In Part 1 of this two-part article exploring the implications of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) for healthcare providers, healthcare leaders and health IT experts discussed why it’s critical for clinicians to think strategically, rather than tactically, about MACRA compliance. Part 1 was published last week and can be found here.
MACRA, which was passed with bipartisan support in Congress, launched its first reporting period in January 2017 in which eligible Medicare clinicians will be reporting to a Quality Payment Program (QPP) that determines a physician’s reimbursement based on the high quality, efficient care they provide that’s supported by technology. MACRA includes two payment tracks that eligible Medicare clinicians can take part in that will determine their payment adjustments in future years. Early on in the program, most of these clinicians are expected to participate in the less risky Merit-Based Incentive Payment System (MIPS) track as opposed to the Advanced Alternative Payment Models (APMs) track.
Part Two of this article explores the operational and reputational implications of MIPS reporting and the technology investments that will be vital to success.
As reported by Healthcare Informatics Managing Editor Rajiv Leventhal, the Trump administration is currently reviewing potential 2018 updates to MACRA that would especially ease the burden the new legislation puts on small physician practices. In the first performance year, the Centers for Medicare & Medicaid Services (CMS) allows physicians to “pick their pace” of participation. It’s expected that new Health and Human Services (HHS) Secretary Tom Price, M.D. will extend that flexibility, Leventhal reported. The proposed rule from Price is expected to drop in the coming weeks, if not sooner.
However, even if CMS does extend that flexibility, the MIPS score performance threshold will eventually increase, and provider organizations need to be prepared in order to “keep up with a treadmill that is going faster and faster,” according to Tom Lee, Ph.D., founder and CEO of Chicago-based consulting and software firm SA Ignite. “We are seeing physician practices that are concerned about the immediate and annual reimbursement impacts regarding the payment adjustment, but they are even more concerned about the reputational impact. The winners get richer and the losers get poorer, and then you get to a point where you are not going to be able to catch up.”
Operational and Reputational Implications
Healthcare provider organizations’ MIPS scores will be publicly reported to the Physician Compare website, and will also be accessible by other third party rating systems including Yelp, Angie’s List, Health Grades and Google, something that about half of physician practices were not aware of, according to a recent Black Book Research survey, as reported by Healthcare Informatics.
Lee notes that while CMS has made it relatively easy for physicians to avoid a penalty for the 2017 reporting year, many physicians may not be considering the long-term reputational impact of having a lower score than their peers. “If you get 18 out 100 points, you’ll avoid a penalty by more than 15 points as CMS has set an artificially low threshold of 3 points. However, your 15 out of 100 points will be publicly reported through the Physician Compare website hosted by CMS and you run the risk that your 15 out of 100 points may not look so good to a consumer that’s now looking at how you compare to another clinician on this score out of 100 that has the Medicare stamp of approval on it,” he says.
He continues. “That score basically sticks with you for at least two years, and probably forever. If you pick up and leave an organization in 2018, but you’ve already earned the score of 2017, and then you go to a new organization, that new organization in 2019 will inherit the payment adjustment for MIPS that you earned in 2017. So, the MIPS score is basically irrevocably stamped to your resume as a clinician, and that has very broad implications for physician recruiting, contracting, compensation and credentialing. And a lot of physicians don’t realize that.”
Many healthcare IT leaders recommended that physician groups establish a multidisciplinary MIPS steering committee consisting of clinicians, staff, administrators, IT, and finance, if they haven’t done so already. “The MIPS committees that we see being spun up are very cross functional. The people involved in those MIPS discussions, at a leadership level, they come from every single function, so instead of just the CIO, you get the chief experience officer (CXO), the chief quality officer (CQO) and the COO because MIPS broadly impacts almost every function,” Lee says.
The focus of a cross-functional MIPS steering committee and organizational leadership should not be on just complying with MIPS requirements for 2017, but on the strategic implications moving forward, many industry leaders say. Lee points out that as the “pick your own pace” options end at the end of this year, it could be sink or swim for most organizations when it comes to MACRA in 2018.
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