With the inaugural reporting period for CMS’s new Merit-based Incentive Payment System now underway, you should be preparing a plan for how you’ll fulfill the program’s requirements, which can vary greatly depending on several factors ranging from the size of your practice to the number of patients you deal with directly each year. In recent years, many groups have relied on their billers to assist with reporting quality metrics required by the Physician Quality Reporting System. However, we’ve encountered numerous groups who have suffered Medicare penalties due to their biller’s failure to properly submit all the claims data required by PQRS.
The reality is that although billers have good intentions, they often cannot keep up with the constant changes to these programs put forth by CMS. This has progressed to the point that many billers have now said they will either no longer assist with quality reporting or are charging additional fees to continue doing so.
With that in mind, here are 22 items to consider as you prepare for MIPS:
- Are you confidant your biller truly understands the intricacies of the four MIPS performance categories: Quality, Practice Improvement, Advancing Care Information and Cost?
- Does your biller understand how those categories relate to the Physician Quality Reporting System (PQRS), Value Modifier (VM) and Electronic Health Record Meaningful Use (EHR MU) programs?
- Have you and your biller examined your Medicare payment history to determine whether or not you’re required to report under MIPS?
- Were you aware that CMS has dubbed 2017 as a “transition” year for MIPS? Have you and your biller had a conversation about what this entails, and what future years of the program could look like?
- Do you know whether you qualify for a MIPS exemption because of your hospital’s participation in a CMS-approved alternative payment model (APM)?
- Aware you aware of the potential benefits, as well as the risks, of participating in these various APMs?
- Have you received PQRS or Value Modifier penalties in the past? Was your biller able to explain why you came up short?
- If you did receive Medicare penalties under previous programs, did your biller offer to assist you with the appeal process? Was the appeal successful?
- Are you aware of whether you meet CMS’s designation as a non-patient facing clinician under MIPS? You should understand both the threshold for this designation and its potential impact on the categories you’ll be required to report on.
- Do you understand the differences between quality reporting under PQRS and the new Quality category of MIPS?
- How intimately does your biller understand the various quality measure groups of the Quality category? Can they help you determine which measures are applicable to your group, and how many you must report on to achieve your full score?
- Does your biller know the MIPS scoring thresholds that could open your group to receive additional Medicare bonuses beyond the maximum 4 percent initially offered for 2019?
- Has your biller determined whether or not your group will be required to report in the Advancing Care Information category?
- Do they understand how a category’s weight is redistributed if you receive an exemption?
- Have they discussed what Practice Improvement activities among the more than 90 available options would best suit your group. Have they supplied you with a plan for how to best fulfill the category’s requirements?
- Do you understand what you must do to attest you’ve completed your Practice Improvement activities?
- Were you aware the Cost category won’t count toward your total MIPS score in 2017, but will be in play for the 2018 reporting year?
- Has your biller informed you that CMS has made funding available to some small and rural practices to help them prepare for MIPS reporting?
- Have you and your biller had a discussion about your reporting options? ie: whether to report individually or as a group, or whether to report via claims or a registry?
- Are you prepared to report quality data on 50 percent of your applicable patients for all payers if planning to report via registry or through an EHR vendor?
- Given that MIPS has been dubbed by CMS as a “budget neutral” program, has your biller discussed with you how the success or failure of your peers could influence potential bonuses you can receive under MIPS?
- Has your biller provided you with projections on how much revenue you could stand to lose through MIPS penalties as they increase each of the next four years?
If you’re looking for a consultant to provide expertise and guidance on your MIPS reporting, give us a call at 517-486-4262. We’ll be happy to set up a free consultation to discuss your unique situation while providing details of how we can get you and your group on the right track.