Practice Management

MIPS Tips: Report the basics to avoid dwindling payments

In this blog from Epstein Becker & Green and its affiliate EBG Advisors, Robert Atlas and Yulian Shtern delve into the upcoming Merit-Based Incentive Payment System and how physicians can best maneuver their way through the process .

Robert Atlas
Robert Atlas

Physicians participating in Medicare should understand how they can avoid the payment reductions levied for failing to participate with value-based payment programs. A recent report from the Centers for Medicare & Medicaid Services (CMS) indicates that nearly 500,000 clinicians will see a 2% reduction in their 2017 Medicare reimbursements for failing to participate in the Physician Quality Reporting System (PQRS). Medicare’s new Merit-Based Incentive Payment System (MIPS), which replaces PQRS in 2017, promises to escalate such fee reductions, as physicians who fail to participate in 2017 will see a payment adjustment of up to 4% in 2019. However, physicians can avoid the payment reduction under MIPS with less strenuous reporting requirements compared with PQRS.

PQRS, a quality reporting program for certain eligible professionals, was intended to increase the availability of data and information concerning certain quality measures. PQRS used a “carrot and stick” approach, rewarding participating physicians who showed positive quality measures with payment incentives and punishing non-participating physicians by way of a Medicare fee reduction. Some in the medical community criticized PQRS as being overly burdensome due to the costs and effort associated with PQRS fulfillment and the payment reductions levied against providers who fail to participate.

These criticisms resonate most with solo and small group practitioners, who may not have the resources to compile and submit the requisite data. CMS’s recent report indicates that of the 500,000 physicians who are subject to the 2% payment reduction, 21% are individual practitioners. One in six of these providers is a primary care practitioner. While overall participation has increased since PQRS was initially implemented, government regulators and industry stakeholders have expressed concern over the large number of non-participating physicians.

CMS tried to resolve these concerns by implementing MIPS, which will measure physicians based on a combination of quality, clinical practice improvement activities, meaningful use of electronic health records, and resource use (cost). For 2017 performance, impacting payment in 2019, CMS has simplified reporting requirements under MIPS and exempted many smaller practices.

Under the MIPS “Pick-Your-Own-Pace” approach, clinicians may choose from several options during the transition period to avoid negative payment reductions. The MIPS “Test Pace” option has the least burdensome reporting requirements, requiring the reporting of only one quality measure, one improvement activity or the five required “advancing care information” (meaningful use) measures. Physicians who satisfy the “Test Pace” option will avoid negative payment reductions, but will not be eligible for incentive payments. Alternative options require more reporting measures, but may yield greater incentive payments.

In addition to the relatively relaxed “Pick-Your-Own-Pace” approach, MIPS provides exemptions for certain individual or small group providers who are below certain low-volume thresholds. Clinicians who bill Medicare $30,000 or less or who have 100 or fewer Medicare patients are exempt from MIPS reporting requirements and payment reductions. A proposed rule introduced earlier this week indicates that for 2018 these thresholds may increase to $90,000 in billings or 200 Medicare patients. The exemption is welcomed by the individual or small-group provider community, which has practically struggled to participate in PQRS.

Yulian Shtern
Yulian Shtern

To further ease burdens on solo or small-group practitioners, the new proposed rule contemplates permitting solo or small-group clinicians to participate in MIPS in “Virtual Groups.” Solo practitioners and groups consisting of 10 or less eligible clinicians would be permitted to come together “virtually” and jointly report on measures and performance requirements. The new proposed rule reveals that the Trump administration is ready to carry forward with the same push toward value-based payment that began under the Obama administration. The tactics show a willingness to ease physicians into the new regimen, but not a change in strategic direction.

Robert F. Atlas is a strategic advisor and president of the health industry consultancy EBG Advisors , an affiliate of Epstein Becker & Green P.C. He can be reached at batlas@ebgadvisors.com .

Yulian Shtern, Esq., is a health law attorney in the health care and life sciences practice of Epstein Becker & Green P.C. He can be reached at yshtern@ebglaw.com .

 

In this blog from Epstein Becker & Green and its affiliate EBG Advisors, Robert Atlas and Yulian Shtern delve into the upcoming Merit-Based Incentive Payment System and how physicians can best maneuver their way through the process .

Robert Atlas
Robert Atlas

Physicians participating in Medicare should understand how they can avoid the payment reductions levied for failing to participate with value-based payment programs. A recent report from the Centers for Medicare & Medicaid Services (CMS) indicates that nearly 500,000 clinicians will see a 2% reduction in their 2017 Medicare reimbursements for failing to participate in the Physician Quality Reporting System (PQRS). Medicare’s new Merit-Based Incentive Payment System (MIPS), which replaces PQRS in 2017, promises to escalate such fee reductions, as physicians who fail to participate in 2017 will see a payment adjustment of up to 4% in 2019. However, physicians can avoid the payment reduction under MIPS with less strenuous reporting requirements compared with PQRS.

PQRS, a quality reporting program for certain eligible professionals, was intended to increase the availability of data and information concerning certain quality measures. PQRS used a “carrot and stick” approach, rewarding participating physicians who showed positive quality measures with payment incentives and punishing non-participating physicians by way of a Medicare fee reduction. Some in the medical community criticized PQRS as being overly burdensome due to the costs and effort associated with PQRS fulfillment and the payment reductions levied against providers who fail to participate.

These criticisms resonate most with solo and small group practitioners, who may not have the resources to compile and submit the requisite data. CMS’s recent report indicates that of the 500,000 physicians who are subject to the 2% payment reduction, 21% are individual practitioners. One in six of these providers is a primary care practitioner. While overall participation has increased since PQRS was initially implemented, government regulators and industry stakeholders have expressed concern over the large number of non-participating physicians.

CMS tried to resolve these concerns by implementing MIPS, which will measure physicians based on a combination of quality, clinical practice improvement activities, meaningful use of electronic health records, and resource use (cost). For 2017 performance, impacting payment in 2019, CMS has simplified reporting requirements under MIPS and exempted many smaller practices.

Under the MIPS “Pick-Your-Own-Pace” approach, clinicians may choose from several options during the transition period to avoid negative payment reductions. The MIPS “Test Pace” option has the least burdensome reporting requirements, requiring the reporting of only one quality measure, one improvement activity or the five required “advancing care information” (meaningful use) measures. Physicians who satisfy the “Test Pace” option will avoid negative payment reductions, but will not be eligible for incentive payments. Alternative options require more reporting measures, but may yield greater incentive payments.

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In addition to the relatively relaxed “Pick-Your-Own-Pace” approach, MIPS provides exemptions for certain individual or small group providers who are below certain low-volume thresholds. Clinicians who bill Medicare $30,000 or less or who have 100 or fewer Medicare patients are exempt from MIPS reporting requirements and payment reductions. A proposed rule introduced earlier this week indicates that for 2018 these thresholds may increase to $90,000 in billings or 200 Medicare patients. The exemption is welcomed by the individual or small-group provider community, which has practically struggled to participate in PQRS.

Yulian Shtern
Yulian Shtern

To further ease burdens on solo or small-group practitioners, the new proposed rule contemplates permitting solo or small-group clinicians to participate in MIPS in “Virtual Groups.” Solo practitioners and groups consisting of 10 or less eligible clinicians would be permitted to come together “virtually” and jointly report on measures and performance requirements. The new proposed rule reveals that the Trump administration is ready to carry forward with the same push toward value-based payment that began under the Obama administration. The tactics show a willingness to ease physicians into the new regimen, but not a change in strategic direction.

Robert F. Atlas is a strategic advisor and president of the health industry consultancy EBG Advisors , an affiliate of Epstein Becker & Green P.C. He can be reached at batlas@ebgadvisors.com .

Yulian Shtern, Esq., is a health law attorney in the health care and life sciences practice of Epstein Becker & Green P.C. He can be reached at yshtern@ebglaw.com .