The Merit-Based Incentive Payment System quality reporting period begins at the start of 2017, with the payment adjustment period following two years after. The Merit-Based Incentive Payment System is a component of the biggest overhaul of the Medicare payment system in recent history, the Medicare Access & CHIP Reauthorization Act. I believe it’s important to understand the implications of MIPS in order to help providers thrive in what will be a highly competitive couple of years.
The first thing to note about the Merit-Based Incentive Payment System (MIPS) is that is not just a facelift or aggregation of the existing quality reporting systems. The feature I find most interesting and potentially revolutionary about MIPS is a line in the MACRA Proposed Rule, which states, “We propose public reporting of a MIPS eligible clinician’s data; in that for each program year, we will post on a public Web site (for example, Physician Compare), in an easily understandable format, information regarding the performance of MIPS eligible clinicians or groups under the MIPS.”
In other words, the CMS will publish the MIPS Composite Score and the performance rating of every Eligible Professional (EP) under each MIPS Category to the public, for everyone to see. How well an EP does to government standards will be put on an easy-to-read national database for everyone to see, share, and utilize.
This seemingly minor facet of MIPS cannot be understated. To understand the impact of the composite score, let’s look at MIPS from a different angle.
MIPS Creates a Cutthroat Competitive Market
We must look at the public release of the MIPS Composite Score from a marketing perspective. Who will see—and most importantly utilize this database?
- Third-party Review Sites: The public release of MIPS scoring throws Eligible Physicians into the highly polarizing, multimillion-dollar industry that is online healthcare review sites. Websites like Consumer Reports and Health Grades will be quick to incorporate MIPS scoring into their databases, and providers will be put under review whether they like it or not. This is not something providers can sweep under the rug. These websites can make or break a provider through reputation alone, and it is extremely hard to bounce back from a low rating because, as we’ve seen with CMS’ Hospital Compare System, ratings are based on the performance period which ends 15 months prior to the release of the score. Conversely, a provider given a positive rating will keep it for the next 15 months. The impact of this revenue-wise is incalculable.
- Consumers: Consumers will be able to see the performance of providers, through government and third-party websites. Connecting the dots with this audience is very simple: better score equates to more patients and more revenue. A positive MIPS score will be a factor in whether or not a patient continues doing business with a provider.
- Other Eligible Physicians: Eligible Physicians may look at a practice and determine if they want to do business with you, from outsourcing to referrals, based on your MIPS Composite Score. Providers may use the composite score as a factor in business decisions, keeping in mind that patients can also see who they are being referred to, and how they rate under MIPS.
- EHR Vendors, Clearinghouses, Payers, etc.: Suffice it to say, everyone in the healthcare pipeline has access to the composite score and may act upon it. A potential business partner can be encouraged by a high MIPS Composite Score, and be more willing to do business with the provider.
Because the MIPS score is publicized, public reputation becomes a critical factor in the success of a practice. Providers will be judged for everyone to see based on how well they perform to government standards. In this sense, the reputational impact of MIPS is potentially magnitudes more financially impactful than the positive or negative payment adjustments. Payment adjustments can be compensated for on a yearly basis—however, a strong reputation can positively impact the finances of a practice for years to come.
What to Do with Your MIPS Composite Score
Keep in mind that those who choose not to participate in MIPS and are eligible will get a zero in each category. Needless to say, getting a zero will plummet a provider’s MIPS score, and therefore their reputation to the ground. However, a high MIPS Composite Score can be a huge boon to your practice.
Utilize the virality and interconnectedness of social media to advertise your practice with the MIPS Composite Score. It is possible that third-party review sites will not feature your practice (positively or negatively), or will feature it incorrectly (small sample sizes, data), which makes self-publishing the MIPS score a viable option. Self-publishing ratings allow you to be in charge of how you are presented online and will give you a hands-on approach to patient engagement. You may promote your score to consumers and show them that you are a top-notch provider of stringent government standards.
Final Thoughts about MIPS
A couple of final thoughts on MIPS:
- Know whether or not to self-publish your rating: It is up to the provider to decide whether or not they want to promote their score. They can let the CMS/third-party review sites take control over how consumers see them, but it may be wise to take initiative. A provider may publish a not-so-great rating to promote transparency and show consumers a willingness to improve, or they can choose to keep their MIPS score under wraps. However, with MACRA getting so much publicity, smart and high performing providers will be looking for any and every way to promote their MIPS Score.
- Get a good grasp of the market: The public release of the MIPS Composite Score takes influence from the existing CMS Hospital Compare system, which has its own niche in the healthcare industry. Hospitals are obviously on a different scale than private practices, but providers can take note of best practices and how the reputational score will affect revenue. The smaller scale of EPs will make self-promotion to consumers more important.
- Understand the performance-to-published rating period: If we take note of how the CMS published the Hospital Compare star rating, there is a 15 month lag period from the performance period, to when the rating is posted. Therefore, a provider will be stuck with whatever score they receive for 15 months. This can be beneficial or detrimental to a practice.
Only time will tell how the public release of the MIPS score will impact providers. Important questions such as, “how will our bottom line be affected by a 50/100 score versus an 85/100” need to be asked and answered. An experienced marketing team may be vital in creating and maintaining the reputation of a practice. Remember that in the healthcare world, it is easier to maintain a strong reputation, than trying to salvage or rebuild a tarnished one. Estimate your MIPS score, and prepare for what I believe will be a very financially productive 2017, for providers who take advantage of the MIPS Composite Score.