MIPS: The Day of Reckoning – Chapter 2 – The Fine Print
Earlier this week I published a post entitled MIPS: The Day of Reckoning. That screed covered my thoughts on the predictability and inevitability of the impact of the first MIPS scores being publicly released in 2018. I will not bore you with how important those scores are. Suffice to say they will affect Medicare Part B reimbursement, professional reputation, provider compensation, practice value, and the ability to obtain and maintain loans. If you are interested in the minutiae of those sub issues, feel free to peruse my earlier thoughts on those topics.
The issue I address today Dear Reader is the regulatory plan behind the public release of those MIPs scores on the Physician Compare website. First let’s take a look at what the Rule tell us will be found there:
- The MIPS eligible clinician’s final score
- The MIPS eligible clinician’s performance under each MIPS performance category (quality, cost, improvement activities, and advancing care information)
- Names of eligible clinicians in Advanced APMs and, to the extent feasible, the names of such Advanced APMs and the performance of such models;
- Aggregate information on the MIPS, posted periodically, including the range of final scores for all MIPS eligible clinicians and the range of the performance of all MIPS eligible clinicians for each performance category
Now let’s take a gander at what the Rule says regarding the opportunity of affected ECs to see their MIPS score before anyone else.
The Act requires the Secretary to provide an opportunity for eligible clinicians to review the information that will be publicly reported prior to such information being made public……the Act also requires that eligible clinicians be able to submit corrections for the information to be made public with respect to the eligible clinician. We finalized a policy to continue the current Physician Compare 30-day preview period for MIPS eligible clinicians starting with data from the 2017 MIPS performance period, which will be available for public reporting in late 2018.
That sounds pretty good. If an EC has a question about their MIPS score they have 30 days to review and submit additional information. You can bet there will be some serious scrambling during that 30-day period. The Rule states, with tongue in cheek, that there is no point in giving more than 30 days because everyone will wait to the last-minute no matter how much time is given.
One last item I find interesting. How will the vast amount of MIPS scoring data be made available at the Physician Compare site? We know the data will be both viewable on the site and also available to download for analysis. It will also be searchable and allow for comparisons according to CMS:
The information is further required to be made searchable by at least specialty or type of physician or other eligible clinician; characteristics of the services furnished (such as volume or groupings of services); and the location of the physician or other eligible clinician.