Prepared or not, providers face deadline for MIPS positive payment adjustment

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Oct. 2 is the deadline for clinicians to start collecting performance data new Merit-based Incentive Payment System (MIPS) and still be eligible for a positive payment adjustment in 2019. With multiple sources showing clinicians and healthcare finance professionals feel unprepared for the first year of the new payment track, some eligible providers may settle for simply avoiding a negative adjustment.

Under the “pick your pace” options for the Medicare Access and CHIP Reauthorization Act (MACRA) payment tracks, MIPS-eligible clinicians could submit data for the entire year, any consecutive 90-day period, or a minimum amount of data, though the latter option will just avoid a negative payment adjustment. If providers wanted a chance at a positive adjustment in 2019, they would need to begin collecting that data on Oct. 2.

It’s unclear how many will try. A Medical Group Management Association (MGMA) survey released in August named the MIPS as the top burden in the eyes of physician practices. Still, MGMA’s senior vice president for government affairs, Anders Gilberg, believed most of the providers the association speaks for will report this year.

“MGMA members, representing medical groups with professional administrators, are prepared,” he told HealthExec. “Most are already collecting MIPS data. Solo physicians and the smallest practices are far less prepared.”

While flexible participation options were praised when announced by CMS, surveys have shown consistent concerns about lack of preparedness and not understanding MIPS requirements. 75 percent of physicians responding to a June survey from the American Medical Association and KPMG said they felt unprepared for MACRA requirements this year—with about a third unlikely to meet even the minimum standard of reporting on one MIPS measure on a single patient.

“Those who are prepared to report more data can realize rewards for improvement and for delivering high-quality, high-value care,” said AMA President David Barbe, MD.

Other healthcare professionals also reported difficulties with the new requirements. A survey of hospital finance executives found CFOs may have said they’re confident about understanding MIPS requirements, but didn’t correctly identify specifics. For example, 75 percent of those who said they’re confident didn’t know eligible providers which didn’t submit data would see their Medicare reimbursements cut by 4 percent in 2019. Only 30 percent knew about the 90-day reporting period for a positive adjustment.

Providers may have been confused by certain MIPS moves from the new administration at CMS. Eligibility notifications for clinicians were released months later [JG1] than scheduled and more than half of Medicare providers were declared exempt from MIPS. That number will likely rise based on CMS’ proposal to raise low-volume exemption thresholds in the second year of MIPS, meaning some providers which prepared for MIPS in 2017 now won’t be able to participate in 2018 unless some sort of “opt-in”mechanism is created.