Another new wrinkle the MIPS program will bring is publication of physicians' individual "Final Score" and the consequences that flow from that in the industry. "We are trying to educate members that their final score does follow them," Mullins says. "That MIPS score is going to affect your payments in 2019, even if you change jobs."
As this data becomes available on Physician Compare, it has the potential to impact physician practices in a number of different ways, Abrams says. Created in 2010, Physician Compare offers online performance scores to help consumers make informed decisions and to encourage clinicians to provide the best care.
That information could and is intended to influence consumer choice of which physician to go to, so it could influence volume, he adds. "It might become a consideration in choosing which physicians are included in payer networks and could even influence the volume of referrals by hospitals and other individual physicians."
Another unintended consequence that healthcare analysts will have an eye on is industry consolidation. Physicians sell their practices to hospitals in part because that means there is somebody on the payroll to worry about compliance. "All the mechanics of compiling, aggregating and filing the data and making the difficult choices every year in terms of what metrics to choose to characterize your practice makes being part of a larger entity more attractive," Abrams says.
On the other hand, AAFP's Mullins notes that CMS does realize that MIPS is more difficult for small practices, and the 2018 final rule offers 5-point bonus points for practices with 15 or fewer clinicians.
Some small provider groups also may opt for MIPS "virtual group" reporting. The idea is that physicians in smaller practices who may not have enough patients to get statistically valid quality measurement results would join together to get statistically valid results on more measures. Participants in virtual groups, however, would have to decide by Dec. 31, 2017, less than two months after the final rule was released. Perhaps that is why CMS estimated that nationwide only 16 virtual groups made up of 765 MIPS-eligible physicians would participate in 2018. "If you are a small practice and want to join another small practice or even a little larger practice, how do you make that happen?" asked Abrams. "Put an ad in the paper? And how can you be assured that if there is one bad actor in the group, you don't all pay a penalty for it? There are a lot of uncertainties involved in that process."
As the final rule for 2018 approached, Phoenix Heart's Kyle Matthews was hoping that CMS would stick with a 90-day reporting period. But like many others, he was disappointed when the final rule called for a full-year reporting period for Quality and Cost measures. "It is just impossible for a rule to come out Nov. 1 and within 60 days change the behavior of 14 doctors and 75 staff members and to work with the EHR vendor to do a full-year reporting period," he says. "If they want full-year reporting, they need to release a rule on Nov. 1, 2017, that is effective for Jan. 1, 2019. You need time to do this."