How the Bipartisan Budget Act Will Change Your MIPS Program Compliance Strategies

The Merit-based Incentive Payment System (MIPS) program has been around for a few years, but many clinicians and groups are still struggling with their compliance. And now you have another curveball thrown at you: The Bipartisan Budget Act of 2018 (BBA) will change several key aspects of MIPS and, subsequently, your efforts to comply.

The BBA will have a significant impact on the MIPS program and what you need to do to avoid a Medicare payment penalty, in three crucial ways, warns healthcare compliance expert Stephanie Thomas in her webinar, “MIPS and MACRA — How to Make Sure You’re Doing Things Right!

  1. Enjoy a More Gradual Penalty Threshold Increase

Pay attention: The BBA gives the Centers for Medicare & Medicaid Services (CMS) more flexibility in determining a gradually increasing performance threshold through 2021, according to the New England Quality Innovation Network.

Under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the MIPS performance threshold you need to avoid a payment penalty would be set at the average MIPS performance score—the mean or median performance of all participants beginning in 2019. CMS set a MIPS performance threshold of three points for 2017 and 15 points for 2018.

But because the MIPS performance scores were unknown for the 2017 performance year, this increase would likely mean that a significant number of eligible clinicians (ECs) and groups would fail to meet the threshold and receive a 7-percent or larger pay cut.

Good news: But the increased flexibility in determining a more gradually increasing performance threshold afforded under the BBA will allow you to more effectively develop quality improvement and reporting strategies to meet MIPS requirements.

  1. Expect Stalled Implementation of Cost Performance Category

Old way: MACRA allowed CMS flexibility during reporting years 2017 and 2018 in weighing the performance categories, according to the Medical Group Management Association. CMS weighted cost at zero for 2017 and 10 percent for 2018, and then would have needed to count cost at 30 percent of the total MIPS score beginning in 2019.

But developing cost measures has been an ongoing effort and more time is necessary to construct and test them. One big problem was that the two existing measures (aggregate cost and Medicare spending per beneficiary) tagged some physicians with costs they can’t control and left others with no attributed costs, and punished practices with high-risk or medically-complex patients.

New way: Thanks to the BBA, CMS has more flexibility to count cost measures at between 10 percent and 30 percent of the total MIPS score for three additional performance years (until 2021). The law also eliminated the year-over-year improvement scoring for the cost category during reporting years 2018 through 2021.

  1. Understand Changes for Part B Drugs

Another key modification from the BBA is that the MIPS payment adjustment percentage will apply to only Medicare Part B “covered professional services”—i.e., no MIPS payment adjustment for Part B drugs, according to SA Ignite. This means that the MIPS financial incentives and penalties (in absolute dollars) will be reduced somewhat.

Also, the low-volume exclusion for MIPS eligibility will now be based on covered professional services only, rather than on services and items such as Part B drugs. The low-volume exclusion will exclude slightly more clinicians than before the 2018 performance year.

Important: Instead of 2019, the MIPS post-transition period now begins in 2022, at which time the cost category will be weighted at 30 percent of your score. Also in 2022, the MIPS performance threshold must be the mean or median of the national historical MIPS scores.

Key takeaway: Keeping up with all the requirements and changes to the MIPS program can send your head spinning. But you must gain a solid understanding of how to comply with MIPS and how laws like the BBA impact the program, so you don’t get a Medicare pay cut, stresses Stephanie Thomas in her webinar, “MIPS and MACRA – How to Make Sure You’re Doing Things Right!” In this instructive session, she helps attendees identify the easiest ways to report to Medicare—and avoid reimbursement cuts.

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