Will MIPS bonuses be worth the effort needed in 2019?
Grant Huang, CPC, CPMA
Director of Content at DoctorsManagement
When CMS revealed to providers how much of a payment boost they would see for their 2017 performance under the Merit-based Incentive Payment System (MIPS), many came away disappointed and some even said the money wasn’t worth the effort it took.
One Texas-based group managed to get its 21 physicians to an average MIPS composite score of 95 points, just five short of the maximum possible 100. Yet the reward for these efforts – which required hours of physician education, staff training, and EHR reconfiguration – CMS will be boosting their 2019 payments by a mere 1.83%.
Now that the 2019 MIPS performance period is upon us, does it make sense to put forward a supreme effort in hopes of bigger payment bonuses in 2021? Let’s take a look at how the MIPS program is changing in 2019 first:
CMS is finalizing most of the provisions for MIPS in its proposed rule, many of which are statutorily mandated by the 2015 Medicare Access and CHIP Reauthorization Act (MACRA) which established MIPS. This includes the addition of multiple eligible clinician types, including physical and occupational therapists, qualified speech-language pathologists, audiologists, clinical psychologists, and registered dietitian or nutritional counseling professionals. Other final provisions relevant to MIPS scoring and bonus payments include:
- Minimum performance threshold to avoid a negative adjustment doubles from a 15-point MIPS composite score to 30 points in 2019. The exceptional performance threshold (for which additional bonus monies are paid) increases from 70 points to 75 points – this is actually down from 80 points in the proposed rule.
- Adding a third criterion for MIPS exemption (meaning the provider does not need to report MIPS or comply with any of its requirements, though they will also not be able to earn bonus payments). The third criterion allows providers who provide 200 or fewer covered professional services over a 12-month period to be exempt.
- The MIPS Quality performance category is reweighted from 50% of the MIPS composite score in 2018 to 45% in 2019. Meanwhile the MIPS Cost performance category is reweighted from 10% in 2018 to 15% in 2019. The other performance categories have the same score weights in 2019.
Again, provider behavior to dictate bonus size
A key reason for the underwhelming bonuses in 2019 was provider behavior – the vast majority of providers (at least 91%) participated in MIPS in 2017 according to CMS – meaning that less money was in the pot to spread around to high performers. MIPS is a budget-neutral program, so more high performers means a smaller pot, says Stanley Nachimson, principal at Nachimson Advisors LLC, a healthcare IT consulting firm in Brandenton, Fla. “The bar was very low in 2017 in terms of MIPS score needed to avoid a payment penalty,” explains Nachimson, who previously worked at CMS as an advisor on HIPAA regulations and health IT.
That minimum bar to avoid a penalty jumps from 5 points in 2017 to 30 points in 2019 (it had increased to 15 points for this year). Thus some physicians not willing to do the extra work will get a payment penalty, and it may not matter much to them if their Medicare volume is very low, but just high enough to make MIPS mandatory for them, Nachimson explains.
At the same time, CMS is increasing the bar for exceptional performance from 70 points in 2017 to 75 points in 2018. It doesn’t seem like much of an increase – remember the Texas group had 95 points on average – but it could limit the number of exceptional performers and enlarge the pot.
It’s also possible that some providers who felt MIPS wasn’t worth the effort in 2017 won’t bother to be exceptional performers in 2019. If they simply settle for avoiding a penalty by hitting the 30-point mark, there will be more room at the top for exceptional performers, Nachimson points out.
At the end of the day, provider behavior across the industry will have the greatest impact on whether the MIPS pay-off is worthwhile, and now that the learning curve for MIPS is lower as more time has been invested in training, it may not be such a stretch to go for a high score, Nachimson says.
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