If you are a Merit-based Incentive Payment System (MIPS) eligible provider who took a few years off from MIPS between 2019 to 2023, this blog is for you. Whether it was COVID-19 or other Extreme and Uncontrollable Circumstances (EUC), returning to MIPS could be significantly challenging after a hiatus. In this post, we'll explore why it can be advantageous to participate in MIPS and strategies for returning to the program.
MIPS Refresher
First, let's refresh what MIPS is and why participation is crucial for healthcare providers. MIPS is one of the key components of the Quality Payment Program (QPP), which aims to incentivize healthcare providers to deliver high-quality care. Through MIPS, eligible clinicians earn payment adjustments (positive or negative) based on their performance in four categories: Quality, Promoting Interoperability, Improvement Activities, and Cost. If you are a MIPS eligible clinician, failure to submit data will result in a -9% payment adjustment to your Medicare Part B reimbursements for an entire year.
What Allowed for a Break from MIPS
Participating in MIPS allows healthcare providers to demonstrate their commitment to delivering value-based care, which is increasingly important in today's healthcare landscape. However, sometimes circumstances make it impossible for providers to participate in MIPS for an extended period. CMS allows providers to opt out of MIPS either in part or in entirety by filing an Extreme and Uncontrollable Circumstances (EUC) exception to accommodate for these unforeseen events.
These circumstances could include personal health issues, EHR deficiencies, cyberattacks (hacks), natural disasters, or other unforeseen events. From 2019 to 2023, COVID-19 was the most prominent reason cited for the EUC exception. Eligible providers have leveraged these exceptions for the past five years as applicable to their situation.
The New World of MIPS
While these exemptions offered much-needed relief during challenging times, returning to the MIPS program after a 1-5-year hiatus can pose its own set of challenges. Providers may feel overwhelmed by the prospect of catching up on missed reporting requirements and meeting new and more rigorous performance targets. Additionally, the MIPS program has undergone multiple changes over the last few years.
Quality Category
Category weight has been reduced from 60 points to 30 points of the total 100 points possible.
Several measures have been modified, removed, or have more stringent specifications, making it necessary to reevaluate the measures that apply to your practice and patient mix.
Steeper measure benchmarks make it harder to achieve higher scores.
Promoting Interoperability (PI) Category
“July 1, 2024, marks the last available 180 consecutive-day reporting period for the 2024 performance year. ”
The reporting period is increased to 180 continuous days for 2024 from the previous 90-day requirement. More time is required to demonstrate the meaningful use of a certified EHR.
The attestation portion of PI has increased from just the Security Risk Analysis (SRA) to include the additional attestation element, to complete the Safety Assurance Factors for EHR Resilience (SAFER) Guide.
Additional measures have been included:
Prescription Drug Monitoring Program (PDMP) under e-prescribing
Health Information Exchange – to include participation in the Trusted Exchange Framework and Common Agreement (TEFCA) program
Public Health – Electronic Case Reporting (eCR) in response to the COVID-19 pandemic
Improvement Activities (IA) Category
It's crucial to review the measures in the Improvement Activities category, as they may have changed since your last report.
The reporting period remains at a minimum of 90 consecutive days, and the scoring method and weights for Improvement Activities are unchanged at 25 points.
For practices with two or more providers, at least 50% of the providers must report on the same Improvement Activities.
Cost Category
This category has increased from a zero initial value to 30 points out of 100.
CMS has added additional population and or episode-based measures (29 total), that could trigger a specialty’s attributed Cost scores.
At the beginning of MIPS, most ambulatory specialties were free from a Cost score due to the lack of attribute events. Starting in 2023, an increased number of episode-based Cost measures has resulted in more frequent triggered attributes for more ambulatory specialties.
Why Return to Reporting for MIPS?
MIPS offers the opportunity to earn incentives if you score well. However, failure to submit data will result in a negative payment adjustment (-9%) on your Medicare Part B reimbursements for an entire year.
Seven Steps to Reboot Your MIPS Strategy
We have outlined seven steps providers, and practice administrators can take to ease the transition back into MIPS participation.
1. Assess the Situation: Start by assessing where you stand in terms of MIPS eligibility requirements. Review any communications from the Centers for Medicare & Medicaid Services (CMS) regarding changes to the program during your time away from MIPS.
2. Update Knowledge: Stay informed about any updates or changes to MIPS requirements and reporting mechanisms that may have occurred during your hiatus. This could include changes to performance measures (in Quality, Promoting Interoperability, Improvement Activities, and Cost categories), what your EHR can or will handle, reporting methods, or eligibility criteria.
3. Seek Guidance: Don't hesitate to seek guidance from professional organizations, peers, or consultants who specialize in MIPS participation. They can provide valuable insights and assistance in navigating the program's complexities. Darena Solutions has been offering end-to-end MIPS guidance since the beginning of MIPS in 2017.
4. Develop a Plan: Create a detailed plan outlining how you will meet MIPS requirements and improve performance in each category. Set realistic goals and timelines to ensure steady progress toward compliance.
5. Utilize Resources: Take advantage of available resources and tools CMS provides to support MIPS participation. These may include educational webinars, online tutorials, and technical assistance resources.
6. Monitor Progress: Regularly monitor your progress towards meeting MIPS requirements and achieving performance goals. Adjust your plan as needed to address any challenges or obstacles that arise.
7. Stay Engaged: Stay engaged with MIPS-related updates and developments to ensure ongoing compliance and optimization of performance. Participate in relevant training opportunities and stay connected with professional networks for support and guidance.
Returning to the MIPS program after a gap may seem daunting, but with careful planning and dedication, healthcare providers can successfully reintegrate and continue their journey toward delivering high-quality, value-based care. By staying informed, seeking support, and taking proactive steps to meet MIPS requirements, providers can ensure that they remain on track to achieve positive outcomes for their patients and practices.
Our team has been guiding providers and practices across various specialties and sizes in meeting their MIPS requirements from the program's inception. As a CMS MIPS Qualified Registry, we enhance our support through MIPS White Glove Services, which handles everything from data acquisition and measure recommendations to data submission to CMS across all MIPS performance categories. This integrated approach allows us to offer comprehensive guidance and support.
July 1, 2024, marks the last available 180-consecutive-day reporting period for the Promoting Interoperability category. If your organization intends to participate in MIPS 2024, you must act now.