By Renee Freyer, MIPS Advisory Services, Verana Health
LinkedIn: Renee F.
LinkedIn: Verana Health
The Merit-based Incentive Payment System (MIPS) was established with great motives: improve healthcare, reduce costs, and promote efficient use of healthcare information by tying Medicare payments to clinician performance.
Like any large program, MIPS evokes a range of opinions and perceptions, even misconceptions. MIPS was designed to use both a carrot and stick approach to encourage medical practices to provide higher quality care at a lower price. It is also designed as a revenue-neutral program funding the positive adjustments from the negative adjustments.
To participate in MIPS, providers fulfill reporting requirements across four categories (Quality, Promoting Interoperability, Improvement Activities, and Cost). For some practitioners, the associated administrative tasks can feel bureaucratic at times, like checking boxes.
But there are clear benefits to be gained from the program – both by patients and medical practices.
In fact, the value that practices realize from MIPS can be related to how they approach the program. An important question for any practice to consider is, “Are we maximizing our opportunity with MIPS?”
To Participate or Not to Participate?
While participation in MIPS is not compulsory for practices earning below the threshold specified by the Centers for Medicare & Medicaid Services (CMS), there can be consequences of not participating.
Practices that choose not to participate in MIPS may be at risk of the following:
Negative Payment Adjustments: Eligible clinicians who choose not to participate in MIPS or fail to meet the reporting requirements risk receiving negative payment adjustments. These penalties can result in reduced Medicare reimbursements, impacting their revenue streams.
Missed Opportunities for Improvement: By not participating in MIPS, providers miss out on the chance to gain valuable insights into their performance and areas that need improvement. The lack of feedback and benchmarking data may hinder their ability to optimize patient care and operational efficiency.
Loss of Competitive Advantage: In an era where quality and value-based care are highly regarded, providers not participating in MIPS may find it challenging to remain competitive in the healthcare market. Patients and payers may gravitate towards providers with proven track records of delivering high-quality care.
Limited Resource Allocation: Providers who neglect MIPS may allocate fewer resources to quality improvement initiatives and health IT integration, potentially hindering their long-term growth and adaptability in the changing healthcare landscape.
For all these reasons, practices earning below the threshold often opt to participate to increase potential reimbursement and capitalize on associated benefits.
Common Misconceptions about MIPS
With frequent changes and updates to MIPS regulations (including adjustments to reporting requirements, quality measures, performance thresholds, and payment adjustments), medical practices must make a concerted effort to stay informed and adapt their reporting practices accordingly.
It’s also important for practices to avoid common misconceptions about the program. Two of the most significant misconceptions relate to MIPS documentation and forgiveness of mistakes.
Many clinicians think they only need to complete MIPS documentation for Medicare patients. This is not true. Though it is just Medicare patients whose reimbursements are directly tied to MIPS performance, the calculation is based on all measure-specific eligible patients regardless of the payer. Providers must submit MIPS documentation for all patients.
Another common misconception is the idea that CMS will extend leniency during audits for honest mistakes that practices make related to lack of comprehension of regulatory details. Again, this is not true. Though MIPS measures and rules can be complex and changing, responsibility for keeping abreast of and understanding the current regulatory landscape lies entirely with the practice.
Changing Perceptions: From Burden to Benefits
Many medical practices, particularly small and independent practices, perceive MIPS as a significant burden. The program’s reporting requirements are often seen as complex and time-consuming, leading to increased administrative costs and a perceived focus on compliance rather than improving patient care.
However, understanding the importance of MIPS and how it supports better patient care can be a valuable transition for clinicians.
For example, Measure 130 in the Quality category (Medication Documentation Attestation), may seem on the surface like just another box to check, but it’s really about patient safety. Having an accurate and up-to-date medication list helps avoid potential drug interactions – ensuring not just compliance but also good clinical care.
Viewed from this perspective, MIPS fundamentally supports clinicians in their primary focus: delivering safe, high-quality care.
What About MVPs?
One example of MIPS evolution is the MIPS Value Pathways (MVP), a new, voluntary reporting option for clinicians as an alternative to traditional MIPS or the APM Performance Pathway (APP). MVP reporting has reduced complexity compared with traditional MIPS, particularly within the Quality category, which groups related measures by specialty or condition, making it easier for clinicians to report on what’s most relevant to their practice.
In fact, if a practice reports on both MVPs and traditional MIPS, CMS will apply the higher of the two scores.
Benefits of MIPS Reporting for Medical Practices
By incentivizing quality care, promoting transparency, and aligning with value-based principles, MIPS empowers providers to enhance patient outcomes and financial performance.
In addition to supporting better patient care, MIPS can help healthcare providers improve reimbursement adjustment rates and access additional funding. It also encourages the adoption and refinement of healthcare IT, leading to enhanced decision-making, reduced inefficiencies, and a stronger industry reputation.
In essence, MIPS incentivizes quality and cost-efficient care, drives improvements in care processes and health outcomes, and reduces the cost of care.
The Road Ahead: Less Burden, Better Patient Care
With the right approach to MIPS, providers can enhance patient outcomes and financial performance, through improved reimbursement rates, access to additional funding, refinement of IT, enhanced decision-making, and reduced inefficiencies. The guidance of an experienced advisor to navigate the challenges of MIPS can be invaluable to a medical practice.
Practices want to report on measures that make sense clinically – and give them the best chance to score well – but with MIPS rules, scoring, and measurement requirements changing annually, it can be tough for practices to know exactly where to focus and how to choose the right measures. Even when performance is strong, data may not always flow correctly from the EHR, so identifying any mapping issues early is key to getting full credit for the work being done.
EHRs have come a long way in helping practices by alerting them when MIPS documentation is done for the right patients. But the way these alerts work can vary. Some systems are better than others at making those notifications clear and helpful. And these alerts don’t always cover every measure, especially if a practice is using customized ways of reporting or using a Qualified Clinical Data Registry (QCDR) registry, which may have additional Quality measures available.
MIPS matters; It is integral to a medical practices operational success and reputation, but in light of the ongoing pressures to provide better standards of care, while being compliant with ever changing MIPS reporting mandates, leading medical practices are recognizing the value offered by MIPS advisory services, expert guidance which can help practices navigate complex reporting requirements and optimize performance scores.