Not Ready for MIPS? Here's What to Do

Physicians should use this transition year to take advantage of resources to help them comply with MACRA and get started if they haven't already, the AMA president says.

Although it's been just months since half of healthcare providers admitted stark lack of awareness, let alone readiness, to comply with Medicare Access and CHIP Reauthorization Act (MACRA), a key deadline for the law's merit-based incentive payment system (MIPS) track has already come and gone.

David O. Barbe, MD, MHA, a board-certified family physician and president of the American Medical Association, provides guidance on how physicians and medical groups can get up to speed.

HealthLeaders Media: Now that the October 2 deadline for 90-day participation in MIPS has passed, what's your advice to physicians?

David Barbe, MD: For 2017, if a physician hadn't started reporting prior to October 2, then they missed the opportunity to do what I call 'standard reporting.'

However, in our conversations with CMS in preparation for this first transition year, we were able to negotiate a fairly straightforward process where a physician can report on one patient and one quality measure, and that will exempt them from the penalty.

They don't get a bonus for that of course, but they don't get a penalty applied.

HLM: What are the main questions you have been getting from members about MIPS?

Barbe, MD: When physicians have questions, it's mostly around how to participate, which measures to use, and what's going to work for their practice.

So we have developed several tools and resources, including what's called a payment model evaluator, which lets the physician assess his or practice, where they stand in terms of readiness to participate fully, and what is the gap between where they are now and where they need to be.

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We also have a MIPS action plan, which is an even more robust program that will help physicians track their progress toward being able to participate successfully in MIPS.

To get back to your earlier question: Now is the time to get ready for 2018. Now is the time to avail yourself of these resources, to go to the CMS website, and get ready to participate at some level in 2018.

We have to help physicians understand that this type of program—with emphasis on paying for value and quality, incentivizing continued use of the electronic health record (EHR), and making care model changes—is not going away.

HLM: Granted that the regulatory and administrative burden on physician practice is increasingly untenable, medical groups have historically been slow to prepare for regulatory changes. What's your message about being more proactive about compliance?

Barbe, MD: That's the reason that through essentially every outlet that we have to communicate with physicians, we've attempted to help them understand this, to not procrastinate, to roll up their sleeves and begin to gear up for these programs. And I think most of them have.

The biggest hurdle here is quite honestly the business case. What does it cost to gear up, to improve your EHR, to hire the extra personnel that are required, to do a new care model or collect the data, and report the data, etc.? That is all fairly resource-intensive and, therefore, costly.

And the incentives under the previous legacy programs were nonexistent.

HLM: Are MIPS incentives adequate?

Barbe, MD: At least now under MIPS we have an upside opportunity for those groups that perform well. But it's a zero-sum game or budget neutral, and that makes it difficult sometimes for a physician to get too excited about it.

They know that half of the physicians are going to be under a median or mean threshold of performance just by definition. That's the way it's designed to be structured.

The AMA has lobbied hard—and been successful so far—in getting CMS to use the flexibility it has as to where it sets the threshold. But that potentially goes away in the 2019 reporting year by statute, according to MACRA. So we will be gearing up to work with the legislature because we'll need some legislative changes to allow CMS to provide continued flexibility.