CMS, MACRA-MIPS, and Drawing the Short Straw
Now, I’m not a mathematician, but I can count to ten. So, I wasn’t expecting any problems when I decided to look at the recently released MIPS Final Scores for the 2017 reporting period.
It is a bit hard to find the Final Scores as they are not viewable on the Profile Pages at the Physician Compare website hosted at Medicare.gov. Those numbers, while available, require a journey into the depths of large data bases. Sure, would be nice if they were easier for John Q. Public to find. The 2017 MIPS final scores (affecting 2019 Medicare reimbursement) are in two different data bases depending on whether the reporting was done via the Individual or Group method.
Not too long-ago CMS released a report entitled the “2017 Quality Payment Program Reporting Experience”. Stated in that report is: “….out of the 1,057,824 clinicians eligible for MIPS for the first performance year, 93 percent received a positive payment adjustment or better, whereas other two percent earned a neutral payment adjustment. Only five percent of MIPS eligible clinicians (EC) received a negative payment adjustment for their 2017 performance….”. At first glance that looks pretty good but is it? Well, it depends, and here is where the math falls apart.
While there is truth to the CMS claim that 95% of 1,057,824 ECs achieved a 2017 MIPS final score of 3 or higher, this is also true:
- The 2017 Group Reporting MIPS data base listed 22,599 groups of which 8,005 (35.4%) scored zero.
- The 2017 Individual Reporting MIPS data base listed 413,233 individuals of which 31,591 (7.6%) scored zero.
For the 2017 MIPS reporting year all that was required to avoid a reimbursement penalty was to score 3 out of 100 possible points. This only required perhaps 5 minutes of work during the entire year. All you had to do was to report one quality measure on one patient, no EHR required, and you avoided a penalty. CMS tells us that only 5% of MIPS eligible clinicians failed to meet that minimum score of 3. But that is not the whole story. Based on a deeper review of the data it is obvious that there are winners and losers. It is easy to see who the losers are, those ECs who reported as a Group and probably had a relatively small number of providers in their group. I continue to be concerned about the ability of the MACRA – MIPS program to maintain a level playing field for individuals vs. small groups vs. large groups. Let’s hope additional education and support is being offered to those that have drawn the short straw.