Just because rehabilitation professionals are not currently included in the merit-based incentive payment system (MIPS) as eligible providers does not mean that rehabilitation professionals should not be thinking about this type of payment model.
Right now eligible providers have somewhat of a grace period. The eligible providers will experience MIPS where quality reporting is the highest weighted category and by 2020 quality becomes less weighted as cost is included in the MIPS performance metric. Rehabilitation providers may not be granted the same "Pick Your Pace" option that currently happened for 2017.
Below are the three ways that you can prepare for Medicare quality payment programs.
The very first detail you need to be aware of focuses on the volume of patients who you treat under Medicare B. As of right now providers receiving payments of $30,000 or less from Medicare OR provide services to 100 or fewer Medicare subscribers do not need to think about MIPS. Your first step is to analyze a few years of data within your system to know your volume of Medicare subscribers.
The focus on MIPS will be performance scores. 2020 is when MIPS begins being rolled out to its fullest capacity. The four areas MIPS will consider in the performance score includes quality, cost, advancing care information and clinical practice improvement activities. It is imperative to know the final destination of MIPS to understand your participating strategy. Yes, it is a strategy because if rehabilitation professionals have a multitude of quality measures from which to report, I'd advise knowing your strengths. Report the quality measures in which you are strong. It seems the quality measures may be familiar and may be the same as the Physician Quality Reporting System measures. When MIPS opens the process to rehabilitation professionals, plan on reporting one outcome measure. This is not something that has been included in the past. If you search by keyword for "outcome measures" within the quality payment program, you'll see that FOTO provides 4 of the 5 available options of reportable outcome measures. At the moment, no other outcomes management system has been accepted as meeting Medicare's quality payment program standards. As I'm thinking about quality reporting, you should also determine how you will report the quality measures. FOTO became an approved MIPS quality registry in 2017.
The last challenge is to remember that by 2020 cost is factored into the MIPS equation. The game is changing from reporting to also efficiently delivering outcomes. The time is now to start collecting and analyzing patient reported outcome measures. You need data to analyze. It is a humbling experience for clinicians to be truly evaluated on their performance with real data. You could use paper and pencil tools, but this won't be robust enough. Computer adaptive testing is a much better option because it is more sensitive to a patient's change in function and more readily captures that change. Because FOTO has been built with risk adjustment and predictive analytics as part of its heart and soul, clinicians will immediately know (via patient specific reports) both predicted improvement in functional score and expected number of visits for each patient evaluated. FOTO uses the risk adjustment and predictive analytics when analyzing aggregated data to create scorecards for each clinician. In 2021, MIPS will equally weight quality and cost. The higher the quality with lower cost will lead to financial reward. Waiting until required to report outcome measures will lead to penalties. The process needs to be implemented now because of the learning curve associated with collecting and analyzing data. Based on what is learned via the data, clinical decisions and practice patterns may need to change.
What have you been doing to be MIPS ready?
Until next time,