Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient. The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring. This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.
According to the CMS MIPS Cost User Guide, “Feedback on 2018 MIPS performance year cost measure performance will be available in summer 2019 and CMS is looking to incorporate beneficiary-level data, if technically feasible.” This material will allow practices to know whether or not Cost was a factor in their MIPS Final Score and, if it was, then they will learn how they performed in 2018. The 2018 reporting period will determine the practice’s Medicare fee schedule adjustment factor in 2020.
The first time Cost became a factor in MIPS scoring was during the 2018 reporting period, when it was 10% of the Final Score. For the 2019 reporting period, Cost will be 15%. However, as with all MIPS scoring, if the Cost category does not apply to a practice then the Quality performance category absorbs the value of the category not applied. For many radiology practices neither the Cost nor the Promoting Interoperability category will apply, so the Quality performance category becomes re-weighted to represent 85% of your total MIPS score with the 15% balance attributed to the Improvement Activities category.
In those instances where radiologists do receive a score in the Cost category, they will most likely be measured by their Medical Spending Per Beneficiary (MSPB) score. The MSPB measure assesses total Medicare Part A and Part B costs incurred by a single beneficiary in the period surrounding an inpatient hospital stay. The MSPB episode window begins 3 days before an admission and continues through 30 days after hospital discharge. Each MSPB episode is attributed to a single Eligible Clinician (EC) or group practice that reports under a single Taxpayer Identification Number, determined as the EC or group that billed the largest amount of Medicare Part B claims during the episode period.
In order for a radiology practice to receive a Cost score, they must have at least 35 MSPB episodes attributed to them. Diagnostic imaging that takes place immediately preceding the admission, such as pre-admission testing or emergency department imaging, counts toward the dollar volume as does imaging or interventional procedures performed during the inpatient stay. With the cost value of radiology services being generally higher than Evaluation and Management services, radiology could easily become the largest cost factor for some patients. Note that not every hospital admission qualifies for the MSPB measure. The CMS User Guide details the attribution exclusion criteria, and also contains more detail on the calculation of the MSPB score.
Our blog contains an earlier article on how the Cost category will affect radiology practices, and we provided updated information in our annual Review of the Medicare Quality Payment Program for 2019.
Please subscribe for updates to our blog. We will be posting a review of the Medicare Physician Fee Schedule (MPFS) and the Quality Payment Program (QPP) Proposed Rules for 2020 as soon as they are released by CMS.
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