The Verdict is in: QPP MIPS Bonus Underwhelms, well, nearly everyone! So, you scored 100 points for your QPP MIPS final score and only received a positive 2.1% payment adjustment, eh? Where is that exceptional bonus anyway? Did anyone get a positive 4% payment adjustment? It seems not.
We at Patient360 hate to burst everyone’s bubble, but when budget neutrality is involved, AND the feds ease the way for almost anyone submitting even the least bit of QPP MIPS data to avoid negative adjustment… there’s just not enough “found” money to go around. For 2017, it seems a positive 2% payment adjustment is pretty decent especially compared to how the legacy programs operated over the last decade. Before further addressing budget neutrality, let’s do a quick recap on w hat 2017 QPP MIPS payment adjustments were meant to look like and what various practices would stand to lose and/or gain.
So, it’s pretty obvious that non-participation of eligible providers in 2017 would have resulted in a meaningful loss, even for small practices. If you look at the dollars at risk for Practice 1 (a solo doc) even just $7,200 can cover unavoidable expenses; e.g., disposable supplies, small technology items, paper, etc. For a group of only 5-10 eligible providers, the money at risk is tens of thousands of dollars. In today’s physician practice, every penny counts! Based on the philosophy of “at least avoid loss” coupled with CMS making it SO easy for “newbies” to participate via Test Pace, there were very few practices that saw a NEGATIVE 4% payment adjustment. This means there was very limited “found” money derived from keeping up to 4% of Medicare payments from providers who did not participate or did not perform well enough to avoid a negative adjustment. Medicare was to redistribute money recovered from those losing 4% AND those dollars were to be redistributed to those performing at elevated levels. In short, it was so easy to participate and avoid penalty, almost everyone did both.
And here is the rub as it pertains to the MIPS program and budget neutrality. Because CMS made it so easy for EVERYONE to successfully participate in a program where bonus was the aggregate of recovered 4% AND $500 million, there was just too much success and too little money to share. If only the $500 million were shared with 500,000 successfully reporting providers, each would receive $1,000. If a million providers, only $500 each. Until the anty is upped and underperforming providers see their money redistributed to those with elevated performance, low single digit returns will be considered solid performance.
Is it all doom and gloom and no future upside? Not so fast! If we look at the chart above, just by participating everyone avoided the negative 4% payment adjustment. This is a much higher payment adjustment compared to the legacy PQRS program. Remember we are closing in on the program maximum of 9% that will more than double the dollars at risk in the table above. Avoiding a nearly 10% loss from a growing Medicare population in and of itself is desirable. We all want to maximize potential dollars which, this year, would have meant receiving the exceptional positive 4%. However, if you are reading this and are one of the lucky recipients of that whopping 2.5% bonus, know that you are in good company. No one else with whom Patient360 has spoken (i.e., other registries, QCDRs, and from chat room surveys) seems to have received positive 4%. The more the program evolves and imposes stricter minimum thresholds, the more the high achievers will achieve more, and the lower achievers will crash and burn. In other words, the broadness of the divide between successful and unsuccessful will dramatically expand. Therefore, as we move forward, it’s in your best interest to try and do far more than the minimum to “get by” under QPP MIPS.
If you haven’t seen your MIPS 2017 Feedback report yet, you can find it by logging into your EIDM account. Feel free to send it along to Patient360 if you need some consultation with regard to the results and what to consider as you approach your submissions for 2018 and beyond. These reports will become increasingly important as the Cost category gains momentum and additional weight each year.
Partnering with a seasoned registry with a proven track record, like Patient360, is your best bet to elevate performance and continue your winning ways. We hope to have your join P360 to optimize your QPP MIPS performance!