2018: A Transformative Year for MIPS in Healthcare

Challenges Faced by Physicians

In 2018, the Merit-based Incentive Payment System (MIPS) encountered significant criticism from healthcare professionals. Many physicians expressed discomfort with the payment model, particularly regarding the minimum threshold required to avoid penalties. This threshold was deemed unacceptable by numerous clinicians, as it did not seem to yield improvements within the healthcare sector. Practitioners were primarily focused on avoiding negative adjustments rather than enhancing patient care.

Changes Implemented by CMS

In response to these concerns, the Centers for Medicare & Medicaid Services (CMS) revised the previous MIPS reporting rules. These changes aim to alleviate physician apprehensions while promoting the growth of the healthcare industry. Besides adjustments to performance category percentages, CMS proposed modifications to MIPS quality measure reporting. This article will explore these updates and how they can shift the focus from penalties to incentives and bonuses.

Virtual Group Participation: A Legal Advancement

Understanding Virtual Groups

One of the notable advancements in MIPS reporting guidelines is the introduction of virtual group participation, which is now officially permitted by CMS. Virtual groups can consist of solo practitioners and groups of 10 or fewer clinicians who collaborate virtually throughout the MIPS performance year. Participants in these groups are required to report against all four performance quality measures and must meet the same reporting standards as traditional MIPS groups.

Requirements for Participation

To participate as a virtual group, solo practitioners and groups must undergo an election process. This election must be completed before the performance year begins and cannot be altered once established. For instance, the election period for MIPS 2018 ran from October 11 to December 31, 2017.

Updates on Low-Patient Threshold

Threshold Adjustments

The low-patient threshold has been revised to exclude individual clinicians or groups with $90,000 or less in Part B allowed charges or fewer than 200 Part B beneficiaries. This determination is made during the performance year or prior to it.

Bonuses for Managing Complex Care

Incentives for Complexity

CMS offers a 5-point bonus to the final MIPS score based on the average Hierarchical Conditions Category (HCC) risk factor. This adjustment reflects the complexity of patients’ medical conditions, incentivizing clinicians to manage care for more complex cases effectively.

Support for Small Healthcare Practices

Benefits for Small Practices

MIPS 2018 aims to support small medical practices by providing an additional 5 points to their final MIPS score when they submit data on at least one performance category, recognizing the unique challenges they face.

Hardship Exception Application for Extreme Circumstances

Submitting Hardship Applications

Eligible clinicians who do not utilize CEHRT (Certified Electronic Health Record Technology) due to uncontrollable circumstances, such as natural disasters, can apply for a Hardship Exception. This application allows for the reweighting of the Advancing Care Information (ACA) performance category, thereby increasing the weight of remaining categories in the final MIPS score. The deadline for submitting hardship applications is December 31, 2018.

Projected Participation and Payment Adjustments

CMS Estimates for MIPS 2018

CMS anticipates that approximately 572,000 clinicians will engage in MIPS 2018 reporting. Additionally, they project that clinicians will receive around $173 million in positive payment adjustments through MIPS consulting services. This presents an opportunity for clinicians to report clinical data to CMS effectively and potentially receive greater payment incentives.

Increased Threshold for Penalty-Free Status

Raising the Bar

In its initial year, maintaining a penalty-free status required only three points. However, this threshold has now risen to at least 15 points, reflecting significant improvements in care standards and overall progress within the healthcare industry.

The Need for MIPS Consulting Services

Given the complexity of tracking these changes, consulting a MIPS-qualified registry has become essential for clinicians. P3Care is recognized as a reputable provider of MIPS consulting services, assisting healthcare professionals in navigating these evolving requirements.