Should I just do the minimum? 3 Reasons clinicians and groups are going all out in MIPS this year

Much to the relief of many physicians, practice managers, and quality teams, the Centers for Medicare & Medicaid Services (CMS) drastically reduced the requirements for avoiding the negative payment adjustment in the Merit-Based Incentive Payment System (MIPS) in 2017. The final rule introduced a 2017 transition year, which means that there is a very low bar for avoiding penalties in the MIPS program this year. Given this, why are many clinicians and groups participating fully in the program this year?

In this article, we’ll break down the three main reasons below:

  • Your scores will be public
  • You can access the $500 million bonus pool
  • You can set up for future success

But first…

What is the bare minimum?

CMS has defined minimum requirements for avoiding the negative MIPS payment adjustment in 2017, which they call the “test pace.” Clinicians and groups that do any one of the following will avoid a negative payment adjustment:

  • Report any data for one Quality measure
  • Attest to performing one Improvement Activity
  • Report a “yes” or a 1 in the numerator for all Advancing Care Information base measures

Given that in past years, many providers have had to report 9 PQRS measures and separately report for Meaningful Use, this test pace is a drastic reduction in requirements. So why would providers consider meeting additional requirements in 2017?

Advantages of full participation

To seek a top score in MIPS in 2017, clinicians and groups must meet the requirements for all three categories–Quality, Advancing Care information, and Improvement Activities–which is a lot more than one measure.

But the upside can be well worth the effort. Here are the advantages of aiming high in 2017:

1. Your scores will be public

One factor driving eligible clinicians and groups to maximize participation in 2017 is that significantly more performance information will be publicly reported this year versus previous years. Prior to this year, Physician Compare has been the website CMS used to publicly report the following performance:

  • 14 group practice level measures collected through the Web Interface for groups of 25 or more EPs participating in 2014 under the PQRS and for ACOs participating in the Shared Savings Program or Pioneer ACO program
  • Six individual level measures collected through claims for individual EPs participating in 2014 under the PQRS

For performance in 2017, that reporting will expand significantly. MACRA requires that public reporting on Physician Compare expand, making available identifiable individual eligible clinician and group performance information, including:

  • The MIPS eligible clinician’s final score;
  • The MIPS eligible clinician’s performance under each MIPS performance category (Quality, Cost, Improvement Activities, and Advancing Care Information);
  • Names of eligible clinicians in Advanced APMs and, to the extent feasible, the names of such Advanced APMs and the performance of such models; and
  • Aggregate information on the MIPS, posted periodically, including the range of final scores for all MIPS eligible clinicians and the range of the performance of all MIPS eligible clinician’s for each performance category.

This information will be published across submission mechanisms. The data will be available in a downloadable database, and a subset of the information will also be available in clinician and group profiles on the Physician Compare website. The information on the website will be included based on consumer testing that CMS will carry out to see what information is most helpful to users.

2. You can access the $500 million bonus pool

Another reason providers and groups are aiming high in 2017 is that it may be the easiest year to be a top performer.

In each year of the program, providers have access to a $500 million bonus pool for exceptional performers. The annual point threshold for accessing this pool will be set by CMS, and in 2017 the threshold for exceptional performance has been set at 70 points out of 100 possible points in the Composite Performance Score. Though thresholds for performance bonuses in future years have not yet been set, it is possible that this threshold will increase as the general provider population gets better at participating in MIPS.

3. If you don’t set up for success this year, you will have to soon

There is general consensus across the healthcare and policy communities that MACRA is here to stay under the current administration. Therefore, many eligible clinicians and groups are choosing to use 2017 to set up for success, recognizing that this is a grace period when mistakes are okay–but knowing that this grace period will likely end soon.

Participating minimally in MIPS this year is, in many ways, kicking the can down the road. Rather than designing a system for minimal participation this year and then going back to the drawing board next year to figure out how to achieve full participation, many forward-thinking clinicians and groups are using 2017 to get working systems in place that will help them be successful in the long haul.

In addition, Medicare has made it clear that they will increasingly emphasize participation in value-based payment models, and commercial payers are following suit. Performance-based payment programs are likely to only increase in their contribution to your revenue, as well as in their reporting burden. Much of the infrastructure and operations for fully participating in MIPS can be extended to these programs down the line.

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Further reading:
Expert Commentary: Nathan Bays on MACRA in 2018
At long last: The documentation you need for Improvement Activity audits

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