Most of us who have been in the business of healthcare for 5 years or more are familiar with the term “Meaningful Use.” For others, let me define “Meaningful Use” at it will serve as the basis for this blog. Meaningful Use was a program implemented by the governmental agency, “Centers for Medicare and Medicaid Services” (CMS) to measure and reward medical practices for the use of Electronic Health Record (EHR) technology. EHR is the software a medical practice uses to manage its business and store all Protected Health Information (PHI). I believe Meaningful Use was a success. It brought a much greater awareness to EHR technologies, and pushed practices small and large to evolve, and store their PHI electronically. Storing information electronically in turn allowed medical practices to provide a better level of service, care coordination and sensitive data security to its patients.
You may have noted I used 3 three letter acronyms (TLAs) in the first paragraph. This comes with working with information technology and is multiplied by government bureaucracy. There are plenty more to come, so I will document the rest up front, right now!
1. MACRA- Medicare Access and Chip Reauthorization Act
2. QPP- Quality Payment Program
3. APM- Alternative Payment Model
4. MIPS- Merit-Based Incentive Payment System
5. EC- Eligible Clinician
The next year brings the sequel to Meaningful Use, MACRA and the payment system within it: MIPS. The QPP final rules were posted on November 2, 2017 giving participants two months before reporting starts on January 1, 2018. Nearly all healthcare providers, physicians, physician assistants and nurses must participate. The scoring for MIPS will be based on a point system, look for future BLOG’s to take a deeper dive on MIPS including the point system.
A practice that bills Medicare Part B* claims in an amount less than $90,000 or has fewer than 2,000 Medicare claims is not required to participate. The smaller practices that do report receive some breaks; groups from 1-15 clinicians get an automatic 5 points, even if completing the minimum amount of reporting. Groups of 1-10 clinicians can team up with other smaller groups to combine reporting, regardless of location or specialty. This will allow some “rock-star” practices to report with lesser groups allowing all to benefit from the payment program.
MIPS reporting for 2018 will be divided into 4 categories, each of which will have a different weighting. Additionally, the weighting percentages are set to change in years 2019 and 2020. The following are the four reporting categories and their weights:
- Quality (60%) – The practice selects at least 6 measurement criteria to report on from a choice of over 300. Some are general categories and some are for specialty practices. For example, a cardiologist may report on measurements for controlling high blood pressure among all their patients. Quality is the only category that must be reported on for the entire year.
- Advancing Care Information (25%) – ACI includes all the measurements that were a part of Meaningful Use. It measures how the practice promoted patient engagement (patient portal) and exchanged information using EHR technology.
- Improvement Activities (15%) – The primary focus on Improvement Activities will be on care coordination, which is the ability to work seamlessly with other providers. Additionally, providers will have a list of over 900 categories and 9 sub-categories to report on.
- Cost (no mandated reporting in 2018) – This information will be based on data from Medicare claims received.
MIPS reporting options for 2018
- Option 1 – Submit “some data”- Quality is the only data that must be reported for the entire year. Enough data for 15 points must be reported.
- Option 2 – Quality full year – Submit Quality full year, Advancing Care Information and Improvement Activities for 90 days.
- Option 3 – All categories full year- Cost not reported in 2018
A practice can pick any of the options they choose, most likely it will be driven by their understanding of the program and the resources they assign to it.
More will be revealed on MACRA, MIPS and the best practices for reporting in the coming months. Due to the consequences of failing to report, and the urgency of a short preparation period, many healthcare organizations will need assistance with reporting. MIPS has much greater consequences than Meaningful Use.
First, all information submitted for reporting will be public. We will see reported information on CMS websites allowing you to compare providers, like we look at online reviews for traditional business today. Secondly, MIPS does more than just reward compliant practices, it also penalizes non-compliant ones. Meaningful Use was initiated as an experiment to some extent. MIPS seems to be making the transition to a regulation that is here to stay. Healthcare organizations will either need to get on board or face serious consequences.
Given the importance of MIPS to the healthcare industry, and the continued flow of information to this day, we will provide another update to this before year-end. Please look for a deeper dive on MIPS information including components not covered here, like how the points system works and Alternate Payment Methods (APM), that will become more important in the years to come.
*Medicare Part B is the portion of Medicare that pays for ambulatory services such as doctor office visits and prescriptions. Part A applies to hospital stays.
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