How Will MIPS Impact Your ENT Practice?

With MIPS on the horizon, what changes can you expect in your otolaryngology practice? How will he Merit-Based Incentive Payment System (aka, MIPS) affect your day-to-day life?

ENT physicians will appreciate new focus on improved patient care — and the financial rewards for their efforts. But that’s just one aspect of this brave new world.

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Better patient care & greater value

The “Big 3” goals of MIPS are improved (and more accessible) patient care, smarter spending and healthier people.

For ENT physicians, this translates as an emphasis on:

• Physician performance metrics (with financial incentives for providing high-quality patient care)
• New Medicare reimbursement formula
• Information-sharing of patient records via EHR systems

In this structure, MIPS links fee-for-service payments with quality and value – not on quantity, and not on simply having an EHR system. EHR technology slips into a supportive role for patient care, with an emphasis on better-connected systems.

One physician’s EHR system should be able to communicate with another clinician’s system. Patient records should be transferrable – so that patients can receive optimal care wherever they are in their travels. If they see another doctor, the flow of patient records should be seamless.

A patient’s allergies or other health condition should be immediately known to every physician he or she sees, as well as every emergency room. As every ENT clinician knows, the result can be life-saving.

Ending the SGR component of the payment formula

With MIPS, the reimbursement formula is also changing. Booted out is the Medicare Part B Sustainable Growth Rate (SGR) reimbursement formula.

New arrival is a value-based reimbursement system called the Quality Payment Program (QPP). The QPP has two tracks: The Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (Advanced APMs).

In 2019, you’ll be able to choose between the two – although MIPS offers rewards you might not want to pass up.

New rewards system

MIPS creates a new rewards system for improving the delivery and value of care. ENT clinicians participating in MIPS will have:

• A small, annual inflationary adjustment to the Part B fee schedule. 
• MIPS payment adjustments (incentives or penalties) based on the MIPS 100-point Composite Performance Score (CPS).

The inflationary adjustment is an annual 0.5% increase for 2016 to 2019.

Payment adjustments (rewards) via MIPS are potentially much more substantial. However, the MIPS penalties can be just as substantial.

MIPS = Better Patient Care = Financial Incentives

MIPS is designed to provide incentives for excellent patient care. With that comes a Composite Performance Score (CPS) program that rates clinician performance in 4 categories:

• Quality (50%)
• Advancing Care Information (ACI, renamed from Meaningful Use) (25%)
• Clinical Practice Improvement Activities (CPIA) (15%)
• Resource Use (10%)

The CPS earned by a clinician for a given performance year will determine MIPS payment adjustments in the following year – your financial reward.

MIPS Incentives & Penalties

The Good News: If a clinician earns a CPS of 100 points, then the incentive is 4%. There is an additional “exceptional performance bonus” that escalates up to 10% for progressively higher performers within the top ~30%. This is for the top 75% of those earning an incentive.

The Bad News: If a clinician has a CPS of zero, the penalty assessed is 4%, the maximum penalty.

Bottom Line: Every ranking in between is possible. The top-to-bottom MIPS potential impact on Part B payments for 2017 is likely to be from a 14% incentive down to a -4% penalty, or a total 18% top-to-bottom swing.

MIPS scores go public

That’s right, CMS will release each clinician’s annual CPS performance to the public.

For the first time, consumers will be able to see their providers rated on a scale of 0 to 100 and how their providers compare to peers nationally. This goes beyond existing programs such as VBM, which calculates quality and resource use scores — but does not publicly publish the results.

Don’t panic about MIPS!

The MIPS program is a lot for ENT clinicians to digest, and may feel intimidating. Don’t panic, as we’ll lay out steps you can take now to prepare for the changes. We’ll help you with a game plan.