Be wary of the decile
Keep in mind that providers qualify for incentive payments based on their performance when compared to peers. This means that just because a provider submits a raw score that is very high, payment is not guaranteed.
When providers submit quality measures, CMS converts them into a 10-point scoring system, or decile, based on benchmarks. Each provider’s performance score is ranked by decile as compared to measures submitted by all providers. The decile rankings thus dictate whether or not a provider qualifies for a bonus: providers with the highest average performance scores are the only ones to qualify.
For example, smoking cessation is considered an easier measure and thus widely used by many providers. On the other hand, colorectal cancer screening may be more difficult to track and used less often. Consider a provider that scores 98.5% on smoking status. While 98.5% is an outstanding score, if it is not in the top decile (as it is in the example below,) the provider might not qualify for a bonus and won’t get the highest points for that measure.
On the other hand, less widely-used CQMs may not require as high a score to qualify for a bonus. As shown in our example, a provider could score an 83 for colorectal screening, rank in decile 10, and qualify for a bonus.
When high quality is not enough
When a provider elects to report performance data through a qualified registry, the registry issues the provider a quality score. Providers should not be misled into thinking that a high score means they are performing well. For example, a registry score of 94.66% may indicate a “YES” measure for participating in MIPS. However, if the same provider is participating with our same hypothetically-constructed smoking measure, that same 94.66 earns a score in decile 7 – and not sufficient for qualifying for a positive payment adjustment. Unfortunately, there isn’t a way to know at what score or decile a practice will definitely qualify for a bonus. Achieving a bonus, or not, depends on your score relative to what other providers have submitted.
As you finalize all your measurements for 2017 reporting, keep in mind that 2018 is nearly here. You still have a few weeks to review the 2018 MACRA Final Rule, which CMS released late last month. A few notable highlights, include:
- The reporting period requirement for quality and cost measurements increases from 90 days in 2017 to one full year in 2018.
- CMS is extending numerous exemptions and exclusions, allowing about 60 percent of all clinicians who bill Medicare Pat B to skip out on MIPS. CMS predicts that 116,226 clinicians in small practices will participate in MIPS, with at least 80 percent receiving a neutral or positive payment adjustment.
- CMS proposes a bonus of 10 percentage points under the MIPS Advancing Care Information program for providers that implement a Certified 2015 Edition product.
- CMS will award providers 5 bonus points for their care of complex patients. Aprima’s chronic care management functionality in the EHR can aid providers in this.
- Providers who were affected by natural disasters during 2017 are not required to submit 2017 MIPS data, allowing them to avoid the 2019 penalty.
While regulatory tracking and reporting is never simple, the Aprima implementation and support teams are dedicated to helping practices achieve MIPS success. Please reach out to us for help along this path; we are regularly asked about MIPS tips and are ready to help.