As you think about your practice in 2020, you may be considering how to maximize your Medicare payments through the Merit Based Incentive System (MIPS). At the 2019 Annual Assembly of the American Association of Physical Medicine and Rehabilitation (AAPM&R), Mark Huang, MD, and Robert Jasak, JD, presented a session titled MIPS 2020: Preparing Your Practice for Reporting and Strategies to Improve Performance.
According to them, most Physiatrists will report under MIPS which has a direct impact on future Medicare payments. The program is updated annually, and 2020 performance will adjust Medicare payments anywhere from a 6.2 percent increase to a 9 percent decrease in 2022, so this is a long game.
It’s also important to remember that MIPS is not an all or nothing proposition, so there is value in completing what you can and reporting it, even if you can’t achieve all of the benchmarks.
Who Is Excluded from MIPS?
First things first: are you even required to report for MIPS? Jasak explained that if your volume of Medicare patients is low, you may be excluded from MIPS in 2020. The low volume threshold now stands at fewer than 200 Medicare patients or less than $90,000 in Medicare revenue. Check your tax ID on the CMS site to determine if you are required to participate, as about 45 percent of physicians will be excluded with no requirement to report.
Know the Changes to the Reporting Categories for 2020
If you determine you are required to report, there are four areas CMS will evaluate in 2020 to determine any increase or decrease in your payments in 2022. They include:
Scoring weight: 45 percent
Clinicians are asked to report on six quality measures found in the 2020 Specialty Measure Set. However, fewer measures may be reported for partial points. Any quality measure must be reported for at least 20 patients and at least 70 percent of the patients to which it applies. Further, it must be reported for the full twelve months of 2020. Again, if you are not able to report on 20 patients, partial points will be assigned for reporting on fewer patients.
2. Promoting Interoperability
Scoring weight: 25 percent
This measure is based on EHR meaningful use. Hospital-based providers are not required to report on this measure, and the category weight is shifted to the “Quality” category.
Scoring weight: 15 percent
This measure has no affirmative reporting requirement. CMS will score cost based on administrative data. Medicare has reconfigured its Medicare Spending Per Beneficiary (MSPB) with two goals:
- “Ensure attributed clinicians are responsible for a patient’s care during an episode.”
- “Remove services not clinically related to the underlying reason for the index admission.”
4. Improvement Activities
Scoring weight: 15 percent
This measure will be required, and as Jasak explained, most physicians will need to report on four activities. Smaller and rural groups may only be required to report on two. Beginning in 2020, CMS requires that at least 50 percent of group members report on an improvement activity for points to be awarded. A group can no longer benefit from the improvement activities of a single member. This will require some planning by the group to ensure all four activities have the appropriate participation and reporting.
After each of these measures is calculated, a final score of zero to 100 will be assigned to each provider. Those with a score of 45 will have no adjustment in 2022 payments. Scores above 45 will receive a positive adjustment on payments in 2022, estimated to be greater than zero and less than 6.2 percent depending on how far above 45 the score is. Those with greater than 85 are eligible for an exceptional performance bonus as well.
On the other end of the spectrum, those with scores below 45 will have a negative adjustment to their pay, maxing out at a 9 percent decrease for scores at or below 11.25 points.
Reporting for MIPS certainly adds some complication to the administrative side of medicine. But with substantial increases or decreases at stake, it literally pays to get it right. AAPM&R offers staff and resources to help you get MIPS right in your practice, so be sure to use the resources available to you and don’t leave money on the table.