Merit-based Incentive Payment System (MIPS) is part of the Quality Payment program, which implements provisions of the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA). Let’s take a look at MIPS considerations for a Radiology practice.
For radiologists, participating in the first performance year evolves three options – test, partial, and full.
MIPS will begin to take effect for Medicare physician reimbursement in 2019 but those payment adjustments will be determined by performance reported for 2017, which is being termed a ‘transitional year’ for the program. The reporting period for 2017 has been lowered to a minimum of 90 days rather than a full year for all of the MIPS categories. It is expected that MIPS will be in full effect for 2018. The Medicare payment adjustment in 2019 will be based on submitting data and the radiologist’s performance for the following MIPS categories in 2017:
- Quality performance (60%)
- Cost (0% for the first year)
- Advancing Care information (25%)
- Improvement activities (15%)
The key idea here is the assessment of the value of care given to patients. The following areas need to focused on: clinical care, patient safety, care coordination, patient and caregiver experience, prevention and population health, and affordable care. The idea behind this is to promote and ensure high clinical proficiency, professional diligence, and thoroughness.
Radiologists have focused for decades to create ways to lower radiation dose and using techniques, such as “Image Wisely” and using calculation methods to administer the lowest possible diagnostic quality dose for adult CT scans is critical. Similarly, they must report the radiation dose/time for fluoroscopic procedures. The radiologist should report to Radiation Dose Index Registry all necessary events.
Accurate and unambiguous reporting is emphasized minimizing hedging terms and vague descriptions are encouraged in order to make reports clear, succinct and actionable. The reports should include patient reminders for follow up imaging-related visits. The reports also need to include all key information, such as stenosis measurement in carotid imaging reports. The radiologist should also follow up with referring doctors about biopsy results and imaging findings.
Improvement Activities Performance:
The focus here is on Support care coordination, patient engagement, patient safety, population management, and health equity. Important points include:
- Radiology practices with fewer than 15 ECs and those who are considered non-patient facing only need to report 1 high-weighted or 2 medium-weighted IAs to receive the full credit of 40 points.
- Only about a dozen or so improvement activities are currently applicable to radiology, and few are high-weighted.
- Most applicable IAs will be found in the Beneficiary Engagement, Care Coordination, and Patient Safety and Practice Assessment categories.
- Group reporting provides an advantage since a single individual’s participation gives credit to the entire group.
Advancing Care Information:
Support the secure exchange of health information and the use of certified electronic health record technology (CEHRT)
There is an Advancing Care Information performance category score, which includes:
- base score,
- performance score
- bonus score.
There are two measure set options for reporting:
- Advancing Care Information Objectives and Measures
- 2017 Advancing Care Information Transition Objectives and Measures
MIPS eligible clinicians need to fulfill the requirements of all the base score measures in order to receive an Advancing Care Information performance category score. If these requirements are not met, they will get a 0 in the overall Advancing Care Information performance category score.
A Radiology department/practice should first, estimate its current MIPS score. Then, it should help educate the organization, particularly upper-level executives advising them on what needs to be reported on, where they should focus effort, and why. And then, they should look at maximizing their quality score.