The Merit-Based Incentive Payment System (MIPS) has been an integral part of the healthcare landscape for nearly eight years. Despite its intended purpose of enhancing healthcare quality and efficiency, many providers continue to grapple with ongoing confusion regarding MIPS rules and measures. This article explores the lingering uncertainty surrounding MIPS complexities and offers strategies for successful navigation.
The Evolution of MIPS and Overcoming Hurdles
MIPS emerged from the Medicare Access and CHIP Reauthorization Act (MACRA), representing a significant step towards transitioning from fee-for-service to value-based care. The initial goal was simple: incentivize healthcare providers to deliver high-quality care efficiently. However, MIPS has evolved significantly since its inception, introducing layers of complexity that challenge even the most seasoned providers. Providers often find themselves uncertain about the expectations for each reporting period. Adding to the complexity are eligibility requirements, exceptions, and the diverse interpretations of rules and measures by different entities. The most recent example of program evolution is the transition to MIPS Value Pathways (MVPs) reporting option that started in the 2023 performance year. It seems like just as you get comfortable with MIPS rules, CMS releases another rule or method that needs to be followed.
Administrative burden and resource constraints are other significant hurdles. Smaller practices often lack the resources and staff required to navigate MIPS effectively. Many will submit data "as is" – without a thorough review – without realizing they’re potentially jeopardizing their revenue.
MIPS: Not One-Size-Fits-All
MIPS is a multifaceted program, consisting of the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories. The scoring system incorporates quality performance benchmarks, updated annually, that measure your performance compared to that of your peers in the same category. The number of available measures often leaves providers struggling to determine and decipher which measures are most relevant to their practice. Providers often default to pre-selecting measures that appear to be easy to meet or align with their specialty. However, as the program's performance thresholds rise, these once-reliable tactics become less effective. The overuse of common measures can lead to lowered scoring, retired measures, or reduced benchmarks.
Impact on Reimbursement
One of the primary MIPS concerns for providers is its effect on reimbursement. The MIPS program is budget-neutral, meaning that it redistributes funds among providers based on their performance. Underperformance or non-participation can lead to financial penalties, which are then distributed to clinicians who exceed the minimum score for the performance year. And while incentives are capped at a certain percentage, they rarely reach that maximum, therefore falling short of revenue expectations. Understanding how MIPS influences reimbursement is pivotal, as it can significantly impact a provider's financial bottom line. No one wants to lose a percentage of their Medicare Part B reimbursements, so MIPS participation in all applicable categories is important.
Strategies for Navigating MIPS Successfully
While MIPS presents considerable challenges, there are effective strategies for success. A profound understanding of MIPS rules and measures relevant to one's practice is essential for devising a winning strategy.
Leveraging technology and data, particularly Electronic Health Records (EHR) and data analytics, can streamline the data collection and reporting process, if there is transparency to the data and an opportunity for correction before submission.
Taking a holistic approach to patient population analysis can help determine the most suitable measures for a group or individual physician, transcending the traditional pre-selection approach. This also eliminates the limitations of specialty measure sets. Focusing on measures with robust benchmarks can maximize points, directly correlating with financial gains. A Certified EHR Technology (CEHRT) that leverages electronic Clinical Quality Measures (eCQMs) based on clinical data can provide higher benchmarks, translating to higher points and, ultimately, higher reimbursement.
MIPS remains a pivotal program with the potential to reshape healthcare for the better. However, the prevailing confusion among providers stands as a significant roadblock to its success. Clarity, education, and support are the cornerstones of addressing this issue. By simplifying reporting, offering resources, and promoting transparency, we can empower healthcare providers to excel in MIPS, benefiting both providers and their patients.
For more information on MIPS and effective strategies for successful navigation, contact Alpha II. We have been a leader in MIPS quality reporting for over 9 years. QM Accelerator – our ONC-certified EHR technology – simplifies quality reporting by pulling data from EHRs and PM systems to analyze and determine the most suitable measures based on patient populations. The dashboard provides insights into scores, benchmarks, and performance, aiding providers in improving their MIPS performance and reaching their goals.