Robert "Bo" Gamble
We just completed the comment period for CMS’s Merit Based Incentive Payment System (MIPS) and alternative payment models (APMs), which are components of the Medicare Access and CHIP Reauthorization Act (MACRA) passed by Congress in 2015. For many, that may sound like a bucket of red tape ready to entangle any practice that gets in its way. Well, if you think just the names of those programs fill your head with static, try reading the documents! Actually, you should read them.
There is a lot in the program guidelines that oncology practices MUST familiarize themselves with. To not do that is going to leave you flat-footed and behind the curve when this incredibly important legislation becomes more established. It is essential to prepare now for this scale of change, even if delays in implementation are likely.
A recently completed survey of the Community Oncology Alliance Administrators’ Network showed that practices generally have littleto- no understanding of MIPS. Less than half (46%) of oncology practice administrators report that they have started to prepare for MIPS. About one-third (30%) report that they are awaiting the final rule, 17% view it as yet another major change, and 7% are paralyzed with fright.
To better understand the scale of what is coming, consider the introductory paragraph CMS uses to describe the legislation: “MIPS would consolidate components of three existing programs, the Physician Quality Reporting System, the Physician Value-based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program for Eligible Professionals, and would continue the focus on quality, resource use, and use of certified EHR technology in a cohesive program that avoids redundancies.”
Oh, boy! That is a lot of change to how we work and are paid for delivering high-quality care!
So, what are some practical things practices should know about this? Beyond the name changes, MIPS essentially breaks down into four very complicated scoring components, which are identified in the box below. And for the real kick in the pants, consider that your efforts will not be rewarded or penalized for a full year! Performance in 2017 is used to determine your payment adjustment for 2019. So that means 2018 could be either a year of celebration or of real nail-biting!
The above is specific to MIPS. Let’s not forget that the alternative to MIPS is participating in a recognized APM. Most of these are in their infancy, and there are few indications of which, if any, are working.
Although the MIPS and MACRA rule is preliminary and subject to change, CMS is clearly putting a lot of weight into it, and the act will be a major part of oncology practice. The question is, will you be able to untangle the regulations in time to prepare?