MIPS Management Program for Specialists
The bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), often referred to as the “Permanent Doc Fix”, established a dedicated route toward new Medicare payment systems that align payments with quality performance and cost efficient outcomes. The Act, as published in the Final Rule in late 2016, 1) permanently repeals the Sustainable Growth Rate (SGR), 2) locks Part B payment (fee) rates at near zero growth with elimination of fee schedule updates from 2020 to 2025, and 3) stipulates the development and implementation in of a Quality Payment Program (QPP) with two distinct value-based performance payment paths (Merit-Based Incentive Payment System [MIPS] path and Advanced Alternative Payment Models [APMs] path) with varying levels of adjusted reimbursement based on the
path chosen and the performance exhibited within the path.
Under the MIPS path, Medicare Part B providers (inclusive of all independent physician specialists) who are mandated to participate in the MACRA QPP are scored annually on a 100-point performance scale
for the following four distinct performance categories:
- Quality Performance Category
- Cost Performance Category
- Promoting Interoperability (formerly called Advancing Care Information) Performance Category
- Improvement Activities Performance Category
A specialist provider’s total MIPS Score carries with it significant financial and reputational realities. Unfortunately, the challenges that specialist face in satisfying the MIPS performance category requirements and avoiding negative financial and reputational impacts are real and formidable. Specialists must grapple with:path chosen and the performance exhibited within the path.
Under the MIPS path, Medicare Part B providers (inclusive of all independent physician specialists) who are mandated to participate in the MACRA QPP are scored annually on a 100-point performance scale
for the following four distinct performance categories:
- Determining which reporting method to use among a maze of at least 6 different Quality Performance Category reporting methods under MIPS
- Selecting measures that are meaningful to the practice while at the same time ensuring a positive impact on the total MIPS score (NOTE: In the MIPS quality performance category measure set, not all measures are created equal. MIPs follows a decile based benchmarking system that fosters increased relative point values for certain benchmark measures, with reduced scoring weights for topped out measures).
- Ensuring that selected measures meet both the Case Minimum and Data Sufficiency criteria.
- Accommodating the impact the performance measurement has on practice workflow design and the potential need for re-training of staff.
- Dealing with the limitations of EHRs to satisfy interoperability functions.
- The increase in performance expectations for 2019 and beyond.
- Transparency of MIPS performance and the public posting of individual specialist’s performance on CMS Physician Compare website with full reputation implications.
MIPS Management Program
In full understanding of these challenges, Guardian Health Services offers a MIPS Management Program for Specialists that is designed to guide and assist individual and group specialist practices in maximizing MIPS performance, yielding significant financial and reputational impacts. The program provide specialist with:path chosen and the performance exhibited within the path.
Under the MIPS path, Medicare Part B providers (inclusive of all independent physician specialists) who are mandated to participate in the MACRA QPP are scored annually on a 100-point performance scale
for the following four distinct performance categories:
1. A proactive documentation management process for continuous documentation improvement.
2. A detailed analytics approach, driven by a robust integration engine (the Guardian platform) to identify documentation and reporting problem areas, and areas that underrepresent the care provided.
3. Individualized strategies for maximizing a practice/provider overall MIPS score, focusing attention on benchmarked measures and avoiding topped out measures.
4. An avenue for practices/providers to monitor MIPS performance status with a continuous focus on identifying areas for improvement before the annual submission to Medicare.
5. A proven path for practices/providers to 1) fully understand the rules and reporting requirements of MACRA-MIPS, and how those rules and reporting requirements can be integrated into a provider/practice specific strategic plan for performance optimization, and 2) capture and understand iterative changes in the QPP and MIPS over time.
6. Opportunities to capture bonus points and corresponding financial reward from changes in the bonus structure of MIPS (e.g., use of 2015 Certified Electronic Health Record (CEHRT) exclusively for the entire ACI reporting period; reporting additional outcome/high- priority measures; complex care bonus for providing services/treatment to a complex patient population)
The Guardian Health Services MIPS Management Program for Specialists capitalizes on the positive experience of the Guardian CMS approved Qualified MIPS Registry, the robust Guardian IT platform, and the wide-ranging portfolio of Guardian Health Services Programs. They provide direct avenues for specialists and organizations to realize high MIPS quality performance, interoperability functionality, direct practice improvement activities and efficient use of health care resources and cost savings.
Under the MIPS path, Medicare Part B providers (inclusive of all independent physician specialists) who are mandated to participate in the MACRA QPP are scored annually on a 100-point performance scale
for the following four distinct performance categories: