Plan Now for MIPS Reporting in 2018

Jackie Rogers

The end of the year is always hectic for oncology practices, but 2017 is proving exceptionally busy as CMS' Quality Payment Program (QPP) transitional year comes to a close. Many practices participating in the Merit-based Incentive Payment System (MIPS) are hyper-focused on their data collection and organization for performance year 2017. Although it is easy to focus on just the current year, oncology practices should not neglect the opportunity to plan for 2018. For all practices—regardless of the extent of their participation in MIPS—this is the time to get organized and develop an action plan so they can hit the ground running next year.

Although some practices may feel like they have time to get organized or are on the fence about participating in 2018, next year will be crucial to oncologists for several reasons. At AmerisourceBergen’s Quality Reporting Engagement Group (QREG), we estimate that the average 2019 financial costs for nonparticipation in 2017 will be approximately $8,283 per oncology physician, excluding Part B drug revenue, and $74,680 including Part B drug revenue. This is based on ION Solutions’ latest InfoDive benchmarks from August 2017 containing financial data for 450 physicians.

Based on how they perform, oncologists will receive either an upward or downward adjustment to their Medicare Part B payments. In other words, oncologists will pay either more or less, up to a certain percent. We know that these adjustments will continue to occur more often, affecting 4% of payments in 2019 and up to 9% in 2022. Oncologists could see a substantial cut or increase in Medicare payments, depending on their MIPS score.

Adjustments are felt 2 years after the performance year, so the actions a practice takes today will affect the future. Most important, the proposed rule in front of CMS that outlines amendments to the 2018 QPP indicates that the reimbursement adjustment could be applied to Part B drugs furnished by a MIPS-eligible clinician. We are all waiting to see how this is addressed in the MIPS final rule, due to be published in early November. With so much money in question over the long term, participating will ensure a practice’s financial viability going forward. Participation in MIPS also has an impact on a practice’s reputation. A major goal of the QPP is to foster patient engagement. Medicare will publish MIPS scores publicly on its Physician Compare website, encouraging patients to shop around and truly act as prudent consumers of healthcare. With a click of a button, a patient can see a physician’s entire MIPS score and compare that with the performance of all physicians, not just other oncologists.

Scores are determined by the amount of data that practices submit, whether it is simply test data (1 quality measure or 1 improvement activity for any point in the year), partial data (90 days’ worth), or full data (for the complete performance year). Because composite performance scores and adjustments are determined based on the amount of information submitted and the completeness of the data, we recommend that practices shoot for the stars and submit either 90 days’ or a full year’s worth of performance data from 2017. That would give CMS more information to weigh and ultimately give patients a more complete view of a practice.

Recently, our oncology practice clients have been asking us how to prepare for a complete submission in 2018, learn all the rules, and engage all staff. For other oncology practices with the same questions, I have some practical advice. To effectively participate in MIPS, by the end of this year, choose an internal champion—someone who can dedicate significant time and energy to organize and execute the practice’s effort over the next year. A small practice that cannot fully dedicate 1 person can assign a task force of 3 or 4 people to share the responsibilities. Either way, the goal between now and the end of this calendar year should be clear: Be able to articulate how the practice will report to MIPS in the year ahead.

So how do you get there? Allow the champion or task force an immersion period of 4 to 6 weeks to review the regulatory components and performance categories, study the 19 quality measures for oncology, and build an action-plan framework. The framework should lay out how the practice plans to report—will it be as a group or as individuals? From our experience, oncology practices may want to strongly consider reporting as a group. If providers decide to report individually, a practice may lose a level of control. On the other hand, unengaged members may drag the score down for an entire practice that reports as a group.

The framework should also indicate the reporting pace—will partial or full data be reported? As previously mentioned, the best way to maximize a practice’s MIPS payment adjustment is by fully participating (either 90 days or the full year) with data. Then, outline the quality measures that fit the best. Before deciding on the which 6 to report on, the team should evaluate the practice’s electronic medical record (EMR). Today, EMRs are subjected to rigorous certifications for various measures. Call the EMR vendor to find out which of their measures can be reported on. From there, the team will understand the data and workflows needed to capture and monitor for reporting after the first of the year. Once these aspects are outlined, the next step is selecting appropriate improvement activities and monitoring the practice’s score in the Advancing Care Information category.

An important part of monitoring progress entails uncovering what is already being done. For example, is the practice already reconciling medications? How are patient engagement and the exchange of information using the EMR promoted—is there direct messaging for providers to communicate or a portal where patients can see results, schedule appointments, and request refills? Chances are, much is already happening in these areas. Develop a list of how the practice supports care coordination, beneficiary engagement, and patient safety. Then, figure out how the components are being documented internally or by the EMR. Outline the programs that can evolve and become stronger, and then determine how to monitor them over the performance period.

Just as it was under Meaningful Use, security continues to be a required measure. CMS wants to know how practices are protecting patient information, such as completing or reviewing a security risk analysis, conducting Health Insurance Portability and Accountability Act (HIPPA) training for staff members, and auditing the technical, physical, and administrative safeguards in place for protecting patient information and the practice as a whole. Determine what areas require focus on for security purposes for the current reporting period.

Heading into the next performance year, use the framework to compile a book of evidence. This physical and digital book should have a section for each performance category and contain data that will be used for reporting. It should also contain screenshots providing step-by-step instructions on how the data were pulled. This level of detail will support the practice during an audit by CMS. Practices have a 6-year audit window in MIPS for each year of data submission—it is not an “if” but a “when” scenario. When the time comes, practices will not have to retrace their steps if year-end reports, supporting data, and background on how the information was collected are neatly organized in a book of evidence. Our QREG team has supported more than 120 audits for practices, and these books of evidence helped us pass every single one. At the end of each performance year, multiple people within the practice should know where the final, physical book of evidence is stored in the office and where the digital copy is saved on the practice’s computer system. Keep in mind that CMS has stated that a book of evidence should be maintained for 10 years.

Before the end of this year, the champion or task force should host a meeting with management and providers to outline the practice’s MIPS plan for the year ahead. By the end of the meeting, attendees should be able to clearly articulate the plan and value of participating. With so much year-end planning happening already, it might seem difficult to dedicate more time and resources to programs like MIPS. However, with payment adjustments increasing every year and the public information available about each MIPS-eligible clinician’s performance scores, oncologists cannot afford not to plan and take advantage of this program. Assembling the right team, building the right framework, and strategizing a game plan before the next performance year will ensure that a practice is on track to succeed.

For practices that do not have staff members who can be dedicated to researching and monitoring MIPS, enlisting an outside consultant is an option. Be sure to choose one who has a proven track record with Meaningful Use and the Physician Quality Reporting System (PQRS).

Jackie Rogers is quality reporting engagement group manager for ION Solutions of AmerisourceBergen.