Physician MIPS Participation Determines Smiles or Haircuts
April 3, 2018 at 8 PM marks the data submission deadline for 2017 Physician MIPS Participation. We will hear over the next few months how many physicians participated, and how many chose to take a haircut (reduction) on their 2019 Medicare payments.
The Centers for Medicare and Medicaid (CMS) spent the last two years communicating about the Quality Payment Program (QPP) and its January 1, 2017 start. QPP eliminated Congress' annual "doctor fix". The program implemented the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
2017 was the transition year for QPP. It created two "value-based" payment models under Medicare for ambulatory care:
- Medicare Incentive-based Payment System (MIPS) and,
- Alternative Payment Models (APM).
Both programs are "budget neutral". Medicare will pay bonuses to physicians over the baseline from the prior year. Penalties from other physicians provide the pool for these bonuses.
The QPP Processes for Physician MIPS Participation
CMS educated physicians who received Medicare payments in 2016 to follow these steps:
- Physician validate if they are eligible under the QPP. CMS provides a quick way for physicians to check this through a LINK on their website.
- There are approximately 300,000 providers included in the APM and MIPS look-up files.
- QPP excludes some physicians - due to being new to Medicare or having a low volume of Medicare patients.
- Medicare included many physicians who do procedures or office visits. This included many that other programs, like Meaningful Use had excluded.
- Physicians should understand how QPP changes the Medicare payment rules.
- The program combines several existing fee adjustment programs, rolling them into the QPP: EHR Meaningful Use, PQRS and the VPM Programs.
- Physicians may participate at the individual or group level.
- Medicare allows providers to form virtual groups for economies of scale.
- Medicare gave eligible physicians four options for 2017 participation:
- Not participate - and receive a 4% reduction (penalty) of their 2019 Medicare payments.
- Submit 90 days of data - and avoid any penalties.
- Submit full year data - avoid penalties and possibly earn some bonuses up to 4% over the Medicare baseline.
- Participate in an APM or advanced APM. See CMS Link for overview.
- Regardless of participation level in 2017, they must submit QPP data to CMS by end of first quarter of 2018 (April 3, 18 due to holiday).
- Medicare will solicit provider feedback during Q2-3 2018 as they analyze the Q1 data submissions.
- Medicare will provide physicians 2019 Medicare payment adjustments in Q4 (Oct-December).
Physicians are Ultimately Responsible for their QPP Impact
Medicare provides numerous videos, face sheets and webinars (Click HERE) to help physicians best understand their responsibilities and processes under QPP.
Physician MIPS participation will become apparent as CMS closes the data submission process April 3rd. Physician surveys continue to show that some physicians have not taken action, because they:
- Do not understand the program.
- Do not think they have to participate.
- Believe the cost and effort to participate exceeds the penalties or the bonuses.
- Think QPP, MIPS, APM and MACRA will go away.
While there have been plenty of refinements to QPP in the past year, it is unlikely that these programs will go away. However, the fourth quarter will be interesting as physicians get their 2019 Medicare fee schedule adjusted for their 2017 efforts (or non-participation). As the picture above portrays, many will receive bonuses... some will receive haircuts. There will be an 8-percent spread between the top performers and the non-performers. For many, this may be a wake-up call.
Search our other MACRA QPP Resources or visit our Glossary of MACRA QPP Terms.
2018 Determines Physicians' 2020 Medicare Payments
It's Not to Late to Get on Board
Though many physicians chose to sit on the sidelines in 2017, this year's participants need to submit a full year of Merit-based Incentive Payment Program (MIPS) data to avoid penalties to their 2020 Medicare payments. Qualified physicians who chose not to participate will take a 5% reduction in Medicare payments for 2020. This budget neutral program will then distribute this amount in the form of bonuses. While some will merely break even (i.e. avoid any penalties), others will earn up to 5% over the Medicare baseline.
This sets the difference between non-participants and MIPS top performers at 10%. That is a sizeable loss for physicians who see a significant number of Medicare patients in their practice.
Practices Can Access the Free Resources
Every physician or practice manager who excepts Medicare patients should visit the CMS website and determine if they are subject to MIPS participation. The April 3, 2018 deadline to submit your 2017 data has passed. However, it is not too late to get started and show progress for this year.
The Centers for Medicare and Medicaid (CMS) have a wealth of free information on their website to help you avoid future penalties and even earn some bonus money for your practice improvement and cost reduction efforts.