The Impact MIPS Performance Scores in the Public Domain
As per the MACRA statute Merit-based Incentive Payment System (MIPS) performance scores for individual clinicians and groups will be made available to the public each year. They may be published on the CMS Physician Compare website or released through some other mechanism (e.g. an online database). Many organizations have raised concern over the potential impact of these scores on health care providers and their organizations.
The first MIPS performance scores will be published in late 2018 and will reflect MIPS performance in 2017. Scores will range from 0-100 points and will be assigned to individual clinicians and groups. The MIPS performance score will will not be updated until the 2018 MIPS performance scores are released in late 2019. The MIPS performance scores will be available to patients, clinicians, other healthcare organizations, payers and other stakeholders.
MIPS performance scores have the potential to affect organizations positively or negatively in the following areas:
– Patient retention
– Patient recruitment
– Provider retention
– Provider recruitment
– Clinician contract negotiations
– Referrals from other providers
– Payer fee schedule negotiations
– Staff morale
– Overhead associated with explaining the meaning of MIPS performance scores to patients
MIPS performance scores follow physicians that transfer to another organization, meaning that the scores will be impactful in every setting of care for an entire year.
At this writing relatively high performance in MIPS in 2018 can still be achieved if a carefully designed program were to be implemented as quickly as possible. In theory, a clinician or group could obtain a relatively high MIPS performance score if they implemented a MIPS performance initiative as late as October of 2018. CMS may elect to reduce the reporting period for the MIPS Quality performance category to 90 days (from the current 365 days).
Clinicians and groups were given the option of submitting a minimum amount of data (e.g., one quality measure) to avoid penalties based on performance in 2017. In 2017 practices that achieved score of 3 points or higher avoided penalties. However, MACRA mandates that all MIPS scores be published, including score for groups that chose the minimal reportingi option under the CMS “Pick Your Pace” initiative. Clinicians and groups will have these scores, many of them as low as 3 points, published in the fall of 2018. Unless Congress elects to remove the mandatory MIPS performance score reporting requirement low scoring organizations may wish to evaluated their communication strategies to patients and other stakeholders.
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