On Your Mark, Get Set, Collect Data: Are Providers Ready for Oct. 2 MIPS Deadline?

Ready or not, the Oct. 2 MIPS deadline is here.

For Medicare providers complying with MACRA (the Medicare Access and CHIP Reauthorization Act of 2015)’s Quality Payment Program (QPP) through the MIPS (Merit-based Incentive Payment System) track, they must now begin collecting performance data on the 2017 care they have provided and how technology has helped if they are to avoid penalties.

The deadline for submitting that data to the Centers for Medicare & Medicaid Services (CMS) is March 31, 2018.

Medicare providers reporting under MIPS continue operating under a fee-for-service model. But they are eligible for performance-based payment adjustments (either bonuses or penalties) depending on the data they submit to CMS. The data they submit must illustrate increased quality of care, improvement activities, the effective use of electronic health records (EHRs) and coordination across the care continuum.

The first payment adjustments based on 2017 performance data take effect on Jan. 1, 2019. Depending on the data submitted to CMS by the March 2018 deadline, providers will see their Medicare reimbursements go up, down or remain the same.

Reporting Options Under MIPS for 2019

Providers complying with the QPP through the MIPS track have four reporting options, according to CMS:
  1. No participation in QPP = 4% Medicare payment penalty. If providers refrain from providing any 2017 performance data to CMS, they will be hit with a -4 percent Medicare payment adjustment.
  2. Minimum participation in QPP = break even. If providers submit the minimum amount of 2017 performance data to CMS, they could mitigate the risk of a downward payment adjustment.
  3. Partial participation in QPP = break even or bonus. If providers submit three months of 2017 data to CMS, they could either break even or receive a bonus of up to a +4 percent Medicare payment adjustment
  4. Full participation in QPP = likely bonus. If providers submit the full year of 2017 performance data to CMS, they could receive a positive Medicare payment adjustment of up to +4 percent.

Implications of MIPS, Broader Shift to Value-based Reimbursement

The goal of MIPS, and MACRA’s broader Quality Payment Program, is to equip providers with tools to provide better quality of care to Medicare patients while also curbing U.S. healthcare costs.

But the program encourages less utilization of acute-care services, and providers who depend on those services to stay afloat—notably, skilled nursing facilities (SNFs)—have already felt the pressure of the broader shift to value-based reimbursement. According to recent data from the National Investment Center for Seniors Housing & Care (NIC), in Q2 2017, Medicare patient day mix at SNFs reached the lowest level in NIC’s five-year time series.

“Medicare patient day mix hit a new low at the end of the second quarter, falling 119 basis points from 13.9 percent in March to 12.7 percent in June,” NIC said. “Since February of 2015, with the start of pressure on Medicare mix, it is down a significant 378 basis points from 16.5 percent. Year-over-year, it declined 88 basis points from 13.6 percent.”

SNF occupancy during Q2, meanwhile, fell to the lowest level in the last five years to 81.7 percent—100 basis points lower than Q1’s 82.7 percent.

Under MIPS and MACRA’s broader QPP, more medium and larger medical practices that have, so far, withstood the economic and political pressures driving the consolidation trend in healthcare, are going to find that they are also subject to its forces.

A larger share of medical practices will find themselves unable to remain financially viable amid greater reporting burdens and associated costs, and they too will throw in the towel by closing or being acquired.

The AMA offers a customizable MIPS Action Plan tool to help providers measure their performance against key MIPS dates and steps, which can be used to create a plan or improve upon an existing one.
For information about how your healthcare organization can remain financially viable under MIPS or MACRA’s Alternative Payment Models (APMs) track, contact Patrick Pilch at ppilch@bdo.com. Read more about MACRA here on our blog.