MIPS and Its Impact on Rural Clinics and Hospitals
If you haven’t heard already, performance feedback for the 2021 Merit-based Incentive Payment System (MIPS) performance year is now available. The Centers for Medicare & Medicaid Services (CMS) released the performance feedback, final scores, and associated payment adjustments on August 25th, 2022. Providers can view their feedback and score by logging in to the Quality Payment Program website.
Earlier this year, CMS also released datasets with detailed performance and participation information from the 2019 and 2020 MIPS performance years. In this blog, we will be breaking down some of the most important data and covering why it matters.
What is MIPS?
MIPS, or the Merit-based Incentive Payment System (MIPS) is one of two programs under the quality payment program. These programs move Medicare B providers to a performance-based payment system. MIPS is a seamless combination of three legacy Medicare programs- the Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM) Program and the Medicare Electronic Health Record (EHR) Incentive Program (meaningful use). All providers who meet the criteria and definition of a MIPS eligible clinician need to participate in these programs or they could be subjected to a negative payment adjustment.
Why is MIPS important?
CMS makes the raw data from MIPS available to the public each year – this includes data like clinician demographics (NPI, specialty, locality, practice size), MIPS participation metrics (Medicare volume, exemptions, allowed charges), and MIPS performance [measures submitted, scores, payment adjustments) across all 4 MIPS categories. This data is used by CMS to calculate payment adjustments for Medicare reimbursement for eligible clinicians,
Beginning in 2017 with the passing of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), clinicians participating in Medicare over a certain threshold (based on number of Medicare patients seen and/or amount of Medicare charges per year) are required to participate in the Merit-based Incentive System (MIPS), if not participating in an advanced Alternative Payment Model with double-sided financial risk,
Through MIPS, CMS is encouraging providers to transition to value-based reimbursement models and away from fee-for-service. Under MIPS, eligible clinicians collect and report data across 4 categories, and are subject to payment adjustments on their Medicare Physician Fee Schedule based on performance.
How MIPS Effects Rural Hospitals and Clinics
Small practices, rural practices, and practices located in health professional shortage areas, have reduced reporting requirements under MIPS. Medicare Part B services that are billed through rural health clinic (RHC) or federally qualified health center (FCQH) payment methods are not currently subject to MIPS payment adjustments. However, RHCs and FQHCs may voluntarily report to MIPS to receive a performance score without any impact to their reimbursement. This may indicate CMS could include RHCs and/or FQHCs in future MIPS program years.
- On average, rural providers eligible for MIPS have a lower participation rate than urban providers.
- While most rural and urban providers participate in MIPS as a group, rural providers are more likely to participate in a MIPS APM than urban providers.
- On average, rural providers receive a slightly lower score in MIPS than their urban counterparts.
- Rural providers are more likely to receive a negative payment adjustment under MIPS, when compared to urban providers.
While rewarding provider performance based on quality is a laudable and necessary policy goal, rural healthcare providers continue to be disadvantaged under quality reporting programs like MIPS. Performance results from the first few years of the program indicate that rural providers had a lower participation rate, scored lower performance points, and received lower payment adjustments when compared to their urban counterparts.
To ensure that rural healthcare providers are successful under value-based payment systems like MIPS, it is urgent that policymakers continue to improve MIPS in future program years, consider additional policy measures to ensure a level playing field for rural and urban providers, and support additional research to identify barriers to provider participation and performance.
How Azalea Analytics Make MIPS Easy
Azalea Analytics delivers a turnkey and fully integrated MIPS solution, complete with daily dashboards, best practices consulting, and a one-click electronic form for filing and reporting to CMS directly. As a CMS-approved clinical registry, we are required to attend multiple monthly meetings to stay on top of any changes or updates to the program.
Interactive Performance Dashboards keep the practice and the providers on track while our Clinical Quality dashboards with drill through allow for advanced workflows for each CQM to effectively address gaps-in-care and improve performance. In addition, our automated reporting gives the providers weekly or monthly performance reports, complete with comparisons to goals and specialty benchmarks.
Rest assured as our seasoned team of consultants oversee your practice’s participation throughout the year to save time, insure compliance and maximize results.