Radiologists often identify incidental findings. When clinically significant, communicating these findings for further evaluation and treatment can be a lifesaving action. Despite best efforts, documentation in radiology reports does not adhere to a fixed standard, making subsequent analysis of incidental findings quite difficult. And, while such a finding might be insignificant in the present exam, over time a patient’s status may change and incidental findings may be a key indicator of appropriate follow-up care.
Converting the US healthcare economy to a value-based model that rewards both quality and cost savings is an objective that still holds bipartisan support, despite the well-known burdens of compliance that many providers have experienced. While some significant voices are currently advocating repeal and replacement of MIPS, others are for "charging forward".
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?
During 2016 we worked hard to provide our readers with information and advice that would allow them to maximize their performance under the Physician Quality Reporting System (PQRS) and therefore to maximize their reimbursement in 2018 under the associated Medicare Value-based Payment Modifier (VM). The results have just been announced by the Centers for Medicare and Medicaid Services (CMS), and are available in a CMS Fact Sheet.
Beginning in 2019 the level of reimbursement from Medicare to many physicians will be determined in part by their performance in the Merit-based Incentive Payment System (MIPS). Medicare will award a higher level of payment to those eligible clinicians and groups who report that they have successfully met certain criteria for Quality, Advancing Care Information, and clinical practice Improvement Activities. MIPS is the successor program to the Physician Quality Reporting System (PQRS) and Meaningful Use of Electronic Health Records (MU-EHR) incentive programs, and CMS (the Centers for Medicare and Medicaid Services) has indicated that it will continue its practice of auditing the data submitted by practices just as they did under the earlier programs. As this article in Healthcare IT News illustrates, the result of failing an audit will be non-payment of expected incentives (in the case of a pre-payment audit) or returning of funds already paid and possibly even federal sanctions depending on the severity of the infraction.
This is the third in our series of articles designed to help radiology practices prepare for the Merit-Based Incentive Payment System (MIPS). Previous articles covered the Quality Performance Category, which is the largest portion of the MIPS score, and the Advancing Care Information (ACI) Category. Quality will initially account for at least 60% of the total MIPS score and ACI will account for up to 25% of the total score. The Improvement Activities (IA) Category, originally called the Clinical Practice Improvement Activities in proposed regulations, represents 15% of the total score for 2017, the first year of MIPS participation. The fourth element of MIPS, the Cost Category, has been reweighted to zero for 2017.
By now everyone involved in billing Medicare for physician services should be aware of the new Quality Payment Program (QPP) that will be in effect for payments in 2019 based on data submitted in 2017. The proposed rules for the new system were outlined in our recent article Medicare Quality Reporting Rules are Changing. The final regulations that will govern the new system were recently issued, and radiology practices will benefit from preparing as early as possible to capture the data they will need to report under the new system.
The Merit-Based Incentive Payment System (MIPS) is slowly being analyzed and absorbed by the medical community. This system, passed into law by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), will begin to take effect for physician reimbursement in 2019 but those payment adjustments will be determined by performance in various categories for services rendered in 2017. Regulations governing the application of this law have now been finalized and savvy radiology practices can begin to prepare to comply with the new system.
Earlier this year CMS published its proposed regulations that would implement the MACRA law to revamp the Medicare physician payment system. On October 14th, after consideration of over 4,000 comments about the proposed rules, CMS published the final rule that will govern the initial measurement period that begins January 1, 2017 for payment adjustments in 2019.
Under regulations proposed earlier this year, physicians will face up to a 4% fee schedule reduction in 2019 for failure to meet the reporting requirements of the new Quality Payment Program in 2017. Now the Centers for Medicare and Medicaid Services (CMS) has announced that it is going to revise those proposed regulations to make it easier to avoid the negative adjustment and perhaps even earn a slight positive adjustment in 2019. The final rules will be published around November 1, 2016 and will take effect on January 1, 2017.