Optimizing the Value-Based Revenue Cycle:
The Merit-Based Incentive Payment System
(MIPS)
WI-HFMA, May 27, 2016
Tom S. Lee, Ph.D.
CEO & Founder
SA Ignite
Learning Objectives
1. Understand the back-office mechanics of the forthcoming Merit-Based
Incentive Payment System (MIPS) value-based Medicare Part B
program and its components, including PQRS, Meaningful Use, and
Value-Based Modifier.
2. Learn and apply best practices to identifying revenue leakage and audit
risks associated with the back-office management of value-based
payment programs.
3. Apply shared field experiences and specific examples of optimizing the
value-based revenue cycle to improving your back-office processes and
systems.
2
Agenda
• Our Background in MIPS
• MIPS 101
• Value-Based Revenue Cycle Optimization in Action:
MIPS Quality Reporting Method & Measure Selection
• Q&A
3
Our Background in MIPS
4
We Optimize the Value-Based Revenue Cycle for
13,000+ providers
5
MIPS/MACRA Thought Leadership
Published April 30, 2016,
3 days after release of the
MACRA proposed rule
http://www.modernhealthcare.com/article/20160430/MAGAZINE/304309988/docs-face-stark-choices-under-new-medicare-pay-proposal
6
Google Rankings for MIPS
7
MIPS 101
8
MACRA Passed April 2015
(Medicare Access & CHIP Reauthorization Act of 2015)
• “Doc fix” bill approved 92-8 by Senate
• The Quality Payment Program (QPP) places
each Medicare Part B provider into:
a) Merit-Based Incentive Payment System (MIPS),
b) Advanced Alternative Payment Models
(Advanced APMs) such as Track 2/3 MSSP ACOs,
c) both MIPS and Advanced APM, or
d) neither
9
MACRA Rulemaking Timeline
• April 27, 2016: MACRA draft rule released
• By November 1, 2016: Release of final rule
• January 1, 2017: First performance year begins
10
How Many Medicare Part B Clinicians
Will Be Affected?
MIPS ~ 800,000 out of 1.25M providers*
Advanced APM < 20,000 providers
(mostly in Medicare ACOs)
Hence, MIPS is the “new default”
for Medicare Part B clinicians.
*CMS estimate in MACRA Proposed Rule
11
MIPS Eligible Clinicians
12
MIPS Starts January 2017
• Leverages and augments PQRS, Value-Based Modifier
(VBM) and Meaningful Use rules
• Increases and consolidates financial impacts
• Ranks peers nationally & reports scores publicly
• MIPS is budget neutral: Incentives to winners funded
by penalties applied to losers
13
Components of the CY2017 MIPS Score
14
Unlike Historical MU, ACI Scoring is a
Continuous Scale, Not All-or-Nothing*
From CMS NPRM Fact Sheet
Performance Score: Each measure scored on a decile scale to earn up to 10 points
Key Takeaway:
High, historical MU compliance does not guarantee a high ACI score.
Similarly, historically avoiding PQRS/VBM penalties does not mean the MIPS quality score
will be high enough to avoid MIPS penalties without additional effort.
*MACRA Proposed Rule – May change in Final Rule
15
Financial Impacts of MIPS are Significant
16
4-Year Average Annual Payment Adjustment
Versus MIPS Performance Score
17
5 Things to Do Now to Prepare for MIPS
1.
Educate your organization, particularly the C-suite, as soon as
possible, e.g. leverage MIPS Financial Calculator
2.
Estimate your MIPS score (stay tuned for our forthcoming tools)
3.
Optimize MU (ACI) & PQRS/VBM Quality to maximize MIPS score
– Comprise 75% of the CY2017 MIPS score
– See following section regarding MIPS Quality category optimization
4.
Evaluate staff, resources and organizational structure
– e.g. combine MU & PQRS efforts under a single leader
5.
Identify CY2016 deadlines impacting CY2017 MIPS
– e.g. MSSP ACO or PCMH application deadlines to gain MIPS exemptions or points
18
Educate Your Organization:
Free Resources to Help
•
10 FAQs About MIPS: Google “merit-based incentive”
http://www.saignite.com/resources/faq-about-merit-based-incentive-payment-mips
•
Free MIPS Financial Calculator: Google ”mips calculator”
http://www.saignite.com/mips-solutions
•
Recorded ABCs of MIPS monthly webinars: 250+ attendees/webinar
http://www.saignite.com/resources/hitech-abc-of-mips-webinar
•
LinkedIn Group “Merit-Based Incentive Payment System” (no ads)
19
Estimate Your MIPS Score:
Example from a Client Engagement
ACI (max 25):
•
We predicted 75% ACI performance, translates to 19 MIPS Points
Quality (max 50):
•
We predicted VBM Quality = -0.36, translates to 21 MIPS Points
Resource Use (max 10):
•
2014 VBM Cost = 0.12 translates to 5 MIPS Points
Clinical Practice Improvement Activities (max 15):
•
Assume 2/3 achievement, or 10 MIPS Points
Estimated MIPS Score: 19 + 21 + 5 + 10 = 55 (1-2% MIPS incentive)
20
Value-Based Revenue Cycle Optimization in Action:
MIPS Quality Reporting Method & Measure Selection
21
Selection of PQRS Reporting Method or Measures
Can Greatly Impact VBM & MIPS Quality Scores
22
Many PQRS Methods to Choose From
23
PQRS Measure Selection Complexity
To maximize VBM scores, measures must be selected from among…
PQRS measures
~298 total
EHR Direct: 64 CQMs
GPRO web interface: 17
measures
Registry: ~280 measures
Individual
measures
Measures
groups
…across Individual-Provider and GPRO PQRS reporting methods.
Measure values subject to audit up to 7 years after submission.
Also, for GPRO, should you opt-in to include the CAHPS patient
experience survey measures in the VBM Quality Score or not?
SA Ignite Proprietary and Confidential
24
PQRS Method Selection Fraught With
Interrelated Decision Factors
25
Develop a PQRS Method Selection Decision Tree
and Estimate Decision Impact on MIPS Score
26
Summary
• The financial stakes of MIPS are very high
• Penalties fund the incentives for the winners
• Every MIPS point counts
• Past success in MU or PQRS/VBM does not guarantee a
high MIPS score nor avoiding MIPS penalties
• There are things you can do now to prepare for MIPS
27
Q&A
Tom Lee
[email protected]
28