4 ways to prepare for MIPS now

4 ways to prepare for MIPS now

A paradigm shift in quality reporting and payment programs, the highly anticipated proposed rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA) is potentially only months away from implementation on Jan. 1, 2017.

“MACRA/MIPS is a monumental change in the way Medicare providers are evaluated and reimbursed.”

The Department of Health and Human Services (HHS) issued a notice of proposed rulemaking this spring that outlined agency plans to "align and modernize" Medicare payments after MACRA ousted the Medicare sustainable growth rate formula. Collectively, these changes created the Quality Payment Program, which is divided into two paths that link to quality payments. The path that most doctors of optometry will utilize is the Merit-based Incentive Payment System (MIPS).

Doctors of optometry can use these pointers, from Jeff­ Michaels, O.D., AOA Quality Improvement and Registries Committee past chair, and Chris Wroten, O.D., AOA Federal Relations Committee member, to prepare for MIPS implementation.

1. Registry reporting can impact scores.

MACRA requires the HHS secretary to encourage the use of Qualified Clinical Data Registries (QCDRs) in carrying out MIPS, and the proposed rule carries out this requirement with multiple policies to encourage the usage of QCDRs. For example, CMS has proposed to award bonus points in the quality scoring section for measures gathered and reported electronically via the QCDR. Additionally, CMS has proposed that doctors be required to participate in clinical practice improvement activities, several of which are directly linked to engagement with a QCDR, such as AOA MORE (Measures and Outcomes Registry for Eyecare).

"Simplifying the new CMS payment regulations is an important part of what AOA MORE provides," Dr. Michaels says. "It's an invaluable tool that we see emphasized all over the new proposed payment regulations. AOA members can take advantage of their membership by using AOA MORE, designed to help them navigate the new Medicare payment reform regulations that start on Jan. 1, 2017."

2. Report more frequently.

Quality reporting, similar to the Physician Quality Reporting System (PQRS), continues under MIPS, but CMS has proposed to decrease the number of quality measures required to be reported. Although the number of measures has decreased, proposals would increase the frequency of reporting. The AOA is urging CMS to implement reasonable quality reporting requirements.

Dr. Michaels says there is a burden on all doctors to report quality measures and 'Advancing

Care Information,' formerly meaningful use. "Whether it's the frequency of reporting or learning how to report, it's all new, but that's where AOA MORE comes in. It is designed to simplify this process and to allow optometrists to get back to doing what they do best-caring for their patients."

3. Say goodbye to performance limitations.

CMS proposed that doctors who bill less than $10,000 under Medicare and see fewer than 100 Medicare patients will not be required to participate in MIPS. Similar program requirements that exist under the EHR Incentive Programs have been proposed under MIPS, but CMS is moving away from the all-or-nothing approach that AOA has long argued against. For a portion of the score, doctors would just need to report a numerator and denominator for each objective.

This would provide doctors with part of their base score. Specific performance thresholds that currently exist in the EHR Incentive Programs would not be part of the program. The doctor's performance score would be calculated by analyzing performance for certain measures.  

CMS has made the ability to participate in this new Quality Payment Program more flexible than previous programs, Dr. Michaels says, and with the wide variety of measures available, doctors of optometry can report measures that are important to their practice

4. Be ready for 2017.

According to CMS's proposal, 2017 will be the first performance year for which doctors will be evaluated for payment incentives. Penalties will be assessed in 2019, maxing out with a 4 percent payment decrease.

"Optometrists need to realize their performance on these measures starts Jan. 1, 2017," Dr. Michaels says. "The payment penalties start at 4 percent, but will more than double three years later. AOA members should take advantage of using AOA MORE and the features that will help them participate in this new health care paradigm."

Dr. Wroten adds: "MACRA/MIPS is a monumental change in the way Medicare providers are evaluated and reimbursed. It's imperative that we understand how to maximize our MIPS scores in order to realize the highest reimbursements available from CMS for the services we provide."

August 2, 2016

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