Admittedly, the Merit-based Incentive Payment System (MIPS) is confusing, and when it comes to data submission too many seem to take the path of least resistance. Submitting data through an electronic medical/health record (i.e., EMR/EHR… hereafter EMR) while seemingly “easy” has potential pitfalls. Here are few quick thoughts to ponder in this regard;
Limited MIPS quality measures available: EMR vendors are limited to about 64 or so measures while a CMS-approved Registry affords access to nearly 250. Sure, just submitting via your EMR seems easier but if you don’t even know all the possible measures, how do you know if you are maximizing your score and potential reimbursement and gathering the best data based on your specialty? With negative Medicare payment adjustments moving closer and closer to the 9% maximum, mastering this program now is essential to assure optimal reimbursement.
Measure Optimization: Don’t get me wrong
Some do… but most don't. Top tier CMS-approved Registries are able to assess not only which measures are best for your practice based on your specialty, but which providers (via group reporting) contribute to the best performing data for the group, and even which patient encounters put your practice’s “best foot forward.”
All Eggs, One Basket
The basket falls and all the eggs are cracked and scrambled. If your total MIPS success is tied to your EMR’s promises, and they don’t come through, all the eggs go bust. In recent weeks, several nationally prominent EMR vendors seem suddenly unable to report MIPS data for their clients. And, this inability happening after clients sought no other MIPS reporting mechanism because they thought it was “all set.” Inability to adequately or completely convey QRDA3 files or meet CMS submission deadlines means practices and their providers find themselves in the unenviable and financially disadvantaged position of not reporting at all. This is entirely avoidable. Working with a Registry like Patient360 allows practices to “know” their submission is secure, rather than to “hope” it is.
NOT a “core” Business Function or Focus
Let’s face it, EMR companies were created to provide electronic medical records to optimize patient data capture, ease the administrative (paper) burden on providers, and hopefully more seamlessly share patient information with other providers. Nowhere in that “core” focus/function is there an intrinsic focus on quality payment programs and optimal reporting for MIPS to CMS. For CMS-approved registries, this is all we do. We interface with EMR companies to gather data but in the end, helping clients maximize performance and improve quality outcomes under MIPS is our primary business function and focus.
In the end, each provider and/or practice must make whatever decision seems best. It's certainly important enough to invest time making certain your provider(s)/practice is maximizing Quality Payment Program performance. Perhaps you will find your EMR totally meets your needs. However, don't be surprised if a CMS-approved registry ends up being a better bet and a more optimal partner to help improve patient outcomes and maximize financial performance.