June 13, 2022

Emergency Medicine is a Team Sport

Emergency medicine is a team sport. Our recent work supports that reporting quality measures as a team or group substantially benefits emergency clinicians. Clinicians reporting in groups or as part of an alternative payment model had significantly greater overall quality measure performance scores and resultant payment adjustments than clinicians reporting as individuals.

As background, most emergency clinicians participate in the Merit-based Incentive Payment System (MIPS), a CMS pay-for-performance program enacted in 2015 and intended to promote the shift to value-based care. CMS designed MIPS to measure clinicians across four key performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Weighted performance within these four categories is rolled up into an overall score that translates into an exceptional, positive, neutral, or negative payment adjustment two years after the performance period. Starting in the 2020 performance year, the bonus or penalty for not meeting MIPS requirements could be as high as 9% of Medicare Part B reimbursements. For a typical group staffing an 80,000 visit/year ED, prior estimates have suggested that this amount could represent upwards of $200,000.

In our work assessing the most recently available 2018 performance year, 1,246 EM clinicians reported to MIPS as individuals, 43,404 reported within a group, and 15,178 reported within a MIPS alternative payment model. Clinicians reporting within MIPS alternative payment models are often part of an entity under an agreement with CMS yet do not need to meet the more stringent criteria of taking on financial risk as in advanced alternative payment models. MIPS median overall performance scores were greatest among those reporting within MIPS alternative payment models (100.0), followed by group affiliation (88.4), and followed by individual affiliation (30.8).

As a result, only 12.0% of individual clinicians received a bonus for exceptional performance, while 19.0% incurred a penalty (or negative payment adjustment). Of those reporting as a group, 65.1% received a bonus for exceptional performance, while only 0.5% incurred a penalty. Of those reporting within a MIPS alternative payment model, 99.8% received a bonus for exceptional performance, while no clinicians incurred penalties.

During the 2018 performance year, we additionally identified that >99% of emergency clinicians received either a positive or exceptional performance payment adjustment. This exceedingly high number receiving a bonus is in the setting of a relatively newer program at the time attempting to ease clinicians in with a lower threshold for meeting reporting requirements. In 2018, the MIPS overall performance score required to avoid a penalty was only 15, with the required score being raised substantially to 75 in the 2022 performance period. Given that the MIPS is a budget-neutral program and that the vast majority met the low threshold, bonuses to clinicians for the 2018 performance year were capped at +1.7%, while penalties could be as high as 5%.

As thresholds rise in current and future performance years, emergency clinicians may be prudent to consider the benefits of reporting to the MIPS program within groups or as part of alternative payment models. Just as an extra clinician helps you with a difficult airway, bringing the team into your MIPS reporting may be the ticket to success.