It’s been two years since we recapped the Merit-Based Incentive Payment System (MIPS). MIPS remains the largest physician value-based care payment program and continues to transform as the healthcare industry distances from fee-for-service to value-based payment. ApolloMD has participated for three years and can safely say MIPS is extremely complex. Because of its complexity, we are still learning more about MIPS and digging to find ways to help physicians and other clinical providers understand the program and improve their performance.
The last three years have been an educational period, bringing physicians and APCs up to speed on the changing program. Overall, while there was a focus on embracing quality metrics, the majority of the focus was learning the system and figuring out how to avoid negative payment adjustments. This strategy worked well for practices nationwide. Some have even been categorized as exceptional performers. However, the bar is becoming increasingly difficult.
The risks are higher, quality measure benchmarks increased and good is no longer good enough. We predict the 2020 performance year will be more challenging for individuals and groups nationwide, than in years past.
In the 2020 performance period, the performance threshold increased from 30 points to 45 points to avoid negative adjustments in the payment year (2022). The threshold to avoid a negative payment adjustment is likely to increase even more in 2021 to 60 points.
Payment adjustments also increased. In 2019, clinicians could earn a positive or negative adjustment of up to 7% , which increased to 9% in 2020. Currently, CMS has not forecasted the percent payment adjustment past 2020, which will likely stay at 9%.
This means doing the bare minimum will not cut it this year. A deeper understanding of the program and awareness of where changes can be made to increase scores and performance is critical.
Tips to Improve
MIPS is made up of four categories – Quality, Promoting Interoperability, Improvement Activities and Cost. Each category has different requirements, weight and maximum point values. However, Quality is the category where you have the most control. For hospital-based providers (like Emergency Medicine, Hospital Medicine, Anesthesia and Radiology), Quality also holds the most weight at 70% of the overall MIPS score, which makes it critical to score well.
While the other categories are important, you can work towards improving your score in the Quality category with these simple tips.
1. Know the measures.
The first step in driving improvement efforts is to know what measures are tracked and reported. CMS requires group and individual practices to report on at least six measures.
2. Understand the requirements.
Each measure has a set of requirements to first be considered eligible for the measure and then for the measure to be considered met. Know which patients are included or excluded from the measure. Use accurate verbiage in documentation.
Make sure to meet the proper requirements of the measure. For example, in some cases it may require documenting why a test was ordered. Other requirement examples could include ordering a test, or not giving an antibiotic to a particular patient. Education is key when it comes to performing well in the Quality category.
CMS provides measure specifications for each program-eligible measure. All measure specification documents are available online. The specifications give full details of each individual measure and requirements to meet the measure.
3. Use data to drive improvement efforts.
CMS releases the national average and benchmarks for the individual measures at the beginning of each year. Use these scores as guides to compare how an individual or group is performing. Setting a goal based on the national average will also help drive improvement efforts. The CMS 2020 quality benchmarks and national averages are available in the QPP Resource Library using the search term “benchmarks.”
On the Horizon
CMS finalized a program called the MIPS Value Program (MVP) in the 2020 Physician Fee Schedule final rule. It intends to transform the MIPS program into one that engages clinicians and specialty societies to craft measures which assess physicians and other clinicians on outcomes. This framework is part of the Meaningful Measures initiative. The MVP framework may become effective as early as the 2021 performance year.
MVP will focus on the current MIPS categories but connects measures and activities across the Quality, Cost and Improvement Activities categories. Initially, the framework includes a uniform set of Promoting Interoperability measures to be included in all pathways. The MVP would be organized around a specialty, specific episode of care or health condition. CMS is working with specialty societies to design MVPs and will formally implement the pathways through rulemaking.
Laura Springer is a key member of the ApolloMD Quality Team acting as Director of Quality Reporting. She joined the ApolloMD team in 2015 as a Data Analyst. Laura’s expertise in SQL Server allowed her to analyze financial and reimbursement data resulting in increased visualization of reimbursement changes. Her dedication to project management, coupled with her quality reporting and technical background has allowed her to monitor and report on provider quality performance and be successful in intricate reporting quality data to CMS. Laura received her bachelor of science in health promotion with a minor in business from Auburn University.
Dr. Mike Lipscomb began practicing Emergency Medicine in 1997 as a Clinical Instructor for the University of Michigan. In 2000, he joined ApolloMD at WellStar North Fulton Hospital, becoming Medical Director of the department in 2005. Dr. Lipscomb has served on multiple committees at the hospital, most recently completing terms of Secretary Treasurer and Chief of Staff, and continues to serve on the Medical Executive Committee. In 2013, ApolloMD was excited to welcome Dr. Lipscomb to the corporate team to oversee clinical operations of hospitals in the Southeast. With extensive experience in optimizing emergency department flow, EMR use, and patient satisfaction, Dr. Lipscomb became Chief Quality Officer for ApolloMD in 2016. Dr. Lipscomb received his medical degree from The University of Texas Southwestern Medical Center at Dallas, and completed residency training in Emergency Medicine at The University of Michigan Medical School.
As Director of Analytics and Data Science, Donal Harrison supports the ApolloMD Quality Team through his expertise in data mining and statistical analysis. Donal holds a Master’s degree in Experimental Psychology with a focus in Quantitative Methods from the University of West Florida, where he studied novel applications for linear and nonlinear models in fully- and semi-randomized block designs. Donal has since put his data science skills to use in areas ranging from credit scoring to anomaly detection and has received awards for his work on the use of unsupervised machine learning in post-hoc analysis. Joining ApolloMD in 2015, Donal has applied his expertise in Python, R, and SQL programming to develop high quality, reproducible analytics at the company, facility, and individual provider levels. He looks forward to continuing to leverage modern technologies in delivering actionable insights that foster success for the ApolloMD Quality Team and its partners.