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MIPS: When Will the Alphabet Soup End?

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Jarrod Shapiro
A glass of water next to surgery with a red '12:00' behind glass but infront of surgery.

HIPPA. CMS. EMR. ACA. PQRS. Ready for some more alphabet soup that’s going to make your podiatric medical practice that much more challenging? Welcome to MACRA and MIPS, a new law that is guaranteed to affect your practice. I’m no expert on this topic, so I urge everyone to do your own research, but for now let’s take a quick look at the fundamentals of these new laws.

First, what does MACRA and MIPS stand for?

Medicare
Access and
CHIP
Reimbursement
Act of 2015
Merit-Based
Incentive
Payment
System

Now, I don’t know about you, but when I hear MACRA it sounds somewhat innocuous, but MIPS…now that sounds an awful lot like pay for performance. Remember that other acronym? P4P? It’s back with a vengeance (if it ever really went away).

MACRA will affect those of us who see Medicare patients (the vast majority of physicians). The law has several significant effects1:

  1. Repeals the Medicare sustainable growth formula (which has been a money loser for doctors for many years and a political hot potato).
     
  2. Rewards doctors who provide better care by the creation of two payment systems: MIPS and APMs. What are APMs, you ask? We’ll get to that in a minute.
     
  3. Consolidates three prior reporting programs: PQRS, Meaningful Use, and VBPM (Value-Based Payment Method) into MIPS. It also adds clinical practice improvement activities (CPIA).
     

Yes, you heard correctly. You’ve been spending time and effort working on PQRS and meaningful use, and now they’re going to be absorbed into a new system. Isn’t that fun? Wahoo!

MACRA will only apply to physician practices and Medicare, not hospitals.
The MACRA budget is supposed to be revenue neutral. That means those who receive payment will be offset by those who receive penalties in a bell-shaped curve. Those that sit at the hump of the curve will receive no payments or penalties.
CMS plans to use data obtained from 2017 in order to determine payments when the system becomes fully active in 2019.
Physicians will be able to pick one of two routes of payment: MIPS or APM (alternative payment model). Physicians may chose APM but must also qualify (ACOs, patient centered medical homes, and bundled plans, plus some “demonstration” plans). Most of us will end up in MIPS.
 

MIPS will have four categories which will be considered to base payment to physicians:

  1. Quality (50% of a physician’s score) – physicians will chose six of 200 optional sub-measures in which to report.
     
  2. Resource Use (AKA Advancing Care Information) (25% of a physician’s score) – this is essentially the same as Meaningful Use.
     
  3. Clinical Improvement Activities (15% of a physician’s composite score) – there are 90 outcomes to chose from with various activities from safety to specific patient outcome improvements.
     
  4. Resource Use/Cost (10% of a physician’s score) – this information will be obtained from Medicare reimbursement submissions rather than something physicians report directly.
     

Here comes the fun part. Practices must begin their quality data reporting in 2017. Based on how a provider scores on their composite ranking (adding up the four categories above), there will be up to a 4% adjustment down (AKA penalty) and maximum positive adjustment of 12% (three times the base rate) in 2019 and up to a 9% adjustment (again, up or down) in 2021. Yes, that means if you happen to be at the left end of that bell curve, you could be penalized as much as 9%. The positive adjustment could be up to 10% for “exceptional” providers, though “exceptional” has not been defined yet.


Practices must begin their quality data reporting in 2017.


Who will be exempt from MIPS? Here they are:

  1. Providers in their first year of billing Medicare.
     
  2. Providers whose volume of payments falls below a certain threshold (not yet determined).
     
  3. Those who qualify for the alternative payment model (APM).
     
  4. Those who practice in rural locations or in FQHCs (federally qualified health clinics). This last one is anticipated to be exempt but technically isn’t yet.
     

So, what does this mean for patient healthcare providers? Likely more paperwork and the need to learn a new system. Advocates of this law argue these changes will make things more streamlined by combining several of the prior reporting schemes. I also doubt there will be too many of us against the idea of getting rid of the sustainable growth formula. However, this entire thing seems like another attempt to track what will turn out to be useless data in the end with the only result being that it is ever more challenging to practice medicine.


What this all means for healthcare providers is more paperwork and the need to learn a new system.


Here’s some parting advice to providers from one of the references below2:

Understand the law.
Make sure your Meaningful Use measures are in place since its components will be embedded within MIPS.
Continue to participate in PQRS since it’s not going away yet.
Survey the 90 options for clinical practice improvement to see which will fit your practice.
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For those of you interested in learning more now, click on the links below for further information.

  • Click Here for: Merit-Based Incentive Payment System: Clinical Practice Improvement Activities Performance Category
     
  • Click Here for: Clinical Practice Improvement Activities Performance Category
     
  • Click Here for: MIPS Program: 2017 Advancing Care Information Category (formerly known as Meaningful Use) Proposed Rule Guide
     

My last piece of advice: get ready for ever more changes and paperwork. Alphabet soup or bust!

Best wishes.
Jarrod Shapiro Signature
Jarrod Shapiro, DPM
PRESENT Practice Perfect Editor
[email protected]
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References
  1. Frequently Asked Questions: Medicare Access and CHIP Reauthorization Act of 2015. Last accessed 8/5/2016
     
  2. MIPS explained: 4 categories physicians must master. Medical Economics. Last accessed 8/4/2016.
     
  3. 7 things physicians need to know about MACRA proposed rule. Medical Economics. Last accessed 8/5/2016
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