How to Prepare Your Radiology Department for MIPS


The Merit-Based Incentive Payment System (MIPS) officially took effect on January 1st, 2017. Although the first adjustments will not be applied until 2019, the Medicare Part B payment adjustments will be applied based on 2017 performance. It’s vital, then, that radiology departments take action now to be prepared for that first evaluation.

Read on to explore what MIPS is, what it means, and how radiology departments can prepare for this first evaluation year.

A Quick MIPS Overview

MIPS is less about adding new rules and more about streamlining and synthesizing existing quality programs. It synthesizes aspects of Meaningful Use (MU), the Physician Quality Reporting System (PQRS), and the Value-Based Modifier (VBM) to establish four categories of eligible clinician performance. Together, the categories add up to a final score on a 100-point scale. The four categories are:

  1. Quality. Quality will account for 60% of the score for the 2017 performance year. This category borrows reporting methods and measures from PQRS and VBM.
  2. Advancing Care Information. This category is a modification of MU and counts for 25% of the 2017 score. Instead of a pass/fail compliance program, it’s a scoring system comparing a physician’s measurements to industry benchmarks.
  3. Improvement Activities. For this category, (15% of the overall score), physicians choose activities from a list of 90 potential activities designed to support care coordination, population management, health equity, and more.
  4. Cost. This category can be reported on for 2017, but will not affect the total score. In future years, however, it will be weighted to contribute to the overall score.

Follow the link to take a more in-depth look at MIPS categories.

Why MIPS Matters

There are two key reasons physicians need to be concerned about MIPS scores: reputation and adjustments.

According to SA Ignite CEO Tom Lee, it’s vital to consider the impact of MIPS scores on reputation. Final scores for each performance year will be made available to third-party physician rating sites and for consumers to browse. These scores are bound to the physician, not the health system, so will follow physicians even if they change location.

Lee says, “A provider’s public reputation does not yet override other selection factors, such as referrals from physicians…However, as adoption of high-deductible insurance plans grows, consumers are increasingly paying more out-of-pocket for health care and are seeking to make more-informed choices. Many providers are concerned that the status quo may be disrupted…by the proliferation of ratings sites and the rising tide of provider quality information being published by the likes of CMS.”

MIPS scores will also determine Medicare Part B adjustments, which can range from a 9% penalty to a 9% incentive, based on the total score. The incentive, however, is multiplied by a budget neutrality factor, which can be as high as 3x. With the possibility of a 10% performance bonus, the incentive could be 37%.

As profit margins narrow, these adjustments could have a sizable impact for good or ill.

2017 Is Unique for MIPS Evaluation

Since 2017 is a transition year, the system allows for some flexibility in participation, while incentivizing those who fully comply. Here are the options:

  • Claim Exemption through Advanced Alternate Payment Model (APM) Participation: Health systems that participate in a qualifying APM can claim full exemption from MIPS. These programs generally must be run by CMS and fulfill additional requirements, such as using certified EHR technology and basing payment on quality measures comparable to MIPS.
  • Submit a Full Year Report:
    If you submit complete data for 2017 to Medicare, you are eligible for a positive payment adjustment.
  • Submit at Least 90 Days:
    Reporting a partial year makes you eligible for a neutral or positive payment adjustment.
  • Submit at Least One Measure:
    To avoid a negative payment adjustment, you must submit at least one measure in the Quality, ACI or IA categories.
  • Submit no Reporting:
    Those who choose not to participate and are not exempt are subject to a 4% negative payment adjustment.

According to best practices firm Advisory Board, “Despite new flexibility, providers should not consider 2017 a year off. Instead, we recommend reporting on all possible metrics. Providers who take this leap early will receive performance feedback, which will allow them to choose higher-scoring metrics in the future and thereby position them for long-term success.”

How Radiology Departments Can Prepare for MIPS

Here are just a few of the many actions you and your department can take to ace your first MIPS reporting year.

First, estimate your current MIPS score. Your MU, VBM, and PQRS scores can give you a general idea of how well you’re doing and in what areas you should focus attention.

Second, help educate your organization, particularly upper-level executives. Let them know what your department needs to report on, where they should focus effort, and why.

Third, look at maximizing your quality score. Maria Calamaro, of Healthcare Administrative Partners says, “Since this category alone could be the major determinant of a radiology EC’s reimbursement adjustment under MIPS, it’s not too early to begin to define the systems and processes that will be needed to gather the data for measures reporting.”

One area of particular interest is a bonus for end-to-end electronic reporting. If your organization is all-electronic, you can earn one percentage point for each measure you report, for up to 10% of your possible performance points.

Fourth, choose your improvement activities to align with the best practices your organization is already following. For example, there are two care coordination measures that will be simple for organizations with a system like McKesson Radiology™ (McKesson technology solutions is now Change Healthcare): Providing specialist reports back to the referring physician, and timely communication of test results. Intelligent medical imaging workflow can make it easy to achieve these care coordination measures.

Change Healthcare Can Help with Your MIPS Transition

Once health systems have time to adjust, MIPS promises to be a simpler way for physicians to report on the metrics that matter to the CMS. The transition is not without its challenges, however.

Change Healthcare Business Performance Services for Radiology can help you make the right choices as you transition to MPS. We offer experience client managers to help find the approach that makes sense for your group. They can guide you through choosing individual or group participation, claims-based or registry reporting, and help you choose which measures make most sense for your group to report on. Contact Change Healthcare today to learn more.

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