With so many outcome and reporting expectations from Medicare and other payers, choosing to report (never mind when, and how) can become just another exercise in provider based procrastination. The Medicare Quality Payment Program (QPP) is a different beast. This is why we are talking about 90 Day Reporting!
While CMS (Medicare) is throwing a bone this year by allowing penalty avoidance for submitting literally one measure for just one patient (e.g., “one and done” with Patient360’sM4B Program), those choosing the 90 day or longer category can see a real financial upside!
If you report six (6) measures (i.e., MIPS or QCDR or a combination of the two), you are eligible to exceed the 4% bonus. Moreover, those who report more data for a longer period of time get the most bonus money of the group and are first in line to be paid. If bonus money is your goal, year-long reporting is the best way to make this happen. However, for many, a year of reporting is impractical or thought to be too time consuming. If that is you and you still want access to bonus money, doing at least 90-day reporting is achievable. Here’s how it works:
- Select 6 measures.
- Pick a start date (before Oct 2nd or you run out of 90 calendar days).
- Begin looking at all patients relative to those measures and collect data to report to your registry.
It’s that simple. Honest! After 90 days, you can stop reporting, or if you think “it ain’t that bad…” you can keep going. If 90 days is all you can stand, be done. For some of the measures (e.g., the first three) you may well have pretty robust data. For others (say four through six), reporting may be weak. However, having some data in your 90-day period means you participated and bonus dollars are in reach.
Since you can’t predict when patients will come in with what diagnosis, you can simply choose to report as of August 1 and see what happens. It could be August 10th before anyone has the CPT and ICD criterion for selected measures. So be it. As long as you have measures chosen, you have opportunity to participate in the bonus pool. Do your best to report on all six (6) measures and see what you have after 90 days. You must have at least one patient for each of the six (6) measures you choose and we recommend having at least 20 patient encounters per measure to optimize measure performance and be a part of the national benchmark. As long as you have reported on greater than 50% of your patients for each measure during the 90-day period, that is all you must report. Nothing more, nothing less.
‘But what if my eligible patients are really low and I’m audited!’ Great question! IF you are audited —and it can happen, but doesn’t happen often— all CMS would do is verify that your ICD/CPT combination for that 90-day period included at least 50% of the patients that you reported on. If there were patients you should have reported that you didn’t… that’s a potential problem. You are supposed to report on all patients, which the regulations oddly define as > 50% of your patients. As long as you have done that, you have worked within the confines of the statutes and you should be fine. More importantly, it allows you to be eligible for a larger bonus. AND, if measure capture was not too unwieldy, collect for a longer period as it could mean more money!
‘The spirit of the program’—as the feds like to say—is that by doing the measures, clinical behavior and outcomes should improve, which should save money. Will that happen? It is yet to be determined. In the interim, optimize patient outcomes and your financial position by participating. Even if you only get 4%, that means more money than you were going to get by not participating. There’s a good chance you may get more. It’s a win-win.
Stop procrastinating! Pick your measures and jump into the reporting now, rather than retroactively in January 2018 like far too many of our colleagues. Be ahead of the curve to make the most of the opportunity.