Looking at MIPS Through A Different Lens: From Compliance Burden to Change Enabler

By Tom S. Lee, PhD, Founder & CEO, SA Ignite
Twitter: @saignite

Incentive focused programs such as PQRS and Meaningful Use created opportunities for providers to benefit financially from submitting quality data and attesting to meaningful EHR use, respectively. Because these programs were initially voluntary, providers could choose (or not) to take on their data submission related compliance burdens.

Then MIPS came along and changed everything. MIPS creates both a compliance burden and potential financial penalties in the form of downward reimbursement adjustments. (Of course, for high performers, there is potential upside, too.) If a provider organization subject to MIPS chooses not to comply (not to submit data), its score will be zero and it will be penalized.

It is tempting to think of MIPS as a compliance exercise, with an associated material administrative burden. It is also tempting to think of it as a zero-sum financial incentive program, where high performers win and low performers lose.

But what if MIPS is more than that? What if the program can be looked at through a different lens – a lens through which you can see a future that is very different from today? Learn how some healthcare organizations are making MIPS a change-enabler.

In the future, provider organizations will be subject to many value-based programs issued by government and commercial payers. These programs will have diverse rules, reporting requirements, measurement systems and financial models. Some will be voluntary. Most will not. Some will offer incentives. Many will impose penalties as well.

A number of our customers are now subject to more than a dozen value-based programs. One organization is managing participation in more than 20. The trend towards program proliferation shows no sign of abating. If anything, it is accelerating.

The proliferation of value-based programs will change providers fundamentally. As these programs take hold, they will force providers to change their business and financial models, their operating and management systems and their cultures. In other words, fee-for-service thinking and execution will not deliver success in a value-based world.

But, how will (and how should) this change happen? Will it happen by fiat? By hiring a consultant? By deploying technology? By restructuring the organization?

We believe that change happens one insight, one decision, one action and one result at a time. In other words, incrementally. It is difficult to observe day-by-day, and it certainly doesn’t happen with heavy handed tactics. It happens via collaboration, communication, trying, failing and experiencing. It reveals itself in the evolving views and language of every stakeholder in the organization. It is not easy. We reveal how some healthcare organizations are making MIPS a change-enabler.

So, what role can MIPS play in helping an organization change to deal with challenges of a value-based world? The program is constructed with all the features of a two-sided risk program that requires improvement on multiple dimensions (quality, cost, interoperability, generalized improvement activities). But, it also gives provider organizations room to experiment and drive change. In the early years of the program, MIPS’s penalties are relatively easy to avoid: there are few losers and almost every organization wins at some level. This gives providers space to understand their current performance and begin to engage their stakeholders in a conversation about performance (and change).

Tactically, MIPS allows organizations to choose just one or two things to focus on. It enables them to try and fail, with relatively low consequences. Crucially, it allows them to build “muscle memory” around the relationship between cost and quality, setting goals and attempting to meet them, engaging clinicians in conversations about performance and a host of other capabilities that providers will need to perform in value-based care.

And, because MIPS is designed to intensify over time through full program rollout in 2022, providers can develop these capabilities gradually and ratchet their sophistication in concert with the increasing financial consequences.

We wouldn’t go so far as to suggest that MIPS is a change agent. Change agents can only be organizational stakeholders. But, we do think that it would be helpful for providers to stop thinking of MIPS as a compliance burden and to start thinking of it as a “change enabler.” How could your organization prepare itself for the future if it looked at the program through that lens?

This article was originally published on SA Ignite and is republished here with permission.