MIPS results for 2017 are in, but bonus payments are low
The first year of performance monitoring under Medicare’s Merit-based Incentive Payment System (MIPS) is in the books and CMS has finally released MIPS report cards – which include Part B payment adjustments for 2019 – to all providers that submitted data.
Unfortunately, the sheer volume of participating providers – 91% of all those eligible reported some MIPS data in 2017 – along with CMS setting a very low minimum threshold to avoid a payment penalty has resulted in relatively low bonus payments, says Stanley Nachimson, principal at Nachimson Advisors LLC, a healthcare IT consulting firm in Brandenton, Fla. “MIPS is a budget-neutral program, so if you have everyone doing well, a very small set of doctors not reporting and thus getting the full negative adjustment, everyone else is going to see a small average increase, it might just be half a percent,” explains Nachimson, who previously worked at CMS as an advisor on HIPAA regulations and health IT.
‘Not worth the effort’
The 21 providers at Advanced Orthopaedics & Sports Medicine in Houston, Tex., earned an average MIPS composite score of 95 points – just shy of the maximum 100. Yet the reward for this amount of reporting in 2017, well above the exceptional performance threshold of 70 points, will yield only a 1.83% positive Part B payment adjustment in 2019, reports Joseph Mathews, practice administrator.
What’s more, then 1.83% includes the exceptional performance bonus Mathews’ providers earned by scoring over 70 points. The exceptional performance bonus comes from a $500 million cash pool that is not budget-neutral in 2017 and is applied as an additional percent boost to Part B payments. Mathews was particularly disappointed that the exceptional performance bonus seemed negligible, as a result of so many practices being “exceptional” in 2017.
“We spent a lot more time and money on this than a 1.83% payment boost would cover,” Mathews says. He estimates, based on the group’s 2016 Part B charges, that 1.83% comes out to approximately $45,000. But the costs of preparing for MIPS and reporting MIPS data are higher than $45,000, Mathews believes. His practice spent additional staff time on training, onboarding physicians on MIPS measures, purchasing additional EHR modules, and keeping a close eye on MIPS reporting throughout 2017.
“I think it comes out to $4,000 per provider spent to prepare for MIPS and report, and if you take the $45,000 that comes out to about $2,000 earned in bonus payments for 2019,” Mathews says. “So I’m actually in the negative if you look at it this way. There is no incentive here, other than vanity for getting 95 out of 100 points.”
Other practices said they felt the MIPS bonus was worthwhile because they didn’t spend as much time and money on preparation and reporting. “Yeah, the bonus isn’t much money, but it wasn’t that much in costs and resources for us to report in 2017,” says Kevin Watson, administrator at Colorado ENT & Allergy. He agrees with Nachimson that the high attestation rate in 2017 kept the average positive payment adjustment low. A perfect MIPS composite score of 100 might have been enough for a 2% boost, Watson estimates.
‘You have to ask the big questions’
Nachimson, the former CMS official turned consult, points out that some of Mathews’ costs are one-off expenditures, so the return on investment should be higher in future MIPS years. “Will they get all of that money back in the future? Maybe,” Nachimson says. “But you have to ask the big questions. The purpose of MIPS is to get providers to behave a certain way, and if we truly believe MIPS measures will result in better care, then we’ll realize those benefits while keeping the program budget-neutral.”
A practice as dedicated to MIPS as Mathews might have a chance to keep their MIPS score high in 2019 and beyond, when CMS is likely to significantly increase the minimum score threshold, which would leave many more practices in the red, leaving a much bigger slice of the bonus pie to high-achieving providers, Nachimson says.