This post is part of the MACRA Monday series of blog posts where we dive into the details of MACRA.
As mentioned, next up we’re going to cover the 4 MIPS performance categories. Each of these categories are listed in the graphic below and will contribute to what is called your MIPS Composite Score.
At first, these four new category names might be confusing, but here’s the translation you need to know for each category that will illustrate how MIPS really just rolls up three existing programs and adds one new program as follows:
- Quality Performance Category – PQRS Replacement
- Resource Use (Cost) Category – Value Based Modifier Replacement
- Clinical Practice Improvement Activities Category – New
- Advancing Information Category – Meaningful Use (EHR Incentive Program) Replacement
I’m not sure why the government thought we needed new names for each program, but they decided that was the best route. Maybe they wanted to leave the past behind and move forward without the baggage that exists with the previous names. Regardless, 3 of the 4 MIPS performance categories are programs that most of you probably already know about. There are slight changes with each of the 3 programs (PQRS, Value Based Modifier, and Meaningful Use) under MIPS which we’ll cover in a future part of this series. In most cases, each of those 3 programs was simplified under MIPS.
In order to determine your MIPS Composite Score, each provider will receive a score on a 100 point scale. Each of the 4 performance categories contributes to the 100 point scale and have been weighted as follows:
Yes, that means that if you are already doing PQRS (Quality) and Meaningful Use (Advancing Care Information), then you’ll be well positioned for 75% of the points for the MIPS composite score. If you’re only doing PQRS, you’re still in a position to get 50% of the MIPS composite score without too many changes from what you’re doing today. Of course, that assumes you continue those efforts under the modified MIPS requirements in 2017. If you’re not doing PQRS, meaningful use, or value based reimbursement, then you’ll have some serious work to do in order to not be penalized under MIPS.
Once CMS calculates your MIPS composite score, they’ll compare that score against the threshold to determine the adjustment received. Speaking hypothetically, let’s say the MIPS threshold was set at 64 and your MIPS Composite Score was 64. Then, you wouldn’t receive an increase or decrease to your reimbursement. Of course, if you scored above a 64, then you’d receive a bonus payment. If you score below a 64, you’d be penalized.
CMS has said they intend to publish the benchmarks and thresholds prior to 2017. Given the short time frame, this is going to be a real challenge and is likely another reason why it’s possible that MACRA could be delayed. However, it’s good to know that they’re planning to publish the MIPS threshold in advance so practices can plan accordingly. The great part of this scoring system is that unlike meaningful use which was all or nothing, this scoring gives providers credit for partial performance.
It’s worth also noting that the MACRA program must be budget neutral. So, if more providers are getting penalized than are getting incentives, the HHS Secretary will use a scaling factor to increase the incentives paid to participating providers that qualify. HHS also has $500 million available separate from the normal incentive payments to reward exceptional performance. I have yet to see details on this, but it will be interesting to watch and see what they use as the criteria for exceptional performance. I wonder how much higher of a composite score you’ll need above the threshold to be considered an exceptional performer.
Next week we’ll start going through each of the performance categories at a high level and discuss the changes made to each program that’s been rolled into MIPS and the new Clinical Practice Improvement Activities category.
Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.