Experts with whom we surveyed the new merit-based incentive payment system (MIPS) reporting program proposed rule, which CMS released on April 27, see a lot to like – but worry CMS may be rushing things.
On the one hand, many of the requirements in the four categories that will replace meaningful use, the physician quality reporting system (PQRS) and the value-based modifier are easier than what CMS heretofore required, says Richard Loomis, M.D., chief medical officer of PracticeFusion, an electronic health record (EHR) vendor based in San Francisco. Take, for example, advancing care information (ACI) -- the MIPS equivalent of meaningful use. “It has been streamlined,” he says. “The number of objectives reduced from eight to six, and two changed from numerator-denominator to yes/no.” Also, Loomis adds, the “all-or-nothing” scoring of meaningful use, whereby “if you didn’t completely fulfill a measure, you got no credit,” is gone – you can miss some ACI objectives and still get points toward your MIPS score.
This streamlining will mean less financial outlay for providers, says Loomis. He points to a recent Health Affairs survey that found the average administrative cost of quality reporting for a practice is currently $40,069 per physician per year.
Loomis is also glad to see the requirement for meeting the Public Health and Clinical Data Registry Reporting objectives going from two categories of registry to one. “The stage 2 rule required providers connect to one type of registry from among immunization, syndromic surveillance and disease-specific, but when CMS modified stage 2 last year, they made them connect to two,” says Loomis. “There was a significant outcry from providers for a few reasons, one of which was that their certified tech in some cases could only connect with one; another was the high cost of connectivity for providers.”
But there are downsides. For one, the proposed rule still leaves some mysteries, notes Loomis – the clinical practice improvement activities (CPIA) part of MIPS, for example, is largely being left for the final rule to explain. “Whether EHRs today can perform measurement of those activities is an open question,” he says.
Loomis is also worried about the timing – if the final rule comes out in October, that would leave only three months for everyone to get ready before the Jan. 1 launch. “There is growing concern that the industry and CMS will be able to meet the very aggressive timeline for program implementation,” says Loomis. “It is too early for me to advocate for a delay, but CMS should strongly consider [a delay] based upon proposed rule comments.”
“It could be problematic if the final rule is significantly different than the proposed rule,” says Chris Emper, director of government and industry affairs at NextGen Healthcare. “Some consistency and a predictable path is the most important thing.”
Loomis also finds ominous CMS’ estimate that 87% of solo practices and 70% of practices with two to nine providers will get a penalty in 2019. “Broadly, I would like to see changes that move both MIPS and APM [alternative payment model] components of the quality payment program in a direction that reduces the disparity between small and large practices,” he says.
Tom Bizzaro, vice president, health policy and industry relations at FDB/First Databank Inc. in Indianapolis, believes MIPS is another sign of a shift from fee-for-service to pay-for-performance for Medicare providers.
“Providers now have to think seriously about whether they want to accept the burden of MIPS reporting or to move toward an APM,” which would exempt them from reporting, says Bizzaro. “As this continues to be refined, I expect pay-for-performance reimbursement models will be a prerequisite for participation. We’re already seeing this on the commercial side" with
the rise of risk-based and value-based payment models in commercial insurance.
Update, May 24: CMS' administration of MIPS may soon have a new hurdle to jump: Politico reports that for a bill Congress is considering to confront the Zika virus, some funding will be taken from HHS' Nonrecurring Expenses Fund -- which is where part of the MIPS IT budget is kept.
Editor's note: Need more information about MIPS? Sign up for the June 15 webinar How MIPS works and what providers must do to avoid a 4% pay cut.