When to invest in MIPS analytics

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was created as a catalyst for transforming the healthcare system from fee for service to pay for value.

To accomplish that, MACRA established the quality payment program for “physicians and eligible clinicians” via two tracks: Merit-based Incentive Payment System (MIPS) or the Advanced Alternate Payment models (APM). Unfortunately, many providers perceive the program as a burden due to its complexity and lack of a clearly defined path to capitalize on the incentive payments.

In 2017, providers under the MIPS quality performance category had the flexibility to submit the minimum requirement which was only one measure to avoid the penalty with a monitoring period of just three months. As a result, the need for technology was fairly low in 2017. But starting in 2018, many providers will be challenged to comply with the new MIPS reporting requirements that are more complex and will require the use of technology, data and analytics.

To succeed in this new era of MIPS, its important to understand the changing reporting environment. Here are four of the key challenges that providers will face related to the 2018 reporting requirements:

1. The Data and Analytic Demands of MIPS: As we move into 2018 and beyond, MIPS will require providers to use data, technology and analytics to report on performance, gain insight into their current situation and develop an action plan for improvement. With provider burnout on the rise, many organizations will be further stressed by the additional resources needed to comply with the MIPS reporting.

2. The Multitude of Performance Categories: Providers may not be able score as high as they potentially could due to the complexity of MIPS which scores providers across a wide array of performance categories including quality, improvement activities, advancing care information and cost. Further complicating MIPS is that each category has its own set of measures, base minimum requirements and scoring methodology.

3. Determining Best Measures: Providers will face the daunting task of deciding which of the over 300 measures they should select to optimize their return on MIPS. This will require providers to invest significant time in monitoring, analysis and finding experts with the in-depth knowledge to pinpoint best opportunities.

4. Intricate Scoring Calculation: The Medicare Payment Advisory Commission (MedPAC) wants to eliminate MIPS, stating that it is too burdensome. The root of the problem is the scoring mechanism as category scores are calculated and weighted to determine the MIPS final score. CMS then analyzes performance across clinicians and determines penalties or awards incentives. The adjustment increases over time +/- 5% (2018) to +/- 9% in 2020, meaning the level of financial risk increases and the competition will increase as more physicians and eligible clinicians will strive to improve their score.

Overcoming the hurdles of MIPS
Given the scope and complexities of MIPS, how should providers proceed to minimize the penalties and optimize incentive payments in 2018 and beyond? Physicians and eligible clinicians should track the category measures over the course of the year and determine if there are specific measures where they can score higher. For example, are there any measures where:

• high performers could carry the group?
• the organization’s performance exceeds their peers?
• there is a likelihood that fewer organizations or competitors will submit a particular measure?

This level of monitoring and tracking requires time, money and resources including technology, MIPs analytics and reporting expertise. Many smaller, resource-constrained hospitals and independent physician associations (IPAs) may be concerned about making these investments. However, CMS estimates that 74% of MIPS scores will exceed 70 points putting those organizations at risk for MIPS penalties and leaving incentives dollars on the table.

2018 is the year to invest in MIPS analytics
Now is the time for provider organizations to take the plunge into MIPS analytics to avoid the penalties and optimize the payment incentives in 2018 and for years to come. For example, a group practice with approximately 120 physicians, Medicare part B revenue of $ 10.5M, using a leading EHR with a 2017 MIPS Score of 71, could increase its payment adjustment by over 2% and generate $200,000 in incentive payments in 2018. In addition, establishing an analytics and intelligence capability for MIPS in 2018 will position provider organizations to generate increasing incentive payments year after year while improving patient care.

An effective MIPS programs will require technology support, analytics and specialized MIPS expertise. Provider organizations that lack this expertise, should consider outsourcing MIPS reporting and analytics to services organizations with the requisite expertise and experience to help them achieve their incentive payment goals while ensuring that the organization continues to operate effectively and efficiently. As the saying goes, organizations that stand still get run over, so think of 2018 as the year to get your MIPS analytics program moving in high gear.

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