By Polly Friend, RN
Providers have had two tracks of MACRA to choose from in 2017 – the merit-based incentive payment system (MIPS) and an advanced alternative payments model (APM). Most providers were, by default, placed in the MIPS program, and they put in a lot of hard work to avoid penalties during the uncertainty of MACRA’s first year. In 2018, there will be even more changes as we transition to full implementation by 2019 and beyond. Some of the new regulations for the second year include allowing providers multiple submission mechanisms within the ACI quality and improvement categories; an exemption allowance for practices with less than $90,000 in allowed charges for up to 200 patients in Medicare Part B; and the option of participating in MIPS as an individual or a group, including a new virtual group option.
As adjustments are being made to MIPS, action needs to be taken now, so providers can stay ahead of whatever curveballs are thrown. To some degree, physician practices will need to “build the plane while flying it.” The 2018 second-year rules were finalized on November 2, giving practices lead time to position themselves for success. After months of helping practices design and execute MIPS action plans, we’ve distilled the information gathered into the top three things medical practices can do to get ready for the 2018 MIPS/MACRA landscape.
1. Choose which measures to report on wisely.
Though there are over 270 MACRA measures available, many are specialty-specific, so not all will apply to your practice. Still, narrowing down which ones you will choose to report on can be complex. There are a few ways to approach this. First, it’s important to understand the definition of each measure. When choosing which measures to report on, your practice will be expected to report only on those that are applicable or relevant to the services you provide. For an in-depth look at specific measures that your practice will need to report on, CMS provides a helpful resource library. Additionally, the Early Implementation Review: CMS’s Management of the Quality Payment Program offers valuable insights that can help your practice understand specific MACRA measures.
Once you’ve narrowed the measures down to only those that you could be eligible for, you can turn to your billing data to identify the most frequently reported procedures and diagnosis codes, and look for measures that include those. Another good way of choosing measures is through patient eligibility. Use the analytics tools in your EHR, PM, and billing systems to look at the data of your patient population and identify which measures would apply to them. It’s important to avoid those that have less than 20 eligible cases because they’ll receive an automatic minimum score, regardless of how good your performance is.
When choosing measures for your practice, it’s important to understand not just which ones are applicable to you, but also which ones you can do well with. Setting your practice up for success under the new MIPS/MACRA laws requires some upfront legwork that ultimately will help you mitigate the risk of a penalty and increase your chance of receiving an incentive.
2. Make sure your clinicians are on board.
The shift toward a value-based healthcare system addresses more than just patient satisfaction and practice revenue. There’s also a heavy, albeit indirect, focus on physician burnout. Put simply, when your physicians are overworked and spread too thin, they won’t be able to deliver the best care to their patients. This directly impacts your MIPS score. Before finalizing the measures you’ll report on, it’s important to get your clinicians on board. They will understand better than anyone else which measures are appropriate for them, and which will allow them to best demonstrate the quality of care they provide. Physicians who have gone through rounds of Meaningful Use policies may feel resentment toward this latest set of changes under MACRA.
The ability and willingness of your staff to adhere to value-based care and strive toward the final measures should be weighted heavily. To encourage engagement and ownership, consider having a brown bag lunch session and soliciting ideas for making the transition a success. Another way to engage your providers is to have them brainstorm ways to track and show progress on the measures they’ll be reporting on. For example, they may want to see weekly reports or monthly posters on the practice walls. The way in which your providers want to show progress should be amply supported as another way to encourage participation.
3. Ask your EHR or vendor for help.
Once your entire team is on board with the MIPS measures your practice will report on, you can work with your EHR vendor to determine what documentation is needed. Most will provide you with the support you need so that you can submit the minimal requirements to avoid a penalty, and prepare a plan for next year to achieve the incentive.
One of the most important things your EHR vendor can provide is a guarantee program of some kind. CareCloud offered a 2017 MIPS Guarantee, which ensured clients received full assurance of avoiding penalties during the uncertainty of MACRA’s first year. With the higher threshold of activity that will be required in 2018 and beyond, guarantees like this aren’t as easy to support. Still, you don’t want to carry a double risk by paying for a technology that can’t support your needs while you’re also trying to navigate a program that has a lot of potential for change. Though you may not be able to get a no-penalty guarantee, your EHR vendor should offer some kind of protection on the technology side.
We don’t know what’s ahead with MIPS/MACRA in the year building up to what should be full implementation. Though uncertainty exists, we can still be ready. Taking action now to prepare for pending changes can help your practice mitigate the risk of a penalty and, ideally, work toward earning an incentive.
Polly Friend, RN is senior director of clinical strategy at CareCloud in Miami.
Published by: HIStalk Practice.