Ready or not, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP) and its associated financial incentives and penalties start next year.
Unlike previous pay-for-performance programs, the Centers for Medicare and Medicaid Services (CMS) has done away with “all or nothing” rules for earning payment adjustments with the QPP’s Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APM).
This means that although a full year of reporting is not required in 2017, providers can still maximize incentives by reporting as much of the year as possible beyond the bare minimum 90 days of data. Read on to learn how to earn the most.
1. Participate as Much as Possible
Contrary to one of the myths we discussed in our recent MACRA blog post, participation in MIPS is critical beginning in 2017—unless you are new to Medicare, bill less than $30,000 a year for fewer than 100 Medicare patients, or are participating in an Advanced APM. Reporting no data will result in four percent reduction in Medicare payments in 2019.
Submitting the minimum amount of data (e.g., one quality measure or one improvement activity for any point in 2017) results in neither a penalty nor an incentive adjustment. Providers who submit the bare minimum (90 days of 2017 data) will receive either a zero or positive payment adjustment. By submitting a full year of 2017 data, physicians can earn a positive payment adjustment.
Alternatively, physicians who participate in CMS’s Advanced APM path by receiving 25 percent of Medicare payments or see 20 percent of their Medicare patients through an Advanced APM will earn a five percent lump sum incentive payment in 2019; however, not all risk-bearing payment programs will qualify as an Advanced APM.
2. Take a Long-term View
The MIPS incentive timeline is scheduled until at least 2022, with incentives increasing each year for top performers. MIPS is scored on a zero to 100-point scale based on four weighted categories: Quality, Advancing Care Information, Clinical Practice Improvement Activities and Cost—the latter not being counted in 2017.
The positive payment adjustment is awarded to performers who earn at least 70 points in a given year. The adjustment starts at four percent in 2019 (based on 2017 data) and steadily increases each year, capping at nine percent with the opportunity for an additional bonus of 0.5 to 10 percent.
At the same rate incentives increase, negative adjustments for non-participation or poor performance in the MIPS program also increase each year to a nine percent cap by 2022. In addition, physicians should be aware that unlike the Physician Quality Reporting System and Meaningful Use programs, which only displayed whether physicians participated, MIPS performance scores will be posted on Medicare's Physician Compare website.
3. Partner with the Right EMR
Practices should utilize the first quarter of 2017 to determine if their current Electronic Medical Record (EMR) system will eventually qualify as the 2015 Certified Edition that is mandated by the QPP. If it will not, practices should search for a partner as soon as possible because the process of selecting, implementing and testing a new system is time consuming and the choice will affect potential incentive dollars.
A specialty-specific EMR such as Nextech EMR can help ensure MIPS reporting success in 2017. Nextech's entire suite of EMR products for Ophthalmology, Dermatology and Plastic Surgery will serve as the framework for its certified edition and support Quality measures and Clinical Practice Improvement Activities. In addition, the health information exchange requirement is facilitated through Nextech's integrated communication features.
By capturing and reporting as much MIPS data as possible in 2017, providers will have potential to earn more financial incentives for and will have a head start on 2018 reporting. This process is enhanced by choosing an EMR designed for your specialty to simplify and automate these requirements. In other words, having the right partner and starting MIPS participation early will help your practice have a very happy New Year.