An Introduction to MIPS Basics

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Any views and opinions expressed are those of the author(s) and/or participants and do not necessarily reflect the views, policy, or position of Today’s Wound Clinic or HMP Global, their employees, and affiliates.

Transcript

Hi, I'm Dr. Caroline Fife. I'm the Chief Medical Officer of IntelliCure, LLC, and also a professor of geriatrics at Baylor College of Medicine in Houston. And I've been a wound care practitioner for more than 30 years now.
 
What is the Merit-based Incentive Payment System (MIPS)?
 
Yeah, so, MIPS is one of those things that you either love it, hate it, you care or you don't care, although I have actually wondered if we ought to come up with some other names for it, like “Millions of Instructions, Purse News,” “Medicare Ideas, Poor Solutions.” These are all abbreviations that have been suggested. “Many Interruptions, Please Stop.”
 
But it's the Merit-based Incentive Payment System. And it's part of Medicare's quality payment program. Medicare loves to come up with abbreviations. So the big picture is the quality payment program. MIPS is one part of that. There may be physicians who are participating in accountable care organizations. They are participating in the quality payment program through a little different pathway. MIPS is the pathway for most, especially private practice doctors.
 
How has the Medicare MIPS evolved since its inception?
 
Well, it depends how far you want to go back. Some people might remember something in 2009 called PQRS. What we had for a while, and this just tells you how long Medicare has been working on reforming payment. But as long ago as 2009, Medicare began to try to get doctors used to the idea of submitting data even if it was by claims.
 
What happened with MIPS is a bunch of different programs all got wrapped into one. For a while there, after when the Obama administration started, that's when we got that high-tech act trying to get doctors and hospitals to adopt electronic health records. For a while, there was a program about using your electronic health records. And then there was a quality program. And then there was another piece about other types of practice incentives. It all got wrapped up into one thing with MIPS in about 2018, 2019, depending on how you count the way that it began from the statute versus how it rolled out for physicians.
 
So it's a relatively new project. And for a while things were suspended because of COVID. And the reason that people are paying attention now is that all those COVID suspensions have gone away. And the plan from Medicare, the idea was to link payment to quality. I think we could argue that MIPS hasn't really done that, but that was the idea. Maybe we'll talk some more about what the idea was. and the idea is that we didn't want to pay for things just because physicians wanted to do them. We wanted to reward physicians who are providing high quality and highly effective care and so it's been rolling out in stages with a little pause during COVID.
 
What happens when a physician participates in MIPS?
 
There's a website where you put in your NPI, your identifier, and you find out if you're eligible. “Eligible” is Medicare's word for “you have to do it.” Eligibility is not just MDs, it's podiatrists, it can even be physical therapists, nurse practitioners, and even nutritionists. Eligibility determined by your either the total number of Medicare patients you see each year or the claims, the amount of the claims you put in.
 
So if you're eligible what happens is you get scored, every physician gets a score from zero to a hundred. I like going back to school. And that score is determined by four separate components. One of them is cost. We might have some time to talk about costs, but it's totally determined by Medicare. Clinicians don't have any way to influence that. The other segment is quality, which is usually determined by quality measures. Lots to talk about, good and bad about quality measures. Another component is promoting interoperability, which some clinicians may remember as the Meaningful Use program promoting interoperability has to do with how you use your EHR and then there's practice improvement activities. So those are the four components, three of which clinicians actually participate in the acquisition and submission of data to Medicare.
 
And I should also add that though each of those four things doesn't have the same weight as you get to that 100% score. This year quality is worth 30% but there's fine print around that. Cost is worth 30%. That's the one Medicare calculates on your behalf and there's a good side and a bad side to that. Promoting interoperability is 25% is 25% and improvement activities 15% in 2024, but if you're a hospital-based physician, you're exempted from promoting interoperability and those points get usually thrown into the quality piece. So it's not, even if you know what the rules are, there's a lot of fine print about how, what percentage each one of those categories contributes to your final score.
 
You couldn't design a system more complicated than MIPS. It makes going to medical school look simple. There's no question that it's got to be the most complicated thing that's ever rolled out of Health and Human Services.