With the first transition year for MIPS coming to a close, eligible clinicians must strategize payment implications for upcoming years. Similar to the Physicians Quality Reporting System (PQRS) and Value-Based Modifier (VBPM) but unlike Meaningful Use (MU), MIPS scores each clinician in comparison to others, but also adds benchmarks based on past data, placing clinicians on a curve, and then adjusts payments based on their performance in the distribution.
Special Scoring for ACOs
When comparing anticipated MIPS payment adjustments of ACO participants versus non-ACO participants, Medicare Shared Savings Program (MSSP) participation is expected to enhance MIPS performance, due to the special scoring available to members of those program, which will improve the likelihood of receiving “exceptional performance” bonuses.
Exceptional performance bonuses are only available in the first five years of MIPS. Contingent upon the number of exceptional performers, it is possible to receive up to 10% in addition to the maximum positive payment adjustment, which is up to three times the penalty for the first five years of the program. Taking into account the’s scaling factor and the exceptional performance bonus, a top-performing practice could theoretically earn up to a 25% payment adjustment in the 2018 performance year.
MIPS Cost Component
Beginning in 2018, MACRA requires that 10% of the MIPS score be based on Resource Utilization (Cost) and increasing to 30% in future years. Track 1 ACO participants, however, are held accountable for cost in their ACO and not in MIPS; therefore, Track 1 ACO participants can more easily achieve high scores compared to other MIPS participants, increasing the likelihood of avoiding MIPS penalties and earning the exceptional performance bonus.
Since CMS is waiving scoring on the MIPS cost/resource use category for MSSP and Next Generation ACO participants, it has re-weighted the other performance categories to compensate.
To accurately predict MIPS bonuses, eligible clinicians must know both their performance score and estimate the score of the rest of the providers in the MIPS pool. Because up to 40% of eligible clinicians in the pool are expected to be participants in Track 1 MSSP ACOs, those ACOs will receive the special ‘re-weighted’ MIPS scoring, potentially causing most other MIPS-eligible clinicians to receive lower adjustments in comparison.
Should You Consider an ACO?
As a result of the special scoring and MIPS cost waiver, the majority of providers stand to benefit by joining an ACO. Smaller practices could avoid penalties from the anticipated lower scores due to lower budgets. Providers in rural areas could avoid MIPS penalties due to their frequently higher operational and patient treatment. Community hospitals can earn high bonuses and support their community physicians, particularly specialists, by enrolling them in an ACO, protecting their revenue and reducing their administrative burden.
If you are considering an ACO and want to better understand the process and how to maximize your incentive payments, we are here to help. Contact us here or by emailing [email protected].
