MIPS: The Chickens are Coming Home to Roost
Last month I wrote a post titled MIPS Data: The Finish Line is Crossed. In that blog I noted that the MIPS data submission window ended April 3, 2018 for the 2017 reporting period. After that date it was too late to make strategic decisions on relevant issues such as individual vs. group submission, selection of Quality Measures, or even the submission method.
The annual MIPS score reported for affected providers is precise but the method to get there is littered with potential pitfalls. The MIPS score affects not only Medicare Part B reimbursement but also professional reputation since the scores will be public. Make the wrong decisions and with the exact same underlying data a provider’s score could vary widely.
CMS had now made it possible for a provider to log in and review their preliminary performance. I heard from a practice administrator yesterday who had done so. I don’t like to report these things but here goes. One of her providers was showing a MIPS score of 95 while another was showing a score of 55. Can you imagine the problems that this might cause? Different levels of reimbursement for the same actions depending on which provider is billing? What are potential patients going to do when they see one of the providers with a much higher score? What could be the effect, if any, on malpractice coverage? We are hoping we can help this practice but as you can imagine there has been ‘a lot of water over the dam’ at this point.
Could this have been avoided? Were MIPS attestation and submission decisions made that produced a MIPS score of 55 irrespective of the underlying data? It is too early to tell now but that is certainly a possibility. MIPS is much more complicated than the Meaningful Use program and the stakes are much higher. It has been obvious that the path to a respectful and valid MIPS score can be a process that requires knowledge, guidance, and planning.
O, one last thing. The practice had 3 providers and their EHR vendor charged $1990 per provider to submit measures. One provider, it turns out, did not meet the minimum threshold that required participation in MIPS. Here’s hoping those chickens flying in over the transom don’t turn into a flock in the months ahead.