The Top Three Hidden Impacts of MIPS – MACRA Monday

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust

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  • 1. Not a single patient cares about MIPS scores. I have never had a patient ask me about a Yelp score, Open Payments, Board Certification, MOC, PQRS, MU, etc etc. Never. If their golfing buddy says I am the best, that is all that counts. I promise you, not a single patient will ever determine if they are going to see me by any MIPS score. No one cares. Plus there are so few of us out here on the front lines, they are not a ton of choices! Keep driving us out on meaningless reporting about my care, and watch how fast I quit Medicare. Penalize me more with non-attributable scoring? I’m gone. And guess what, there is no one to replace me.
    2. Recruiting? I can promise you again that no one looks at MIPS scores. Ever.
    3. ACOs are dead. Its HMO in new clothes. Never been successful on any scale. Forget APMs.
    There you go. Best advice…ignore MACRA MIPS and just keep practicing. The costs and burdens of implementation FAR outweigh ANY penalty. Thats my advice.
    And unless you have ever cared for a patient AND participated in meaningless regulations that penalize you for nonsense, then tread lightly on articles like this.

  • meltoots,
    I think you’re right about patients not caring in certain regions. However, in some regions it’s going to be a big impact. I believe that it shouldn’t have an impact and patients shouldn’t look at the MIPS scores since they have no meaning, but I think they will. Same is true for practices in competitive areas when it comes to acquisition and recruiting.

  • 1. I want you to find ONE Medicare patient, even ANY patient that would look at CMS’s website for MIPS scores on their MD. AND that they would consider changing if they scored low on quality reporting. If ANYTHING, it would mean that the MD cares more about the patient than clicking boxes on a computer. Ask any friends of yours that are not HIT experts if they would do that. I bet you will find ZERO that would. And after it goes live, ask again. Zero.
    2. Ask ANY recruiter if a MIPS score would have ANY impact on recruitment. Find one that would say it would make a difference. Just one.

    No one cares about a meaningless MIPS number. MDs are SO over the threats, penalties, game playing and reporting nonsense. Those that aren’t will be soon. And if a patient is freaky enough to navigate CMS’s website for MIPS scores and then make a decision about a provider based on this useless number, they have to be nuts… thank God they aren’t coming to me!

    Tell me about these competitive areas…where is it so competitive that patients would use these scores or recruiters would? What regions? There is not a place in the US that is not short handed on real hardworking front line MDs of any primary care or specialty. Its warm body level everywhere at this point. Do you know how many recruitment letters emails and call I get every day? AND I am not on ANY list looking. And with all these nightmarish regulatory actions, the shortage is ballooning. Not a day goes by that I do not hear about another “leave of absence”, retirement, quit, going into administration or suicide. Warm bodies at this point.

  • meltoots,
    You’re missing the point. No one is going to go to the CMS website to see the MIPS scores. Every physician rating and review website is going to get the MIPS scores from CMS for free and publish them as quality ratings on their website. They’re going to list them as quality ratings (since that’s what they’re called) and misrepresent the quality of that doctor. Patients won’t do the work to understand what a MIPS quality score is. They’re just going to assume that it’s an assessment of the doctors quality. Many will be hurt because of it.

  • I am a patient, and I go on websites such as Yelp, Physician Compare and ZocDoc every single time that I am looking for a new doctor. I also know many others who do – otherwise people wouldn’t even post reviews online. So, yes there are many patients who check physician performance scores before deciding where to go. If a doctor has poor reviews then I stay away.

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