The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website. The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results. According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold.
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.
Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along. One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams. This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021. This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.
The year 2019 marks the third reporting period under the Medicare Incentive-based Payment System (MIPS). Radiology groups’ performance this year will determine their positive or negative Medicare fee schedule adjustment for payments in 2021, just as this year’s Medicare payment adjustment was determined by performance in 2017.
With the publication of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2019, which includes the Quality Payment Program (QPP) Final Rule, we can now review how radiologists can prepare to maximize their 2021 Medicare reimbursement through QPP participation in 2019. The QPP includes both the Medicare Incentive-based Payment System (MIPS) and Alternative Payment Model (APM) tracks. Since most radiology groups are currently participating in MIPS, we will focus on steps to take for successful participation in this program.
With the 2017 MIPS reporting year behind us, we now know that practices that achieved the highest possible Final Score of 100 points will receive 2.02% more Medicare reimbursement than the basic fee schedule for 2019. This increase is compared with the possibility of a 4% payment reduction for practices that did nothing, and a zero-percent adjustment for practices that did the minimum amount of reporting. In between the minimum level and a perfect score, the fee schedule positive adjustment varies on a sliding scale computed by Medicare.
In our recent article we explored the ways radiology groups can begin to move toward participation in Alternative Payment Models (APM*) as an option in place of working within MIPS under the Medicare QPP. But what does APM participation mean for a radiology practice, and what should radiologists look for to begin moving in this direction?
When Congress finalized the fiscal 2017 federal budget on February 9, 2018, the bill1 contained some changes that will affect the Medicare Quality Payment Program (QPP) in the coming years. Nothing in the bill changes Medicare payment levels or the MIPS2 reporting requirements for 2018. There is, however, a change that affects the 2018 performance year low-volume exclusion.
Here is a summary of the changes:
The Centers for Medicare and Medicaid Services (CMS) threw a surprise into the Quality Payment Program (QPP) Final Rule for 2018 when it included the Cost Category as 10% of the MIPS Final Score for 2018 reporting. The QPP Proposed Rule issued a few months earlier stated that Cost would be zero-weighted for 2018 as it had been in 2017. So what does this mean for radiology?
The first performance measurement year of the Medicare Incentive-based Payment System (MIPS) was 2017, the results of which will be used to determine Medicare payment adjustments in 2019. This was considered a “transition year” that allowed practices to “pick your pace,” ranging from a streamlined path that would simply avoid penalties in 2019 to full participation that could generate positive payment adjustments in 2019. The bar has been raised for 2018 performance measurement, and it will continue to be raised again in 2019 as the program reaches full implementation as required by law. This article summarizes the changes for 2018 that will affect the performance of radiology practices as they work to maximize their reimbursement in 2020.