As the Merit-Based Incentive Payment System (MIPS) program is entering the 4th year, organizations are compelled to re-evaluate the way they address their plan of action. The 2020 Performance Year has the most aggressive thresholds yet for avoiding the penalty, as well as for achieving the incentives. Additionally, since CMS had gone live with publishing the Quality results from MIPS on the Physician Compare website, the MIPS performance will impact the professional ratings of your organization. Given this scenario, it is worthwhile for organizations with MIPS eligible clinicians to evaluate the advantages of working with a MIPS Consultant who can help to successfully navigate the significantly increased MIPS challenge.
In this blog, I will take you through the steps to evaluate the Return on Investment (ROI) of engaging with a MIPS Consultant for the 2020 MIPS Performance Year. In other words, is it worthwhile for your organization to invest in a MIPS insurance policy?
The Ascent Up the MIPS Mountain: Risks and Requirements
Let’s take a detailed look at how MIPS has changed for 2020 Performance Year. Over the years CMS has raised the “incline” that an Eligible Clinician (EC) is required to accomplish in order to avoid an ever-increasing financial penalty. The major upgrades to the program are as follows:
For the 2020 Performance Year:
The penalty for not reporting MIPS data is -9% vs -7% for 2019
The need for a MIPS Composite Score of at least a 45, vs 30, to avoid the -9% penalty
The need for a Composite Score of at least an 85, vs a 75 in 2019, to get included in the Exceptional Performance bonus pool.
You must have a Data Completeness of 70% for the quality measures vs a 60% in 2019, to be evaluated based on the benchmarks. Below 70% will score a 3 on the measure for small practices and a Zero for Group practices with >15 ECs.
The Quality Measures have the annual benchmark adjustments. This means the measure you reported in the past may not score as well in 2020.
5 bonus points in PI for having signed opioid agreements with patients has been removed for 2020. So, ECs will need to make up for these points in other ways.
The Physician Compare Website is now active and reporting MIPS Quality Performance scores. All Quality Category scores (good or bad) are available for review by patients. Additional information is publicly available in the form of a downloadable database which could be utilized by other Payers and Physician ranking websites.
Source: Physician Compare Website
Top MIPS Challenges Faced by the Healthcare Organizations
The items listed below have been known to keep senior management up at night. How many of these apply to your organization?
You have received monthly Explanation of Benefits (EOBs) with a negative MIPS payment adjustment code CO237 due to not submitting MIPS data for a prior MIPS Performance Year
Not sure which Quality measures are the best fit for the provider specialty-mix of your organization
Your organization has multiple providers who are close to the $90,000 Medicare Part B reimbursement threshold and could benefit by reporting as a Group, but you are unsure how to evaluate this reporting option
Unsure of how to evaluate the impact of changes to the MIPS for 2020 Performance Year on your organization
Wondering what the deadlines are for submitting MIPS data and the format required for submission
Need guidance on the documentation required to survive a MIPS audit
Considering selling your practice and need to get it acquisition-ready from MIPS perspective
If you can identify with any of the situations above, you need to consider if it is worth the cost of engaging services of a MIPS consultant. Most likely you will see a rapid ROI.
Don’t have a lot of time? We’ve summarized key points of the blog with a quick video.
Is it Worth Engaging a MIPS Consultant?
To adequately assess whether your organization will benefit from utilizing MyMipsScore and realize quick return on your investment, you need to consider the following:
What kind of effort in terms of time and money is required for keep your staff’s education updated on ever changing MIPS terminology, thresholds, benchmarks, and rules?
What is the amount of internal staff involvement needed throughout the year to manage and maintain your MIPS status? Will a MIPS Consultant reduce that FTE requirement for you?
What’s the cost of not participating in MIPS for your organization (Negative 9% payment adjustment on Medicare Part B reimbursements in 2022)? It would be $8,100 for Low Volume Threshold of $90,000 in 2022. Determine what’s at stake for your organization with our FREE MIPS Calculator.
How much do you stand to earn in positive payment adjustments if you exceed the Exceptional Performance Threshold of 85 points? The incentives become meaningful only after crossing the exceptional performance threshold. Each point increase will affect your positive payment adjustment significantly. Is the potential difference in incentive worth getting a MIPS expert’s advice? Use free MIPS Calculator to determine your potential incentive payment.
Does your organization have more than 15 MIPS eligible clinicians? If yes, do you have a MIPS strategy in place? Large group practices or provider organizations have the risk of substantial financial and reputational exposure which can be reduced by a focused effort on developing, implementing and managing a well thought out MIPS strategy.
Do you know that MIPS scores are published on the Physician Compare website open to public? What is your organization’s reputation worth to you?
Your MIPS Consulting Options
If you find that using some MIPS assistance would be beneficial for your organization, there are several MIPS Consulting models available to you. You can choose from a monthly charge for basic services to a tiered approach as you add features. There are even submission-only options. The 2020 Performance Year has increased the degree of difficulty to a new level. Additionally, the out years of 2021 and 2022 get even more difficult. To that end, engaging with a MyMipsScore Consultant will offer a complete full-service program that covers all the aspects of MIPS reporting, from determining eligibility to MIPS data submission.
Our Unique Approach
MyMipsScore combines subject matter expertise with analytics by using our unique MyMipsScore™ app to assist in developing the best strategy to achieve your financial and care-quality goals for the performance year.
Understand the Financial Stakes
You can use our FREE MIPS Calculator to get an estimate of the dollars involved for your organization.
Free MIPS 2020 Calculator for Estimating Payment Adjustments
Stakeholder Education to Build Awareness
The full-service covers education of the staff and other stakeholders in the process. Awareness of what the stakes are and what it would take to cross the exceptional performance threshold leads to more coordinated effort often resulting in surpassing the MIPS score goal.
Determine the Collection Type and Measure Mix for Quality
We help you with selecting the best combination of collection types and measures for the Quality category that best fits your organization’s patient mix. This can be tricky for multi-specialty practices.
Manage Reporting for Multi-Location and Multi-Specialty Practices
Our MIPS experts can help you address the unique challenges that come with managing multiple locations spreading over a city or state(s). MyMipsScore’s robust analytics will help you find the best approach to MIPS for each location.
Audit-Proof Your MIPS Submission
The process would not be complete without the creation of a Book of Evidence to maintain the proper documentation of the MIPS data and the results from submission. This provides a level of “audit-proofing”. Audits are random, however, having proper documents readily available when audited will make the audit process quick and smooth for you. MIPS submission audits can happen anytime from immediately after submission to several years after the fact.
Let MyMipsScore Consultant be Your MIPS Sherpa
A MyMipsScore Consultant can be your Sherpa who will assist in the ever-increasing climb up and over MIPS mountain and will carry the burden of MIPS planning, ongoing analysis, course corrections, data submission and documentation for you. You will get to work with someone who is well versed with the MIPS terrain and utilizes the best tools to help you maximize your incentives for current and future years. The combined power of expertise and tools will help you realize quick ROI on your MIPS investment.
