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You have your final MIPS score and feedback. Now what?


Don’t make MIPS a guessing game. Create and implement quality improvement strategies for the 2018 MIPS program and beyond.

In 2017, 91 percent of eligible physicians and other clinicians submitted for Medicare reimbursement under the Merit-based Incentive Payment System (MIPS) for the first time. You may be one of them unless you don’t have Medicare patients or are participating in an advanced alternative payment model (APM). And on July 1, you might have immediately looked up your final MIPS performance score and feedback, let out a sigh of relief and gone about your day.

For other practices, this wasn’t necessarily the scenario. Best case: They may have needed a reminder about how to review their final results by logging into the same CMS Quality Payment Program website with the enterprise identity management (EIDM) credentials used to submit 2017 performance data. Worst case: When they saw their data, the news might not have been as good as expected. A number of factors could have impacted the feedback since the April preliminary score, so many providers may not have let out a sigh of relief, but one of frustration.

Whether you’re thrilled or dismayed with your final result, there’s still time to maximize your quality improvement (QI) efforts and improve your 2018 MIPS scores for Medicare payments you’ll receive in 2020.

The impact by then could be considerable to your financial outlook. As a reminder, your 2017 MIPS score determines whether you receive up to a 4 percent positive or negative adjustment to your 2019 baseline rates. In coming years, that incentive/disincentive grows more rapidly: +/- 5 percent for 2018 data impacting your 2020 revenues, jumping to +/- 7 percent for 2019 data/2021 reimbursement, and a whopping +/- 9 percent for 2020 data applied to you in 2022 and beyond.

For 2020 alone, that means a practice earning $1 million in Medicare reimbursements could earn up to $50,000 more. A similar practice could also lose that amount of reimbursement. The number jumps to $70,000 in 2021 and $90,000 in 2022. Depending on your Medicare volume, that financial effect could determine whether your practice succeeds or fails in just a few years.

Avoiding a penalty vs. building a foundation

Though MIPS was designed to make things simpler for providers by bringing together QI and cost containment programs, it has made data gathering and reporting more complex and more impactful to your bottom line. This can be especially challenging when you’re already up to your stethoscope serving an expanding aging population with multiple chronic conditions.

Considering the challenges as well as opportunities with this program, some practices have chosen to take a direct approach to MIPS and simply meet the baseline to avoid a penalty. Others have found MIPS to be an exceptional foundation for an overall QI program that can affect patients of all ages, and they’re happy not to leave earned money on the table. These practices keep the Triple Aim (quality, cost and patient experience) in mind as they develop a plan for the 2018 MIPS submission process.

As you review your final MIPS score and feedback, ask yourself: Are you trying to just avoid the penalty, or do you want to build a foundation for your practice’s success? 

Exceptional performance in MIPS and long-term quality strategy

Ramping up your MIPS-related initiatives should also have a major impact on your patients’ health. For example, a Southeast-based academic medical center with nearly 1,000 multi-specialty providers embraced MIPS as part of its focus on the Triple Aim and a larger quality strategy to become an accountable care organization (ACO). Through the MIPS submission process, the team wanted to develop a long-term plan that would continue to improve how they cared for patients and how they were perceived as a quality care provider. This includes determining which core competencies to focus their efforts on, how they capture data and translate quality codes, and how often they could capture this necessary data for measuring and reporting results.

The health system’s EHR didn’t provide all the quality codes needed to meet submission goals, so staff worked with a Qualified Clinical Data Registry (QCDR) partner to uncover and close coding gaps. This included multiple data pulls to identify data elements for numerator credit and denominator exclusions, resulting in better reporting of QI activities and timely discovery of improvement opportunities.

In addition, the health system used a continuous quality improvement methodology to consistently monitor and improve performance status of its target core competencies throughout the performance year and ensure the data and quality codes were accurate. Consequently, the health system achieved an exceptional performance score and incentive payments for its performance optimization, reporting at both the group and individual levels for 585 of its physicians and 30-plus specialties.

The health system showed double- and triple-digit improvements in everything, including the use of aspirin for in vitro diagnostic device, flu vaccinations, tobacco use screening and cessation, breast cancer screenings, controlling high blood pressure, and diabetic attention for nephropathy.

Now, the health system is building on its initial quality successes by also focusing on cost of care, which comprises 10 percent of the 2018 MIPS score.

Tips for maximizing performance and reimbursement as stakes grow

By approaching the MIPS submission as part of your overall quality improvement strategy, you’ll do more than just avoid financial penalties - you’ll see care improvements in the long term.

Here are five ways you can implement change now to positively impact your 2018 scores:

  • Verify your 2018 eligibility. In this case, size does matter. CMS has updated the 2018 eligibility calculations and expanded the low volume threshold. Even with these updates, there is still time to submit, but the process needs to start sooner rather than later.
  • Determine your true core competencies to target which data to mine and the best quality measures to optimize and report on.
  • Take a deep dive into your EHR/Practice Management systems to see whether data is being appropriately captured. Keep in mind that some data in your EHR may not show the correct quality data codes you need for your MIPS submission. Some may not be in your systems at all or hidden in other codified or textual data. Aggregate and normalize all of the data so you can determine your core competencies and get maximum credit for the care you’re delivering.
  • Develop provider and patient engagement plans to maximize adherence and outcomes. Use the MIPS submission process to inspire some healthy competition. If you have the ability to view and monitor data and quality code input, let providers see how they stack up against their co-workers. Perform outreach to patients to drive wellness activities that close care gaps and improve health and MIPS scores.
  • Choose a QCDR partner that’s experienced in helping perform numbers 1-4-and more. In particular, consider a QCDR partner that goes beyond MIPS reporting to offer a continuous quality improvement solution.

Improving MIPS, improving quality

Avoiding a MIPS penalty is important, but earning an incentive increase is even better. After you review your final MIPS score and feedback, decide whether you are going to check the boxes to avoid the penalty or approach MIPS as the basis for your long-term commitment to improve care quality, cost-effectiveness, and satisfaction, not only for your Medicare patients but for your entire patient population.

With these five steps, you can make a significant difference in your operations and fulfill your mission to improve the health of your entire community.

Amy Amick is CEO of SPH Analytics, a CMS-approved Quality Clinical Data Registry (QCDR) and Qualified Registry ranked No. 1 for 2017 by Black Book in MACRA & MIPS Value-Based Care.

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