A strong start for the first year of physician participation in Medicare’s Merit-based Incentive Payment System (MIPS) was no surprise to Gregory N. Nicola, MD, FACR, a leader of American College of Radiology (ACR) efforts to help members use MIPS and other elements of the federal Quality Payment Program (QPP) to measure and improve their clinical performance.
In terms of physician participation, MIPS had a very good first year, according to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma. In a May 31 memo, she announced that 91 percent of all clinicians eligible for MIPS participated in QPP. She also reported a 98 percent submission rate for Medicare Accountable Care Organizations and a 94 percent submission rate for clinicians in rural practices.
In an interview five days later, Nicola, vice-chair of the ACR Commission on Economics, said the secret to that success lay in QPP’s simplicity in its first year. He and his colleagues are focused on 2018 and the years beyond, when the rules for MIPS are tightened and bonuses from the hybrid fee-for-service/value-based reimbursement program will get harder to earn.
The rules are already tougher in 2018 than in 2017, Nicola pointed out. Last year, a clinician had to only report one quality measure for a single patient to avoid a negative assessment. This year, a data completeness threshold of 60% applies, meaning that physicians have to report on 60% of all their patients in order to receive more than one point for each quality measure. Nicola believes reporting success rates could plummet, and the number of physicians receiving negative adjustments (to their Medicare payment rates) could rise based on their performance in 2018.
But there is also good news from the 2018 Bipartisan Budget Act, which allows Medicare to keep the QPP fairly simple for its first years. Without Congressional action, supported by the ACR, Medicare was required to have MIPS fully implemented with all statutory requirements met by 2019. The law has been modified to permit a continued gradual phase-in. Minimal changes are expected in each of the next four years, with full implementation of the MIPS delayed until 2022.
The ACR has developed extensive MACRA Resources and various clinical tools to help members cope with MIPS. In the webinar “MACRA-CMS Quality Payment Program Year 2,” for example, Lauren Golding, MD, and Richard Heller, MD, lay out a road map showing how MIPS performance categories, scoring systems and other requirements changed this year. The ACR MACRA Committee will begin planning an updated version of the webinar as soon as CMS releases the QPP Year 3 rule at the end of June.
The ACR’s National Radiology Data Registry (NRDR®), R-SCAN and Clinical Decision Support (CDS) are potentially game changers for radiologists participating in MIPS.
NRDR has been approved as a Qualified Clinical Data Registry (QCDR) for 2018 MIPS Reporting. The QCDR will include 58 MIPS measures and 22 QCDR measures and will also be able to report improvement activities and the advancing care information performance category. These measures are often associated with high-priority National Quality Strategy domains leading to MIPS bonus points.
R-SCAN gives radiologists opportunities to acquire MIPS improvement activities credits. By demonstrating the use of CDS, ordering providers earn credit for a high-weight improvement activity. While using CDS doesn’t count directly as an improvement activity for radiologists, those participating in R-SCAN meet criteria to receive full credit in this category.
And by reducing inappropriate imaging orders, CDS potential help reduce health care costs.
“NRDR, R-SCAN and CDS all complement different aspects of MIPS and alternative payment models,” Nicola said. “They empower radiologists to optimize their performance scores and make it fairly seamless once you’ve implemented the paradigms to actually participate in those specific programs. They show you’re adding value to your system.”
In addition, the ACR has a robust team in place to help develop new quality measures for MIPS. The ACR’s own technical experts panel is not just composed of radiologists, Nicola noted. It also includes primary care physicians, a urologist and other physician specialists who can confirm that radiology-specific quality measures have value for all concerned.
Successful participation in MIPS or an advanced alternative payment model will ultimately depend on the individual radiologist’s attitude toward it, according to Nicola. The radiologist will fail by not taking personal responsibility for quality optimization in the QPP or dismissing the program as something designed for primary care physicians and not themselves.
He advised radiologists to use QPP to look for things they can do better, especially ways to improve the cost curve for patients. It is then important identify ways to measure progress toward such goals, implement them and then re-measure them to confirm that they improve practices or procedures.
“The QPP’s goal is to use data to drive change,” Nicola stressed. “We have to be doing that no matter what part of the QPP we’re in. And, we have to do it for all our patients, not just Medicare patients, because it is a way to the future, and it’s the right thing to do.”