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News & Press: Industry News

MIPS 2018: Just Another Transition Year, Right?

Thursday, February 15, 2018   (4 Comments)
Posted by: Lynn Scheps, SRS Health
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 “Yes”—technically speaking, 2018 is a second transition year, but you are accepting some big risks if you allow yourself to be lulled into complacency by viewing it through the lens of MIPS-penalty avoidance.

This year’s performance threshold is just 15 points, a pretty low bar—not as low as the 2017 threshold of 3 points, but easily achievable nonetheless. Simply completing the Improvement Activities category earns a provider 15 points; so does submitting 5 quality measures, even with low performance levels; or one can satisfy the base ACI measures and supplement them with a few additional performance points from that or another category.

But the purpose of a transition year is to provide more time to implement new technology, improve workflows, and enhance performance to be ready for the future. In 2019, the game changes dramatically, and you need to gear up for it in 2018. Here are a few reasons:

  • There will be some big winners, and also some big losers, unlike the first two years of MACRA. Not only does the financial risk associated with 2019 increase significantly—from a 5% to 7% impact—but the performance threshold separating those who earn a positive payment adjustment from those who incur a negative adjustment is expected to increase significantly. By law, thresholds are to be set based on mean (or median) experience two years prior. Because no such previous data exists for the first 2 years of MACRA, CMS has had the flexibility to establish very low performance levels. But now, 2017 MIPS performance data will be available to establish the 2019 threshold, and my guess is that current success rates will be high enough to drive that threshold to a more challenging level. MIPS is not an incentive and penalty program; its design requires budget neutrality, which means that the gains of one set of providers will—by definition—be funded by the losses of another. You have the opportunity in 2018 to ensure that you are prepared to be part of the winning set in 2019.

 

  • It will become progressively harder to score well in the Quality category. Benchmarks will be more aggressive as providers build experience. Benchmarks in 2018 were recently posted on the QPP website, and you can already see differences from the 2017 deciles for some measures.

 

  • The Cost category, while only 10% of your score in 2018, will increase to 30% in 2019, making it a distinguishing factor among providers. Improving your comparative cost position is not something you can do overnight; it takes time. So, 2018 is the time to address this area more aggressively.

 

  • Your MIPS performance has implications beyond Medicare payment adjustments. Your reputation could be impacted as CMS makes more and more performance data publicly available on its Physician Compare website. What do you want patients, referring physicians, and payers to see about you when they are researching your practice?

So, take advantage of the second MIPS transition year by using it to prepare for 2019, when the program kicks into full gear and much more is at risk.

 

About the Author

Lynn Scheps is the SRS liaison with government policy makers. Representing the voice of high-performance physicians, she develops strategies to respond effectively to government initiatives. As the leading resource on meaningful use/EHR incentives, and now MACRA/MIPS, she ensures that SRS and our clients are well prepared for success as health care transitions to a value-based world. In addition, Lynn works with the Sales and Marketing teams to communicate how SRS addresses these and the other dynamic issues facing physicians and practice managers.

Lynn brings to SRS extensive management and consulting experience in the healthcare industry. As a consultant in Booz, Allen, & Hamilton’s healthcare practice, she provided strategic planning guidance to the CEOs and boards of hospitals, physician groups, and third party payers. As Director of Operations for CIGNA Healthplan of New Jersey, she contracted and managed the provider network and was responsible for the day-to-day operations of a start-up healthplan. In addition, she was an integral part of the CIGNA/Towers Perrin team that created and implemented the nation’s first point-of-service plan, now a standard in the health insurance industry. Other areas of experience include healthcare cost containment initiatives for corporate clients, development of a cardiac care program incorporating centers of excellence, and the design of professional education programs.

Lynn earned a BA, Magna Cum Laude, from Brandeis University; an MS in Rehabilitation Counseling from Boston University; and as a Kaiser Family Foundation Fellow, an MBA from The Wharton School at the University of Pennsylvania.

 

Comments...

Bradley Coffey, MA says...
Posted Tuesday, February 20, 2018
Hi Kara, If you're talking about the MedPAC vote to recommend removing MIPS, we have an article coming out in this month's OrthoActivist newsletter about the potential replacement program. Essentially, providers would have a portion of their reimbursement withheld by CMS. Those not participating would lose the money; those participating in certain ways would be eligible for incentive payments based on performance as determined by claims data. That being said, MedPAC can only make recommendations. Congress must be the one to actually remove MIPS and implement something else. I still see this as unlikely as it's difficult to get Congress to agree to anything these days. Please feel free to email me at bcoffey@aaoe.net if you have any additional questions about this or anything else related to Medicare payment policy. Brad
Kara Fiske says...
Posted Tuesday, February 20, 2018
This is a great article, thank you for sharing. Would you please summarize the details around the recent vote 12/2 and the thought that MIPS is going to "go away"? Thank you.
Bradley Coffey, MA says...
Posted Friday, February 16, 2018
Hi Joseph, We've put together a comparison of the 2017 and 2018 benchmarks to highlight your concerns. This can be found on the AAOE QPP Resource Center at aaoe.net/qpp under "2018 Benchmarks" or, at the following link: http://www.aaoe.net/resource/resmgr/resources/MIPS/2018_Resource_Center/QPP_Quality_Benchmarks_2017.xlsx. Brad
Joseph Mathews says...
Posted Thursday, February 15, 2018
• It will become progressively harder to score well in the Quality category. Benchmarks will be more aggressive as providers build experience. Benchmarks in 2018 were recently posted on the QPP website, and you can already see differences from the 2017 deciles for some measures. Can you please share this PDF? of the deciles for the different quality scores

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