Becker's Hospital Review

12 Executive Briefing Sponsored by: How Clinicians Can Come Out on Top in a MIPS World A imed at improving the quality and cost-effectiveness of healthcare delivery in the U.S., the Medicare Access and CHIP Reauthorization Act (MACRA) presents both opportunities and threats to future provider revenue. With the first reporting year of MACRA's Quality Payment Program well underway, it is vital for health systems and multispecialty groups to lay the groundwork for MACRA success. MACRA's first performance year began Jan. 1 for eligible clinicians — physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists — who bill Medicare Part B for more than $30,000 a year or provide care to at least 100 Medicare beneficiaries annually. There are two pathways for eligible clinician participation in MACRA's Quality Payment Program: the Merit-Based Incentive Payment System, or MIPS, and the Advanced Alternative Payment Model, or Advanced APM. MIPS is the less predictable model, and already has many healthcare organizations nervous. Because scores under the MIPS payment track will be made public, crafting the right strategy for participation is vital not only to the financial health of provider organizations, but also their reputation. A breakdown of the MIPS payment track MIPS replaces the disjointed requirements of three legacy CMS programs. Under MIPS, physicians will be scored on performance in four categories: quality, which replaces the Physician Quality Reporting System; cost, which replaces the Value-Based Payment Modifier; advancing care information, which replaces Meaningful Use; and clinical practice improvement activities, which is a new category. A clinician's score in each of those categories is consolidated into a final composite score that CMS will use to make payment adjustments in 2019 and subsequent years. Payment adjustments in the first year will be positive or negative up to 4 percent. This will incrementally climb to 9 percent by 2022. "The program is budget neutral, so CMS doesn't really know how much it can pay out in bonuses until it understands what the penalties will be," said Lonnie Johnson, vice president of corporate services at Zotec Partners, a specialized medical billing and practice management services provider. Clinicians and provider organizations participating in the MIPS payment track will be scored against benchmarks on a 100-point scale, with 100 being the best score possible. There's an exceptional bonus pool of $500 million to be distributed to those who receive a score of 70 or above. For 2017, which is the first performance year, the MIPS categories are weighted as follows: • Quality — 60% • Advancing care information — 25% • Improvement activities — 15% • Cost — 0% CMS will provide informational feedback to clinicians on how they performed on certain aspects of cost category in 2017, but performance will not affect 2019 payments. In the 2018 MACRA proposed rule, CMS proposes to, again, change the weight of the cost performance category from 10% to 0% for the 2020 MIPS payment year; as they continue to have concerns about the level of familiarity and understanding of cost measures among clinicians. The cost category is scheduled to be weighted at 30 percent of the MIPS final score in the third performance year. However, CMS is seeking comments from the proposed rule on keeping the weight of the cost performance category at 10% for the 2020 MIPS payment year, so as not to have a dramatic transition to the weighting from zero to 30%. In 2017, full MIPS participation requires clinicians to report six measures in the quality category or one specialty- specific measure set, report five measures in the advancing care information category and participate in two to four improvement activities (depending on the selection of medium of high weighted activities). Providers can choose from a number of options available for submitting data, including using a qualified clinical data registry, qualified registry, EHR, administrative claims or attestation. Some of the options vary based on performance category. Not all clinicians are required to participate in the MIPS payment track. Clinicians are exempt from MIPS participation if they are in the first year of Medicare Part B participation, are qualified participants in the Advanced APM pathway or do not meet the threshold for MIPS participation — meaning they treat less than 100 Medicare Part B beneficiaries and bill less than $30,000 in Medicare Part B allowed charges per year. MIPS participation in the transition year The final MACRA rule offers flexibility by allowing providers to pick their pace for participation. Under the final rule, clinicians and provider organizations participating in the MIPS payment track can opt out of sending data to CMS in 2017. However, those who do not report 2017 data will experience a negative payment adjustment of up to 4 percent in 2019.

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