Codapedia is now a division of Find-A-Code

The Money in MIPS

June 15th, 2018 - Diana Strubler
Categories:   MIPS|PQRS|PQRI   Practice Management  
0 Votes - Sign in to vote or comment.

Seema Verma, Administrator of the Centers for Medicare and Medicaid Services (CMS), recently announced that 91% participated in the first year of the Quality Payment Program (QPP), barely squeaking by their goal of 90%.

Due to these high numbers of participation one would think there’s a lot of money in the pot. Right? Well…probably not.

One man’s loss is another man’s gain

As required by the Medicare Access and CHIP Reauthorization Act of 2015, CMS must implement Merit-based Incentive Payment System (MIPS) payment adjustments in a budget-neutral manner—meaning the agency may not pay out more in incentive payments than it recoups in penalties. In other words, if there are not a lot of losers, there are not a lot of winners.

The maximum negative adjustment for the 2017 performance period is -4% for not participating. Clinicians at or above the performance threshold of 3 points earn a neutral or positive adjustment. The adjustment is applied on a linear scale, so clinicians with higher scores earn a higher adjustment.

Figure 1: MIPS 2017 Performance Year Payment Adjustment

Here is where the math gets tricky. The amount of the positive adjustments is scaled and will depend on the scores as well as the total number of clinicians both above and below the performance threshold. The positive payment adjustment in 2019 for a score of 100 is established at +4% adjusted up or down by a scaling factor.

For clinicians with a final score of 100, the adjustment factor would be 4% times a scaling factor greater than 0 and less than or equal to 3.0. The scaling factor is intended to ensure budget neutrality, but cannot be higher than 3.0.

More clinicians above the performance threshold means the scaling factors would decrease because more clinicians receive a positive MIPS payment adjustment. More clinicians below the performance threshold means the scaling factors would increase because more clinicians would have negative MIPS payment adjustments and relatively fewer clinicians receive positive MIPS payment adjustments.

The image below was published in the 2017 MACRA final rule and is for illustrative purposes only. The scaling factor for the 2019 payment year will not be known until later this year.

Figure 2: Illustrative Example of MIPS Payment Adjustment Factors Based on Final Scores and Final Performance Threshold and Additional Performance Threshold for the 2019 MIPS Payment Year

In the first year of the program, CMS anticipates that the payment adjustment for MIPS eligible clinicians with a final score of 100 points would most likely be around a +2.4% payment adjustment or less.

Which in turn means those clinicians who did well, but not perfect, will receive even less than that.

Where did the money go?

When MACRA was first proposed, clinicians were eligible for around $833 million in incentive payments under MIPS for the 2019 payment year. This assumed that around 746,000 clinicians would be required to report under the MIPS track of the QPP.

At that time, the proposed rule had set the low-volume threshold at $10K. That meant clinicians who billed Medicare Part B $10K or less per year would be exempt from the MIPS program.

This amount quickly dropped to $199 million once the low-volume threshold was finalized at $30,000 and the bar to avoid a penalty was set very low with the “pick your pace” path.

Figure 3: MIPS Estimated Payment Adjustment Pool

Therefore, if a MIPS consultant ever knocks on your door promising you a +5% bonus for your 2019 reporting, you should run the other way.

When the bar to lose is set low and less than 50% of clinicians are eligible to participate, the math just doesn’t work out.

The money may not be worth it, but what about your reputation?

I’m sure many of you are now thinking that the money isn’t worth the effort. Or maybe it will cost you more to report than what you will earn. These are both fair statements. However, I caution you from throwing in the towel.

By law, CMS will publicize your final MIPS score for the world to see on the Physician Compare website. Not participating could result in immeasurable negative consequences. Whether it be patients comparing physicians, payer negotiations, or seeking employment into a new practice, your MIPS score may come into play.

What is your 2017 MIPS Score?

If you submitted 2017 MIPS data through the QPP website, you can access preliminary performance score and feedback data with your Enterprise Identity Management (EIDM) credentials.

Keep in mind this score could fluctuate a little based on the following items still being reviewed:

If none of these items above were applicable to you, then the score you see will most likely remain the same. Your final MIPS score will be available sometime in July. Make sure you know what the final score is for all TIN/NPI combinations you are associated with!

Once your final score is set, CMS will compare you against others to see how you rank, and the pool of money will be identified then redistributed in 2019.


Diana StrublerDiana Strubler, Policy and Standards Senior Manager, joined Acumen in 2010 as an EHR trainer then quickly moved into the role of certification and health IT standards subject matter expert. She has successfully led Acumen through three certifications while also guiding our company and customers through the world of Meaningful Use, ICD-10 and PQRS.

###

Questions, comments?

If you have questions or comments about this article please contact us.  Comments that provide additional related information may be added here by our Editors.


Latest articles:  (any category)

Scanning the Unscannable: Improving Patient Flow in MRI
January 14th, 2019 - BC Advantage
Stay Ahead of your CEUs in 2019Get the latest webinars and earn over 24 CEUs each year included with your BC Advantage Magazine subscription. Latest Webinar: Scanning the Unscannable: Improving Patient Flow in MRI Presenter: Wendy Stirnkorb, President & CEO Stirnkorb Consulting, LLC Time: 46 Minutes Cost: $0.00 to all BC Advantage Magazine Subscribers CEUs: 1.0 On-demand: Watch 24/7 from work or ...
What is Virtual Communication (G0071)?
January 14th, 2019 - NAMAS
Beginning January 1st, 2019 all of our RHC and FQHC organizations have a new CPT code to consider implementing for their Medicare populous (check per Advantage Plan Administration for coverage). In its current form, this code is not reportable by organizations not meeting the RHC/FQHC designation. The code isG0071 and is termed ...
Nine New Codes for Fine Needle Aspirations (FNA)
January 4th, 2019 - Aimee Wilcox, CPMA, CCS-P, CMHP, CST, MA, MT
If your practice performs a lot of fine needle aspirations (FNA), you probably have the code options memorized (10021 without image guidance and 10022 with image guidance). However, the 2019 CPT codes now include nine (9) new FNA codes (10004-10012), one deleted FNA code (10022) and one revised FNA code ...
Dry Needling
January 3rd, 2019 - Wyn Staheli, Director of Research
The correct coding of dry needling, also known as trigger point needling, has been a subject of confusion for quite some time. The American Chiropractic Association (ACA) and the American Physical Therapy Association (APTA) have been working together for several years to obtain appropriate codes to describe this service. In ...
2019 Coding Changes for Chiropractic
January 3rd, 2019 - Wyn Staheli, Director of Research
The new year is upon us and so it’s time to double check and make sure we are ready. Those with Premium Membership can use the ChiroCode Online Library and search all the official code sets: ICD-10-CM, CPT, and HCPCS. It also includes the updated NCCI edits and RVUs for ...
Are You Ready For the 2019 New Codes
January 3rd, 2019 - Aimee Wilcox, CPMA, CCS-P, CMHP, CST, MA, MT
Many articles have been published regarding the 2019 proposed Evaluation and Management coding changes but hopefully, you have taken the time to review those in detail and be ready for them. If not, here is a link to a Find-A-Code article written by Wyn Staheli (Director of Research) entitled, “Are You Ready ...
Quality Measures Finalized for 2019
December 18th, 2018 - Wyn Staheli, Director of Research
CMS recently announced that the quality measures for 2019 have been finalized. There are new eligible clinicians so be aware of how that may affect your organization. New ECs are: Physical therapists Occupational therapists Qualified speech-language pathologists Qualified audiologists Clinical psychologists Registered dietitian or nutrition professionals The following are changes to Electronic Clinical Quality Measures (eCQMs) available ...



About Codapedia & Find-A-Code Contact Us Terms of Use Privacy Policy Advertise with Us

Codapedia™/Find-A-Code™ - 62 E 300 North, Spanish Fork, UT 84660 - Phone 801-770-4203 (9-5 Mountain) - Fax (801) 770-4428

Copyright © 2009-2019 Find A Code, LLC - CPT® copyright American Medical Association