The start of a new year is often a time to reset mentally, personally, professionally, and beyond. On the professional front, one thing that many optometrists have come to expect as the calendar flips to a new year is change on the regulatory front. Within the Merit-based Incentive Payment System (MIPS), for example, the government produces two rules each year, one proposed and one final, that take effect on January 1 of the following year. Often weighing in at over one thousand pages each, these rules can be a lot to not only digest, but also apply in practice. Concisely summarizing the key ideas and offering a checklist for 2020 success is the aim of this article.
No change to eligibility / opt-in determinations
While MIPS remains the path that most ODs will need to consider if they desire a raise from Medicare for Part B services in the years ahead, it’s important to remember that not all optometrists are required or even eligible to participate. The eligibility determination process and ability to opt-in to the program both remain the same as they were in 2019.
No change to performance category weighting
The four performance categories of MIPS will contribute the exact same amount to a clinician’s MIPS final score as they did in 2019.
Increase in performance and additional performance thresholds
The MIPS scores that an individual doctor’s (or practice’s) score is compared to have increased in 2020. Specifically, a score needs to exceed 45 to qualify for a raise and needs to reach at least 85 to quality for bonus money. Both of these increases are in line with Medicare’s expressed intent to raise program expectations over time.
Increase in potential reimbursement revision
With increasing expectations comes greater opportunity for those clinicians who understand program requirements and perform well. While the published reimbursement revision amount based on 2020 performance is +/- 9%, CMS has predicted the true maximum upward amount to be 6.25%.
Increase in data completeness requirement in Quality
2019 asked doctors to report quality measures on at least 60% of applicable patients, but 2020 increases the expectation to 70%. That means if you’re reporting a measure related to glaucoma and you see 100 glaucoma patients during the year, at least 70 of those patients need to have that measure reported. Otherwise, Medicare will consider the measure unreliable and assign it the lowest possible score.
Change in requirements for groups attesting to Improvement Activities
2019 allowed practices of more than one clinician to get credit at the group level when just one of the doctors completed an improvement activity during the year. 2020 changes the requirement to at least 50% of the clinicians in the practice needing to complete the activity. Thus, a practice of six doctors would need to have at least three complete the same activity during the year to be able to claim it during attestation. Of note, each doctor can complete the activity at a different time during the year, if desired.
Checklist for Success
❏ Determine your eligibility: Are you required to participate or is it optional?
With MIPS being optional for many yet also the program that will control Part B reimbursements going forward, it is critical that eligibility status be understood. Once known, educated decisions about what makes the most sense for you and your practice become possible. Thankfully, CMS offers an eligibility status tool at https://qpp.cms.gov/participation-lookup that allows you to enter your NPI number and get a glimpse of eligibility information at each business you see patients.
❏ Promoting Interoperability: Do you have a way to securely exchange health information with other providers?
Electronic health information exchange with other providers has the potential to account for up to 50% of a score in the Promoting Interoperability performance category. Thus, ensuring that a mechanism is in place to allow it to happen is critical. Many utilize the Direct messaging protocol as many EHR vendors have incorporated it directly into their systems to enhance efficiency. However, Direct is not a required mechanism as CMS allows any system to be used provided it is “secure” under the same considerations as HIPAA. A good exercise is to check with the doctors in your community with whom you collaborate to see if they are sharing data electronically and how.
❏ Promoting Interoperability: Make sure you are delivering PHR/portal credentials to your patients
A big driver behind the requirements of the Promoting Interoperability performance category is empowering patients with access to their health information. The thinking, of course, is that if a patient has access to their data they will be more engaged in their care and the more engaged they are, the better the outcomes MIPS requires patients to have timely electronic access to their clinical data and, for most, this means via a patient portal or personal health record (PHR). The good news is that unlike days of the past, you are “graded” solely on the provision of access to the patient, not on patient utilization. Thus, you are in full control of your success. And with the measure accounting for a minimum of 40% of the Promoting Interoperability score and as much as 100%, a solid internal procedure to make sure credentials are being provided to patients can lead to earning a great score.
❏ Quality: Strongly consider using the electronic clinical quality measures RevolutionEHR tracks for you and learn how they are tracked
While many are familiar with the process of adding quality codes onto the claims they submit to let Medicare know the actions taken during the course of a visit, there’s an easier way to report this data: using the electronic quality measures RevolutionEHR automatically tracks for you. Not only are these measures more efficient since you can abandon adding extra codes on claims, but they also offer the opportunity for higher scoring when comparative benchmarks and bonus point opportunities are considered. If you are not familiar with this option, see details here.
❏ Improvement Activities: Review the list of activities and see which one(s) might fit your practice
The Improvement Activities performance category consists of over 100 different options from which one can choose to participate, and many are often surprised to learn that they are already doing one or more. Most improvement activities require at least 90 consecutive days of participation to receive credit. With that in mind, it can be a good idea to review the list of possible activities early in the year so that you can plan your participation. The Quality Payment Program website offers a listing of all improvement activities and a filtering tool that allows you to cut the list down based on keyword. As an example, if you were interested in seeing only those activities related to referrals, the entire list can be pared down that way. The list and search tool for 2020 can be found here: https://qpp.cms.gov/mips/explore-measures/improvement-activities?py=2020#measures
If the above seems like too much to handle alone, consider joining the ranks of the hundreds of RevolutionEHR practices that have partnered with RevAspire. RevAspire will make all of the requirements easy to understand, help you optimize performance, submit your data to CMS, and protect you in the event a quality reporting audit ever came your way. If you’d like to learn more, feel free to reach out at firstname.lastname@example.org