COMMENTARY

Disappointed Docs Say: MIPS Is Not Worth It!

Elizabeth Woodcock, MBA, FACMPE, CPC

Disclosures

August 20, 2019

Some of you are spending significant resources in participating in the program. I have met with dozens of staff who spend hours each week preparing reports, monitoring performance, and implementing actions to improve program participation. Physicians are spending money on monthly registry fees, consultants, and technology support.

But despite all the downsides and all the costs, it's critical that you participate in the program!

That's because the penalties are significant. While there are hopes of gaining $840, there are realities of losing more than 7% in 2021 (the impact year for the current performance year of 2019, as the program runs in 2-year cycles). You can't afford that.

However, there are a multitude of ways you can participate without spending thousands of dollars.

First, recognize the exemptions. Small practices—defined as 15 or fewer eligible clinicians—are exempt from the electronic health record (EHR) portion of the program, now called "Promoting Interoperability." With a simple application, that category can be completely ignored.

Small practices also have advantages in the Improvement Activities category, with only half of the requirements needed to fulfill this component of the program.

Next, acknowledge the exemptions. One of the most time-consuming aspects of the program is the electronic exchange of information required for the Promoting Interoperability category. Part of the task participants are asked to complete—"receiving" information—can be excluded on the basis of the exemption, which reads, "Any MIPS eligible clinician who is unable to implement the measure for a MIPS performance period in 2019." 

Furthermore, the government is paying for free resources to assist. These grant-funded, regional organizations offer a wealth of information, but only if you take the opportunity to reach out to them.

Finally, there's no need to go for a perfect score. Reporting 30 points is required to avoid the penalty (up from last year's 15), but it's easy to achieve. Physicians are used to reporting quality data, so that's always recommended; six metrics are scored, but more can be submitted, with the six highest scores counting.

If you have a relatively modern EHR, you can submit them directly through your system. Like the others, they don't have to be perfect either to gain partial credit. (There are a potential 50 points in this category, but you don't need all 50 to avoid the penalty.)

The Improvement Activities are easy. There are more than 100 of them, and all you need is two "high-weighted" activities—or one if you're a small practice—to gain all 15 points that can be awarded for this category in the current performance year. Plan to get in a handful of quality measures, and max out your Improvement Activities. These actions should allow you to compile the requisite 30 points without spending a ton in return.

Managing a practice is all about trade-offs. There's too much work to be done, and not enough time to do it. Given the government's announcement of the paltry 1.68% that will probably be lowered over time, your competitive nature just plays into the government's hands. It's time to lay off. Avoid the penalty, but don't lose your shirt.

CMS recently announced some proposed changes to the Quality Payment Program. We'll see where those are headed when the final rule is released in November.

To echo the physician's astute words when he learned about this year's MIPS bonus: It's simply not worth it.

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