This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.
As promised, we’re back with another MACRA Monday looking at the MIPS Pick Your Pace options. However, before we dive into Pick Your Pace, we want to take a second to look back at the details of the MIPS incentives and penalties that are available as well. This really didn’t change in the final rule, so it’s review for those who have been following MACRA Monday since the beginning.
If you remember from last week’s MACRA Monday post, what you do in 2017 will determine your MIPS payment adjustment in 2019. Assuming you perform at the top level, you can get a full 4% positive payment adjustment to your Medicare Part B reimbursement (Note: It was pointed out to me that the MACRA program has to be budget neutral, so while they can give up to a 4% positive payment adjustment, it won’t be a 4% positive payment adjustment if enough practices aren’t penalized. With Pick Your Pace, hardly anyone will be penalized. On page 1282-1286 of the final rule it highlights this and points out that with the budget neutrality scaling, the upward adjustment is estimated to be under 1% for the base and 2.4% for exceptional performers. Thanks Lynn Scheps for the clarification!). Of course, if you don’t participate in MIPS, you’ll get a 4% penalty. That scales up to 9% in 2022. There are some exceptional performance bonuses as well, but we’ll cover that in a future MACRA Monday.
In the MACRA final rule, CMS added a number of other ways for doctors to participate in MIPS. They call the various options Pick Your Pace since the provider can choose how much they want to participate in MIPS in 2017. Here are the 3 MIPS Pick Your Pace options (and the Advanced APM for completeness’ sake):
As is laid out above, you can fully participate in MIPS for the entire year and get the largest positive payment adjustment. You can report on 90 days and receive at least a small positive payment adjustment and up to the full positive payment adjustment. Or you can just submit something to MIPS and that will have you avoid the negative MIPS payment adjustment.
The “Test Pace” option as it’s listed above needs some further clarification. Basically, if you don’t want to fully participate in MIPS, but want to avoid the negative payment adjustment you can just do 1 quality measure, 1 improvement activity, or the required advancing care information measures.
Clear enough? Basically, in 2017 they’ve made it so pretty much everyone should be able to at least do the Test Pace portion of MIPS and avoid the 4% negative payment adjustment. I don’t know of any practices where this wouldn’t be a reasonable goal. However, is that the best approach for a practice? I think not.
If I were advising a practice today, I’d suggest they shoot for full MIPS participation in 2017. Assuming they do well, they’ll get the full 4% payment increase and even could qualify for bonus payments. If they fall a little short, then they should still easily qualify for the MIPS partial year option which will provide them a small positive payment adjustment. If they experience a disaster with their MIPS participation, then they will still avoid any penalties.
Why is this my suggested route? MACRA and MIPS aren’t going anywhere. Sure, they might go through various iterations and subtle changes, but the move to this kind of reporting is here to stay and even a Trump presidency isn’t likely going to change this. Plus, you don’t want to be behind the 8 ball in 2018 when the full MIPS requirements will be upon us (Remember my post about thinking about MACRA like med school). You don’t want to get so far behind that you can’t catch up. If that’s still not enough, many people believe that the commercial payers are going to follow suit. Those that have participated in MACRA will be better prepared when they do.
Those are the details on MIPS pick your pace. We may take next week off from MACRA Monday for the holidays, but the next week we’ll be diving into more of the details of MIPS and other changes to the MIPS Performance Categories.
Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.