The Centers for Medicare & Medicaid Services estimates that more than 90 percent of eligible clinicians will be in the Merit-based Incentive Payment System in 2017 vs. the Advanced Alternative Payment System. To avoid MIPS penalties or to earn bonuses, hospitals and physicians might start with these steps:
Recognize the financial impact
MIPS penalties and bonuses start at 4 percent, growing to 9 percent in 2022. Each payment year, CMS also will divvy up $500 million among exceptionally performing clinicians. This adds up to an 18 to 28 percent payment swing between the best- and worst-paid clinicians in 2022, says Joe Damore, vice president of population health management at Premier Inc. “The economic risk is going to flow to hospitals and health systems. Slightly more than half of physicians are employed, and the majority are employed by hospitals.”
“The first task is to provide information [to clinicians] and make it ubiquitous,” said Judith Melin, M.D., chief medical services officer, Lahey Clinic, during an American Hospital Association video series available at www.aha.org/MACRA. “People learn in different ways … and have different needs at different times.” Melin suggests providing a glossary of Quality Payment Program terms, presenting information in different formats such as webinars, graphics and text, and listing links to precise information. She also recommends a push-pull strategy, which she describes as pushing out information via educational sessions in addition to posting materials so clinicians can pull specifics as needed.
Assess current performance
In 2017, eligible clinicians will be assessed in three of the four MIPS categories: quality, improvement activities and advancing health information. A logical step before choosing the metrics and activities to report is to evaluate current performance and progress. For quality, physicians who participate in the Physician Quality Reporting System can turn to Quality Resource Use Reports, or QRUR, to see how their performance compares with that of peers. “If I were a hospital CEO, I’d want to know, ‘How are my physicians doing on quality and other metrics?’ ” Damore says. “Then I’d want to know, ‘What do we have to fix? In what specialty areas do we need to improve performance?’ ”
As providers select QPP metrics and activities to focus on, they should keep other reporting activities in mind. For example, QPP metrics might also be used in commercial pay-for-performance contracts. “Try to get these things integrated so that there’s one way that you’re doing these different veins of your business,” says Austin Weaver, senior director of consulting at the Advisory Board.
CMS has deemed 2017 a MIPS transition year to give providers time to get used to the new reporting requirements. “One of the key questions is, ‘How ready are you to start reporting data and how much data are you equipped to report?' ” says the AHA’s Akin Demehin, senior associate director of policy. At a minimum, Demehin recommends submitting some data, such as one quality measure, to avoid a penalty in 2019. Providers that can report 90 days of data may earn a small bonus, and a full year’s worth of data may bring a moderate bonus.
Decide on reporting mechanisms
CMS provides a variety of ways for providers to submit QPP data, including via electronic health records or qualified clinical registries. “If you’re participating in PQRS, it may be useful to assess how you're reporting data under that, whether it’s working well and whether you might want to move to a different reporting mechanism,” Demehin says. “It’s situation-dependent. Some may find it easier to use a registry than an EHR, for example.”
Report as individuals or a group
Under MIPS, physicians can report as individual clinicians or as part of a group practice. “The determination of what is best depends on the specific situation in which a hospital and its clinicians find themselves,” Demehin says.
Establish clear roles
Melin stresses the importance of determining who is going to do what regarding QPP compliance. Clarity around roles will ensure that “physicians can focus on the piece that we are most expert at and be confident that experts in other areas are going to be addressing other key and important aspects,” she says.
Prepare for 2018 and beyond
Beginning in 2018, CMS will start assessing a provider’s costs as part of MIPS. Evan Benjamin, M.D., chief quality officer at Baystate Health, gives this advice for providers in the early stages of evaluating and reducing costs: “People believe that they need to make huge investments in data and analytics right away. I would say that is necessary, but it’s not the first [thing] you need to do.” He advises focusing on creating a physician-hospital network that engages clinicians in improvement activities. Then he recommends targeting decreasing variation in practice and referral patterns. “Yes, you will need data to get started,” Benjamin says. “But you can get very rudimentary claims data without spending a fortune. Then you can get more sophisticated as you go.”