The Merit – based Incentive Payment System (MIPS) has many similarities to the PQRS and Meaningful Use programs but also differs in significant ways. Most strikingly, PQRS and meaningful use were primarily pass/fail oriented programs where minimal performance on measures would avoid penalties. By contrast, performance that was far more than adequate to avoid penalties under these programs (e.g., quality measure performance rates of 80% to 90%) may result in penalties under MIPS.
MIPS is also extremely competitive and CMS will publish each practice’s MIPS score on the Physician Compare Website. Since the scores will be publicly available they will impact retention and recruitment of both patients and clinicians.
In order to attain high performance under the MIPS practices will have to have a detailed understanding of the requirements of the Quality and Advancing Care Information measure reporting requirements. Each of the measures has detailed specifications that can greatly impact performance for each measure.
MIPS performance will also depend heavily on clinical and administrative staff knowledge of the nuances of MIPS. It will also require optimization of workflows related to information capture and reporting. This generally requires an update to EHR content, settings and user training. Simply reporting on measures without supporting documentation may result in significant penalties and CMS has the option of performing audits that go back several years.
We have spent hundreds of hours reviewing complex regulations, obtaining clarifications from CMS (in some cases at a senior leadership level) and providing suggestions to CMS on future rules.
We are ideally positioned to assist you with designing and implementing a MIPS performance program that will allow you to avoid penalties and potentially obtain significant positive payment adjustments. We set goals for your performance that will allow you to determine a specific return on investment for your services. Our team will also help you position yourself for future directions, such as engagement in MIPS APMs or Advanced Alternative Payment Models.
Please contact us at firstname.lastname@example.org for further information. For a limited time will offer a free 30 minute consultation to authorized representatives of practices and other healthcare organizations.