Reducing the Stress of MIPS Compliance
By Courtney Tesvich
As January nears, health care organizations should consider how they will comply with the Merit-Based Incentive Payment System (MIPS) for 2020. With the new year bringing increased performance thresholds and a renewed emphasis on interoperability and performance improvement, providers may be uncertain about how to approach compliance to ensure optimal outcomes.
Amid these hesitations, it’s tempting to push MIPS work a little farther down the to-do list. However, by taking some time before 2020 dawns to think through how to best meet the revised regulations, organizations can feel more confident about their compliance and lay the foundation for a successful reporting period.
Here are a few strategies to keep in mind when preparing for the year to come.
First, Take Stock of Current Performance
Running quality reports from the previous year can highlight areas in which an organization performed well and identify opportunities for improvement. This will allow time for process retooling to address performance shortfalls before the reporting period gets too far underway, as opposed to playing catch-up at the end.
If improving performance in a measure is unlikely, an organization may want to consider switching it out. The assessment of the entity’s current state may point to more logical measures for them to pursue, ones that better demonstrate the quality of care the organization provides.
It is also valuable to run quality reports periodically throughout the year to stay on top of performance variations as they unfold and avoid last-minute crises as the reporting period closes.
Check Whether MIPS Compensation Will Change
Various specialties will be impacted differently by the MIPS 2020 updates, with some quality measures being discontinued starting in January.
For example, the Centers for Medicare & Medicaid Services (CMS) is retiring two ophthalmology measures related to cataract surgery in 2020. As such, ophthalmology practices should verify they are not planning to submit these measures. If they are, they need to select new ones based on organization strengths.
In addition to double-checking that CMS will accept designated measures, an organization should also verify they will be valued at the same level. When a majority of providers performs well on a particular measure, CMS reserves the right to phase out the measure, downgrading its value across a four-year period.
Organizations should be sure that the measures they choose to report are going to generate the expected point value. If they’re not, they should think about making alternate selections as soon as possible.
CMS offers a benchmarking tool that can help an organization determine whether it has the best mix of measures. With the tool, entities can run their scores and verify whether there are measures that need to be replaced or areas of underperformance that require attention.
While a focus on quality measures is important, organizations should also ensure that they are meeting the requirements of the other categories. There are 15 improvement activities that are being removed from the category. Reviewing existing initiatives and seeing which qualify under MIPS will make certain the organization is effectively meeting the improvement activities requirement.
As part of this process, be sure to check for the necessary number of participants to qualify because the threshold has changed for 2020. In previous years, if one provider was engaged in an improvement activity, the entire group could claim credit for the activity. Starting in January, at least 50% of an organization’s providers must be engaged in that activity. Uncovering any issues with participation rates early can help avoid difficulties down the line.
Leverage Industry Expertise
Realizing strong MIPS performance can be daunting, especially amid an organization’s other priorities. Working with an outside expert that is familiar with the latest updates and specialty-specific best practices for compliance can help ensure an organization designs a comprehensive and effective MIPs strategy.
Such a partner should assist in clearly visualizing the current state, pinpointing improvement opportunities and facilitating seamless reporting. Working alongside a knowledgeable partner, organizations can make significant progress toward optimal compensation based on the most accurate reflection of their performance.
— Courtney Tesvich is vice president of compliance for Nextech.