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At Your Defense

Ignore the MIPS Performance Measures at Your Peril

Reyes, Carlo, MD, JD

doi: 10.1097/01.EEM.0000554856.48906.66
At Your Defense

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As if EPs didn't have enough to deal with, MIPS is putting a bullseye on all of us.

The gist of the new system is that EPs will have to pay seven percent of their Medicare reimbursement back to CMS if they do not report their merit-based incentive payment system (MIPS) performance measures after the 2019 performance year.

This bipartisan program was started in 2017 to transform the Medicare payment system from volume-based to value-based. The rationale is that Medicare recognized that paying EPs based solely on the number of patients treated and procedures performed did not ensure quality medical care.

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A Zero-Sum Game

MIPS is basically a zero-sum game. High-performing MIPS clinicians get additional reimbursement under Medicare, while low performers have to pay the maximum penalty. To make matters worse, the penalty increases each year. By 2022, EPs who do not participate in MIPS will have to pay nine percent of their Medicare reimbursement. (See diagram.)

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An increasingly important determinant of physician reimbursement from Medicare is accurately reporting quality metrics. Qualified Clinical Data Registries (QCDRs) collect clinical information for patient and disease tracking, and are key to Medicare's new merit-based payment system.

The four MIPS performance categories are quality (50% of a clinician's MIPS score), promoting interoperability (formerly called advancing care information, accounting for 25%), improvement activities (15%), and resource use (cost; 10% of the MIPS score). The resource use category is automatically calculated from a clinician's claims submitted to Medicare; no reporting is needed. Importantly, 2019 is the first year that resource use will be factored into the MIPS score. (See graphic.)

Non-hospital-based physicians can select performance measures from each of the three reporting performance categories, but hospital-based physicians may select only from the quality and improvement categories because their promoting interoperability score will be weighted at zero. This shifts the percentage of scoring for EPs to 75 percent for quality, 15 percent for improvement activities, and 10 percent for resource use.

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QCDRs Can Help

The CMS-certified QCDR collects and reports performance measures under MIPS, and is usually run by a medical or specialty organization that has created performance measures tailored to the needs and interests of that organization. The difference between QCDRs and clinical registries is that QCDRs can write measures (so-called non-MIPS measures) that can be used once approved by CMS. QCDRs tend to be tailored to a particular specialty. One example is the clinical emergency data registry (CEDR) established by the American College of Emergency Physicians to enable reporting measures relevant to emergency medicine.

QCDRs provide several benefits for EPs, including guidance and expertise in MIPS reporting, maximizing MIPS composite scoring, and allowing MIPS and non-MIPS performance measure reporting. MIPS is admittedly daunting, but signing up for a QCDR can alleviate the fear of MIPS reporting and even maximize clinical performance metrics. More importantly, MIPS is not going away, and the potentially negative financial impact grows each year. Reporting to MIPS for the 2019 performance year is critical to preventing the seven percent reduction in Medicare reimbursement. That should be reason enough to sign up for a QCDR as soon as possible.

Dr. Reyes is the vice chief of staff and the assistant medical director of emergency medicine at Los Robles Hospital in Thousand Oaks, CA. He is also a clinical professor of emergency medicine and pediatrics at Olive View/UCLA Medical Center, a health law attorney with Boyce Schaeffer Mainieri, LLP, in Oxnard, CA, and the founder and CEO of Health-e-MedRecord, a patient-centered and emergency physician-designed EHR solution. (www.health-e-medrecord.com.) Follow him on Twitter @carloreyesmdjd, and read his past articles at http://bit.ly/EMN-Defense.

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