Installment 2 of 10: Will MIPS Help or Hurt Your Practice?
Most practice owners aren’t thinking much about MIPS, because the CMS doesn’t release their final rule until November 2018. That’s a mistake. The program is well established, as other segments of healthcare have been participating in MIPS for years. Expecting substantial changes vs. the current approach (thinking that the CMS is going to revamp its MIPS program for outpatient rehab, which is less than 0.5% of healthcare), is not advised. Be Aware: Most of the changes that practice owners must make in preparation for MIPS have longer lead times than the 2 months available from the CMS announcement in November until New Year’s Day, when MIPS begins.
Will MIPS help or hurt your practice? The answer is directly related to when you begin preparing.
MIPS is a composite program, made of various parts that are scored in complex algorithms.
PQRS is one of the components of MIPS. Expected to be very similar to the PQRS program you worked with in 2016, submission will now be required through a certified registry.
While PQRS is not the major influence in MIPS scoring, if you want to avoid takebacks and benefit from the 7% (increasing to 9%) bonus payments, your practice must ace PQRS coding and defense. 40% of outpatient rehab practices did not fully comply with PQRS in 2016, either because of error or because they opted out. These practices are at a distinct disadvantage when MIPS begins on January 1st.
Quality is 50% of the MIPS composite score – the single largest influence. At the 10,000-foot level (we’ll take the deep dive with each topic in future installments), the “quality” that MIPS measures is patient progression and outcomes. Hence the terminology “Pay for Progression,” which is often used when describing the MIPS program.
The topic of “Quality,” will be the bane of thousands of practice owners as MIPS sets us all up to compete against each other. You will not be judged (and paid) based on whether your outcomes are good or great. You will be judged (and paid) based on how your patients’ progression compares to the patient progression in other practices.
Most practice owners downplay quality, thinking: “My patients leave here smiling, and very, very functional – My quality is superb.” “Superb” is not the benchmark. The benchmark is how your practice outcomes compare to the outcomes of other practices. YOU MUST KNOW YOUR OUTCOMES, by therapist and by body region, AND YOU MUST KNOW THE BENCHMARK AVERAGE that you’re compared against.
Again, quality is 50% of the MIPS composite score. Practice owners who aren’t paying attention to this topic today will be the ones suffering 7% to 9% takebacks, which will then be given, as bonuses, to the practice owners who were paying attention.
Advancing Care Information (ACI) requirements consist of topics such as Security Risk Analysis, Electronic Prescribing, Electronic Patient Access, Digital Summary of Care, etc. In a nutshell, this is all about interoperability, which is the ability to share data with patients and other providers.
MIPS deliberately pushes electronic transfer of medical records from concept to reality. For example, North Carolina has already notified EMR providers that in 2019, health records will be electronically submitted to NC HealthConnex, or providers will be unable to participate in Medicaid, including the state health plan (Northern Blue Cross Blue Shield State Health Plan). Your state will do the same.
It goes without saying that paper practices will not thrive in the world of MIPS. Note our video, “10 Reasons Why MIPS Will Put Paper Practices Out of Business” Link
Clinical Practice Improved Requirements are services, topics, and reporting that are required by MIPS. Again, participation is included in MIPS scoring.
And scoring will be complex. Here’s a look at one segment (the minority) of MIPS scoring: Total points for high-weight activities + total points for medium-weight activities = Total Clinical Practice Improvement Activity Points.
Total Clinic Practice Improvement Activity Points / Total possible Clinic Practice Improvement Activity Points = The Clinic Practice Improvement Activity Performance Category Score.
TAKEAWAYS, TODAY’S LIST:
Waiting until November to think about MIPS will position your practice to fail.
Right now, today:
If you are a paper practice, you need to find and install an EMR that is equipped to succeed with MIPS (see below).
If you currently use an EMR:
You need to know:
- Will your EMR enable submission of PQRS via a certified registry (required by MIPS)?
- Will your EMR support interoperability (required by MIPS)?
- Will your EMR itself be certified (required by MIPS)?
- Will your EMR provide you with detailed analyses of outcomes and progression, enabling you to ensure best-in-class progression?
If your EMR hasn’t already been discussing these topics with you, consider them (and your practice), “behind the power curve” and at risk.
Our next 8 installments will more deeply analyze the topics discussed above. Click on the “Subscribe” drop-down to receive each of them.
MIPS will punish practice owners who aren’t paying attention. We don’t want you to be one of them.