MIPS Honeymoon Period is over and Minimum Performance Bar is Increasing
2019 has been a busy year for CEDR and its participating physician practice groups!!
CEDR continues to become an ever more important tool to demonstrate quality and reimbursement of emergency care, as CMS has been raising the bar for Merit-based Incentive Payment System (MIPS) compliance. The first 2 years, 2017 and 2018 were declared as “Pick Your Own Pace” years by MIPS, aka Honeymoon Period. Now that the “pick your own pace” period is over, challenges have started to emerge with requirements for higher scores to avoid penalty, a rising penalty threshold (from 5% to 7% and 9%), and the topping-off of a significant number of quality measures.
As an individual practicing emergency physician, let us figure out what is at stake and how do we get better prepared.
The key questions– is MIPS likely to go away?
The Medicare and CHIP Reauthorization Act (MACRA) is the law that was passed by Congress in 2015 to replace the Sustainable Growth Rate (SGR). This law was passed with strong bipartisan support (which is rare in Congress these days). MACRA is here to stay and the SGR is not coming back. Take it or leave it – it is the law of the land. MACRA establishes a strong foundation for value-based programs, where patient-centered, outcome-based quality will be the key measure of success.
Congress has given eight years for CMS to gradually implement value-based systems to create a healthy mix with a transaction-based/claim-based culture. 2015-2016 were the planning years. 2017-2023 are the implementation years. CMS has named MACRA implementation as a Quality Payment Program (QPP). QPP has 2 tracks:
- Alternative Payment Model (APM)
Both MIPS and APM are continuing to evolve. The roll-out has been slow and often confusing. Our choice is to either sit on the sidelines and criticize CMS or become their trusted advisor to influence a QPP program roll-out that reshapes our specialty for success. We (ACEP) have decided to take the latter approach.
MACRA requires CMS to achieve national mean/median of performance by the 2023 performance year for quality scores and associated payment adjustment. They started with a low bar to avoid penalty. Starting at 3 points out of 100 in 2017, 15 in 2018, 30 in 2019, 45 in 2020, and getting to 60 in 2021 and maybe 75 in 2022. Our stakeholders need to realize that the honeymoon period is over. The stick is getting longer, and its impact is likely to be harder.
In closing, MIPS continues to evolve into a complex value-based purchasing program. It is often very confusing and difficult to understand. The Quality team at ACEP is here to help you. Please do not hesitate to call us and discuss your options. You do not have to participate in CEDR to seek advice. There may be other options suitable to your individual needs. ACEP is your organization and dedicated to your success in skillfully navigating through complex quality reporting requirements. We are just a phone call away and hoping to hear from you soon.
Dr. Pawan Goyal MD, FHIMSS, FAHIMA
ACEP Associate Executive Director, Quality