In November, CMS issued its final ruling on the Medicare Access and Chip Reauthorization Act (MACRA). This ruling was the largest change in Medicare in over a decade – pushing completely away from volume based care towards a new era of value-based care. MACRA created MIPS, the Merit-Based Incentive Payment System, rolling previous programs like PQRS, Value-Based Payment Modifier (VBM) and Meaningful Use, into one single program.
This new law and corresponding implementation will have a particularly harsh impact on Critical Access Hospitals (CAHs); exempt from previous programs and generally operating with limited resources, CAHs are at a distinct disadvantage when attempting to comply with MIPS. To not only ensure complete compliance with MIPS, but also to put themselves in the best position to earn incentives under the program, CAHs must now focus on optimizing their MIPS Composite Performance Score (CPS). Here are a few steps that CAHs can take to begin that process of knowing how best to manage the complexity of MIPS.
Step 1: Determine Eligibility
Under MIPS, all Medicare Part B providers must comply with rare exception. Providers within any organization that meet volume thresholds — $30,000 in annual Medicare billings and 100 unique Medicare patients – will have to comply.
Step 2: Learn the Program
In order to comply with MIPS, it will be important for a CAH to educate itself and its providers on the critical elements of the program. For example, developing an understanding for the Quality Measures that providers will be evaluated on will give the organization insight into how to update workflows, improve care coordination, and assess provider performance to ultimately put the organization in the best position to optimize scores in Quality Category – 60% of the MIPS score.
Step 3: Pick a Path
Many CAHs might be thinking about joining an ACO for the chance at being a part of an APM. However, this may or may not be the best option for you. It is crucial to understand that whichever path your organization chooses (APM or standard MIPS) all providers will be required to comply under MIPS in 2017. This means, regardless of the path you choose, you must work to optimize your MIPS score.
Step 4: Formulate a Plan
Once an organization has determined who within the organization is eligible, educated themselves, and chosen a path, it will be crucial to formulate a plan on how to comply. The most critical step in complying effectively will be leveraging technology to use data analytics in order to increase patient engagement and improve overall quality of care. With an increased emphasis on benchmarking, success with data will be critical to success with MIPS.
Step 5: Pick a Partner
CAHs do not have to act alone. As stated previously, CAHs have the added disadvantage of not having complied with previous programs such as PQRS and VBM. A Certified EHR Technology (different from a certified EHR), like Health eFilings software, can integrate directly with an organization’s EHR to automatically extract data without any resources needed from the organization. This means significantly less of an administrative burden on resource strapped CAHs. Not only does this help with compliance, but it does so without adding additional work. Health eFilings software will fully automate the compliance requirements and provide ongoing access to data analytics enabling an organization to increase its MIPS score and maximize its Medicare reimbursement. Additionally, automatic bonuses in multiple categories are applied to the total MIPS score, just for using Health eFilings services.
There are 1337 CAHs across the country. While some will not meet volume thresholds to have to comply, for those who do they will have an enormous amount of work to do in order to do so successfully. Don’t try to do it alone. Health eFilings can help.