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The Top Three Hidden Impacts of MIPS – MACRA Monday

Posted on July 10, 2017 I Written By

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust

A Do-Not-Forget Checklist for EHR Switchers on the Hook for Meaningful Use

Posted on November 21, 2013 I Written By

The following is a guest post by Tom S. Lee, PhD, CEO and Founder at SA Ignite.

According to a recent survey by Black Book rankings, as many as 16 percent of ambulatory EHR users may become  EHR switchers within the next 12 months.  Large health systems such as Intermountain (a client of ours) and the Department of Defense have recently announced that they are switching EHRs or are currently evaluating a change. Many such organizations are planning to switch EHRs while continuing to meet increasingly difficult Stage 2 Meaningful Use (MU) requirements.  According to past National Coordinator  Dr. Farzad Mostashari, there will be no delay of MU Stage 2. That means your health IT road map may now include switching EHRs, managing Stage 2 attestations, and achieving ICD-10 compliance.

How do you switch jugglers while the number of balls in the air increases at the same time?

We have encountered a common set of issues and questions in our work with clients, discussions with prospects, and exchanges with thought leaders in the industry related to the EHR switching scenario, especially as it relates to Meaningful Use.  Here are some things to consider:

1. Assess and properly store data from your old EHR for future MU audits. A recent wave of MU audit notices has been sent by CMS to some of the country’s leading health systems. Each MU attestation is subject to audit 6 years after the attestation date.  With this in mind, be sure to pull out and securely and centrally store all supporting data from your old EHR before its license expires.  Get expert assistance if needed to understand how to build a comprehensive and solid audit trail.  One great place start is the guidance on audit documentation provided by CMS.

2. Optimize the timing of the EHR switch relative to government reporting timelines.  For example, in 2014 there is a one-time opportunity to report on only a calendar quarter’s worth of data for many eligible providers, rather than the entire year.  This modification to MU was originally made to accommodate delayed Stage 2 certifications by the EHR vendors.  However, it can also be leveraged by EHR switchers who can time the switch to happen within 2014 to benefit from a lower compliance bar while the massive impacts of switching EHRs are absorbed by the organization.

3. Plan to merge data across EHRs to meet MU reporting requirements.  Even with the 2014 calendar-quarter reporting reprieve, for many hospitals and eligible providers to achieve Meaningful Use in an EHR-switching year it’ll be necessary to stitch together Meaningful Use data across the old and new EHRs in order to meet many MU reporting requirements.  For example, this may be required simply to meet the minimum certified EHR usage threshold to be eligible for the MU program in that year.  Assume merging data will be necessary, prepare how to do so before your old EHR license expires, seek help, or do both. An interesting contingency we have seen is to drive eligible providers to “over perform” on their MU measures on the old EHR in anticipation that MU performance will drop at the outset of adapting to the new EHR.  This will increase the chances that providers’ total MU performance within a reporting period spanning both EHRs will end up above threshold.

4. Plan to be supporting two EHRs at the same time.  Although it is sometimes possible to do a “big bang” switchover to a new EHR across an entire organization, we often see that rollout plans for the new EHR are phased across specialty, location, or other sub-groups.  During those periods when the organization could be supporting two different EHRs, such as two ambulatory EHRs in different geographic regions, it is important to organize and align teams to not only handle the immediate demands of MU but also transition completely to supporting the new EHR.  For example, MU data reporting and attestation can be hard enough for just one ambulatory EHR, much less two.  It takes preparation well in advance of the EHR switch and government attestation deadlines to avoid 11th hour fire drills.

Is your organization juggling MU requirements while switching EHRs? If so, I’m sure that you’ve found there are additional considerations surrounding an EHR switch that are important to keep in mind. I’d love to hear your suggestions in the comments.