It is crucial for organizations and clinicians to ensure coding and clinical documentation is accurate to meet the program’s data completeness requirements and maximize MIPS incentives. If an organization fails to submit the necessary data, it will receive zero points on a MIPS measure. Ensuring that coding and clinical documentation advancements are accurate is crucial to improving MIPS performance scores. Additionally, ensuring clinicians are prepared for MIPS is essential to avoiding penalties and maximizing performance. Provider organizations can assist their clinicians in avoiding penalties by educating them on MACRA implementation processes and providing access to MIPS support. Organizations and providers who use MIPS successfully protect their financial future by increasing incentives and avoiding penalties. They gain staff buy-in by aligning MIPS goals to what motivates their staff.
Another advantage is empowering a quality champion to provide insight and take the reins on achieving MIPS goals. Finding and using MIPS resources to their advantage and optimizing their EHR system to support quality measurement is beneficial. The financial and reputational impacts of the MIPS score are affixed to a clinician, even if the clinician moves to another organization or practice. For example, if a clinician earns a MIPS score for 2020 and works for another organization in 2021, the new organization will inherit the MIPS payment adjustment applied in 2023 based on the 2020 score earned by the clinician at the previous organization (Berdahl et al., 2019). Additionally, every MIPS score earned by a clinician is a permanent part of the public record released and maintained by CMS, making MIPS scores an increasingly significant portion of a clinician’s resume (Berdahl et al., 2019).
Impact of Failing to Meet Measures of Merit-Based Incentives
The MIPS program determines quality measures and reporting requirements for eligible clinicians and hospitals. Several conditions vary depending on payment implications. One condition is whether a clinician is participating in MIPS, a MIPS alternative payment model (APM), or an advanced APM. The most significant impact an organization will encounter is the possible penalty fees for not meeting quality benchmarks. Another significant impact is for organizations that do not participate in MIPS. Organizations and clinicians eligible for MIPS will obtain a 7% payment increase within the Medicare fee schedule as well as a possible bonus payment for performance scores. The impact of not participating in MIPS is receiving only a half-percent rate increase to their Medicare fee schedule with a potential quarter-percent increase within a few years (Berdahl et al., 2019). Organizations that do not participate in MIPS will also miss a 3-10 percent bonus as a top-performing hospital. These additional reimbursements can be utilized for improvements to patient care and guaranteeing the hospital continually sustains itself as a high-quality care organization. Participation in MIPS offers incentives and allows clinicians to assess their practice and ways to constantly improve. Clinicians who decline to participate in MIPS face the challenges of a fee-for-service reimbursement payment system and the opportunity to improve their practice and provide higher quality care for patients (Berdahl et al., 2019).
There are various methods for management and leadership that could assist departments and end-users in meeting and remaining compliant with Merit-Based Incentive Program requirements. It is imperative that Vila Health improve their performance scores in the MIPS categories to qualify for full payment. It is vital that eligible clinicians and healthcare managers are educated on the measure requirements for MIPS. This knowledge will allow clinicians to leverage the MIPS reporting flexibilities and maximize their composite performance scores. This will result in avoiding the negative nine percent penalty by selecting MIPS measures that the organization performs well on already.
It is important that Vila Health partners with EHR and Health IT Vendors for support to integrate MIPS reporting requirements into clinician workflows. This will allow for scores to be regularly viewed and enhancements made when needed. Implementing clinical documentation support in the EHR will also allow for data completeness, ensuring the coding and clinical documentation is precise according to MIPS guidelines. Finally, it is crucial that organizations identify a physician as a champion to facilitate MIPS education and performance improvements. Utilizing physicians to educate their peers on the importance of clinician workflows that combine MIPS requirements without compromising patient care and other clinical responsibilities would alleviate MACRA implementation challenges (Rutherford, 2017).
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