MIPS: Which Improvement Activities Work Best for Your Practice?

By Sonda Eunus, MHA, CMPE, CPB

MIPS, or the Merit-based Incentive Payment System, will have a significant impact on eligible Medicare clinicians in coming years. MIPS will measure clinician performance in 4 categories, and will assign each clinician a MIPS score that will then result in either a payment increase or decrease to the clinician’s Medicare reimbursement. The 4 performance categories include Quality Measures, Cost and Resource Utilization, Advancing Care Information, and Improvement Activities.

In this article, we will explore the Improvement Activities category in more detail. Clinicians and practices will have over 90 different improvement activities to choose from to implement in their practice. The ultimate goal of this performance category is to improve the quality of patient care provided. There are several subcategories that these improvement activities fall in:

• Achieving Health Equity
• Behavioral and Mental Health
• Beneficiary Engagement
• Care Coordination
• Emergency Response and Preparedness
• Expanded Practice Access
• Patient Safety and Practice Assessment

Let’s discuss these subcategories in greater detail.

Achieving Health Equity

This category wants you to provide quality care to patients while also taking into account social factors in health, such as income level, food security, employment, and housing.

• Measure Example: Seeing new and follow-up Medicaid patients in a timely manner, including individuals dually eligible for Medicaid and Medicare (IA_AHE_1)

Behavioral and Mental Health

This category emphasizes the importance of factoring in behavioral and mental health and its effect on the patient’s overall well-being.

• Measure Example: Diabetes screening for people with schizophrenia or bipolar disease who are using antipsychotic medication (IA_BMH_1).

Beneficiary Engagement

This category measures your efforts in engaging the patient’s family to ensure that they fully understand the patient’s condition and are included in important medical decisions and the development of a plan of care.

• Measure Example: Engage patients, family and caregivers in developing a plan of care and prioritizing their goals for action, documented in the certified EHR technology (IA_BE_15).

Care Coordination

This category holds clinicians accountable for ensuring that the patient’s care is coordinated among the different healthcare providers and facilities that are participating in his or her care, and that there is clear communication between all parties involved.

• Measure Example: Timely communication of test results defined as timely identification of abnormal test results with timely follow-up (IA_CC_2).

Emergency Response and Preparedness

This category gets clinicians ready to respond in the event of a natural disaster or other emergencies, and to ensure that all employees and patients at the facility are protected from harm.

• Measure Example: Participation in Disaster Medical Assistance Teams, or Community Emergency Responder Teams. Activities that simply involve registration are not sufficient.  MIPS eligible clinicians and MIPS eligible clinician groups must be registered for a minimum of 6 months as a volunteer for disaster or emergency response (IA_ERP_1).

Expanded Practice Access

This category wants clinicians to make medical care as easily accessible to patients as possible, by opening longer hours or providing different means of communication with the practice.

• Measure Example: Use of telehealth services and analysis of data for quality improvement, such as participation in remote specialty care consults or teleaudiology pilots that assess ability to still deliver quality care to patients (IA_EPA_2). 

Patient Safety and Practice Assessment

In this category, clinicians must ensure that they are implementing processes that will ensure that safe and quality care is provided to patients across the board, at every visit. Also takes into account population health management.  

• Measure Example: Use decision support and standardized treatment protocols to manage workflow in the team to meet patient needs (IA_PSPA_16).

Population Management

In this category, you focus on patient populations with chronic conditions. You are encouraged to come up with initiatives that will benefit your targeted populations, as well as the local community that you serve.

• Measure Example: Implementation of regular reviews of targeted patient population needs which includes access to reports that show unique characteristics of eligible professional's patient population, identification of vulnerable patients, and how clinical treatment needs are being tailored, if necessary, to address unique needs and what resources in the community have been identified as additional resources (IA_PM_11).

Which of these subcategories would be the most beneficial and feasible to implement in your practice? 

Leading Management Solutions provides MIPS Assistance and Reporting services. Learn more here: www.lmsmips.com and download a free MIPS E-Book containing valuable information and links to useful resources.

MIPS 2017: Avoid a 4% Medicare Reimbursement Decrease

By Sonda Eunus, MHA, CMPE, CPB

As the first year of MIPS reporting comes to an end, healthcare practices and providers don’t have much time left to learn about the Merit-Based Incentive Payment System and how it will affect their revenue and credibility. To make things simpler, I have put together some of the most frequently asked questions about MIPS.

1. How do I know if I am required to report?

Physicians (MD/DO and DMD/DDS), Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists that bill Medicare are required to report for 2017. If you meet any of the below exclusion criteria, you are not MIPS-eligible:

·         You are newly enrolled in Medicare.

·         You see 100 or fewer Medicare Part B patients per year.

·         You have less than or equal to $30,000 allowed Medicare Part B charges annually.

·         You are on the participant list for a model that CMS has deemed an Advanced Alternative Payment Model (AAPM).

Look up your participation status here with your NPI: 

https://qpp.cms.gov/participation-lookup

2. What happens if I don’t report at all?

If you are an eligible clinician who chooses to not participate in the MIPS program, you will face a 4% decrease in your Medicare payments in 2019. These payment adjustments will become greater every year, with a maximum penalty of 9% of your Medicare reimbursement. Additionally, every clinician’s score is publicly displayed on the Medicare Physician Compare website, for everyone to see. Having a low MIPS score can cost you patients, as well as can undermine your credibility with insurance payers.

3. What measures should I report on?

It is recommended that you choose measures that are most representative of your practice, such as those that apply to the patients you see or the procedures that you perform frequently to ensure you have a minimum of 20 cases. If possible, avoid reporting on quality measures that most clinicians generally perform well on across the board, because you may have to achieve nearly the highest possible score on the measure to receive more than the minimum number of points for that measure.

4. I am part of a group practice, what is the difference between reporting as an individual and reporting as a group?

For some multi-specialty practices, it may make more sense to report individually so that different quality or Improvement Activity measures may be used that will best fit each specialty. Also, in instances where individual performance may otherwise be unknown, individual reporting may be beneficial to ensure that bonuses or penalties are properly applied to individual physicians, rather than to the group as a whole.

On the other hand, reporting as a group may be easier than reporting individually. For practices that have been reporting as a group to programs such as PQRS, the transition to MIPS may be less burdensome if the practice continues to report as a group. Keep in mind, though, that bonuses or penalties will be applied to the group as a whole regardless of each individual clinician’s performance.  

5. I am a hospital-based physician, am I accountable for the same measures as outpatient clinicians?

A hospital-based physician is subject to all of the same MIPS rules as a physician practicing in other settings except that he or she is not scored on the Advancing Care Information (ACI) category. Instead, hospital-based physician’s MIPS score will be based on Quality and Improvement Activities (IA) in 2017.

6. When is the deadline to report?

March 31, 2018, but if you are reporting through your EHR then you should verify with your EHR vendor because they may have a different deadline. If you are using the claims-based reporting method, then you only have until Dec 31, 2017 to report. 

7. How can I track my performance?

CMS will provide data to help you prepare for MIPS. Many physicians have participated in the Physician Quality Reporting System (PQRS) and Value Based Modifier (VBM) programs to avoid payment penalties. CMS provides Quality and Resource Use Reports (QRURs) and feedback reports which you can obtain on the CMS website. All QRURs are available on the CMS Enterprise Portal: https://portal.cms.gov/wps/portal/unauthportal/home/. You may need to request the appropriate “role” in the system to view your QRUR.

8. Where can I find more information about the program?

Here are some great links to get started: 

·         https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-MIPS-and-APMs.html

·         https://qpp.cms.gov/

·         https://www.ama-assn.org/practice-management/understanding-medicare-s-merit-based-incentive-payment-system-mips

If you would like to download a free MIPS E-book that explains what you need to do to avoid a 4% Medicare payment decrease in 2019, as well as to earn a high MIPS score and Medicare payment increases, go here: www.lmsmips.com. You will also be able to see the payment adjustments that you may face depending on your MIPS participation level and annual Medicare revenue. 

Leading Management Solutions (www.lmshealthpro.com) provides MIPS consulting and reporting services. We will help you avoid a 4% penalty for 2017, and assist you in earning positive payment adjustments in future years. To schedule a free consultation, go here: https://calendly.com/lmshealthpro.