Public Health Emergency Expiration and the Merit-Based Incentive Payment System (MIPS)

Episode 11 March 16, 2023 00:19:12
Public Health Emergency Expiration and the Merit-Based Incentive Payment System (MIPS)
Kassouf Podcast Network
Public Health Emergency Expiration and the Merit-Based Incentive Payment System (MIPS)

Mar 16 2023 | 00:19:12

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Hosted By

Tara Arrington

Show Notes

Today’s episode is an excerpt from our recent webinar. As you probably know, the world changed a lot in 2020, especially the healthcare industry. A Public Health Emergency was declared which allowed certain exceptions to help the healthcare industry move forward during this challenging period. Based on current COVID-19 trends, the Department of Health and Human Services (HHS) is planning for the federal Public Health Emergency (PHE) to expire May 11, 2023.

With the expiration comes changes to many of the exceptions that were put in place during the PHE. One of these affected areas is the Merit-Based Incentive Payment System or MIPS. In this episode, Joni Wyatt, a director in Kassouf’s Healthcare Group, will discuss these important changes. Joni over 20 years of experience in the healthcare industry, specializing in physician practice management and new practice startups,  physician contracting and compensation models, health information systems, healthcare compliance, and quality measures and reporting.  She is well-versed in new reimbursement models and the legislation driving these initiatives. 

Resources: 

MIPS Portal

Participation Options Overview

 

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Episode Transcript

Speaker 1 00:00:08 This is the kaso Podcast network where your trusted advisors are at your fingertips, are in your earbuds. At Kassouf, we are an accounting and advisory firm made up of a team of specialists in a variety of fields, from healthcare consulting to cyber security, to everything in between Here, you'll discover tips to make your business rent better. From interviews with our subject matter experts, I'm your host, Tara Arrington. As an ex journalist turn marketing professional, I'm the non-expert who will chat with our experts delving into the information you need to help your business succeed. Speaker 1 00:00:48 Today's episode is an expert from our recent webinar. As you probably know, the world changed a lot in 2020, especially the healthcare industry. A public health emergency was declared, which allowed certain exceptions to help the healthcare industry move forward during this challenging period. Based on current COVID 19 trends, the Department of Health and Human Services is planning for the federal public health emergency, or the p e to expire May 11th, 2023. With the expiration comes changes to many of the exceptions that were put in place during the p e. One of these affected areas is the merit-based Incentive payment system, also known as mips. MIPS is the default quality payment program for most providers and will experience changes when the p e expires today. Joni Wyatt, a director in Kause Healthcare Group, will discuss these important changes. Joni has over 20 years of experience in the healthcare industry, specializing in physician practice management and new practice startups, physician con contracting and compensation models, health information systems, healthcare compliance and quality measures and reporting. She is well versed in new reimbursement models and the legislation driving these initiatives. Take it away, Joni. Speaker 2 00:02:08 We're gonna talk a little bit about, uh, mips, uh, for, you know, kind of, it's not really a tutorial. Uh, so if you have not been in healthcare or you're new to healthcare, uh, or you are new to a reporting role that has to do with mips, um, this is not so much a tutorial as it is really a review of what we need to expect, uh, this year and then after the public health emergency. So the Merit Based Incentive Payment program, although it seems like it's been forever since we've actually talked about it, cuz a lot of people haven't been reporting. Um, traditional MIPS has been around since 2017 and it's actually expected to sunset in 2027. In the 2027 reporting year. Don't get too excited because it's not going away, it's just changing. Uh, all patient data with MIPS is included in the reporting. Speaker 2 00:03:01 Just as a reminder, but only your traditional Medicare is actually was impacted by your payment adjustments. And if you remember, there's a two year delay between the reporting period and actually the payment impacts. So, um, everything we report in 2023 won't actually impact you and your Medicare payments until 2025. We are currently at the maximum payment adjustments and so on the upside, uh, it could be up to 9%, although we don't see anything close to that. You know, typically around 2% is what you would see for your top incentives. Uh, from a negative standpoint, it can also be as low as a negative 9%. Negative nine, uh, is a, it's a sliding scale, so anything below the, excuse me, required threshold, it's sort of a linear, so it could be a negative two, it could be a negative three all the way to negative nine. Speaker 2 00:03:58 However, if your total composite score is less than 18.75, uh, it actually is a full negative nine or if you don't report at all and you're eligible also a full negative nine. That's been the case for the last couple years and is actually gonna continue, um, into the future through the sun setting of mips. Every year we have seen annual changes, uh, to the reporting criteria. So we see changes, uh, maybe to the category scores. We see changes to who's eligible and who's not. And we see some minor changes, but the basic program remained the same, um, this year as a reminder about eligibility. So, uh, you have to have a, a provider has to have $90,000 in Medicare charges. Um, eligible Medicare charges 200 part B patients as well as 200 part B eligible Part B services in order to be eligible. If you meet all three of those criteria, um, then you actually are eligible to report. Speaker 2 00:05:00 It's on a look back period. There's a determination period that goes back 12 and 24 months. Um, but there's a great place you can look on the portal. Uh, I'll give you the portal website in just a, a few minutes as we talk more about this. Um, but that's a good place to check to make sure you're eligible. And I do tell everybody, even if you don't think you are always check in 2023, we have had some updates, a little bit of foreshadowing as to what MIPS will look like going forward. So we've had the introduction of the MIPS value pathways. They're actually 13 of them, 13 MVPs, um, that are available. They're, um, similar to they're, they're specialty specific and they're similar to some of the original reporting we saw early on where you could pick a reporting group that really focused on a specific specialty. Again, we only have 13 this year. Um, but it, and it is not a mandatory way to report, but as I said in 2027, when traditional MIP sunsets, this will be the mandatory way to report in 2028 as it stands right now. So getting used to the MVPs and kind of understanding what they are between now and then may not be a bad idea even if you choose not to report that way. Speaker 2 00:06:21 So, like I said, most of us didn't report in 20 20, 20 21 and 2022. Um, it was a little bit of a reprieve but no one was even thinking about it unless it was an integral part of their practice or they were with an ACO or someone who actually reported for them. A lot of our smaller practice does not report and they actually took the public health emergency specific, uh, extreme and unusual circumstances exception. We know those as E U C, that E U C has been in place, um, since the start of the P H E and um, is actually also still in place as we speak. So, um, you actually have the ability in 2023, even with the expiration of the P H e to take that extreme and unusual circumstances hardship again this year. I do wanna remind you of, for some reason you have not reported an a hardship for 2022 and you were eligible, they did extend that reporting deadline to March 31st. Speaker 2 00:07:23 So you still have time if you haven't done a hardship for 2022. Uh, I'm telling everyone, if you can't remember, if you did it, go and check, it's really easy to check to see if you've applied for your hardship. And typically when you apply for your hardship, you get almost an immediate response that tells you whether or not you're approved. And so far, knock on wood, I haven't seen anybody not get approved for, um, the E U C related to COVID or the P H E, the 2023 performance. E U S C is available on the portable, right on the portal right now. So you can actually go out there and apply for that hardship and that deadline as of now is January 2nd, uh, 2024. They have typically extended that every year to where it wasn't that hard and fast. You know, January 1st, January 2nd. But I wouldn't bank on that. Speaker 2 00:08:18 So, um, you know, pay attention to it if it's something your practice knows, they're gonna apply for the hardship. You can go ahead and do that now, keep your documentation and then use the year to prepare, um, for 2024, which is coming, uh, apparently faster than we want it to be since we're already halfway through March. There are available exceptions other than the P H E Extreme and unusual usual circumstances. There's also the promoting interoperability exception, which has been out there forever, that just um, removes you from having to participate a report in promoting interoperability. But it should be known that when you exclude one category and if you're taking a hardship that doesn't exclude all the categories, then all it's doing is re-weighting. And so what it'll typically do is just put a higher weight on your quality score. So while the p h e uh, uh, hardship, you had the option to pick all four categories. Speaker 2 00:09:17 And so in that case you basically had no penalty. If you did not pick all four categories, then it would've just re-weighted to the categories that you did not select to be exempt from. Both of those exceptions require an application. Um, and if you decide to report a category but you've taken the exception, remember that that reporting can override the exception and would then revert, revert back to regrading the scores. So if you're eligible, you file for a hardship but then actually report, then it will override your hardship. If you're not eligible and you report, then they just consider it voluntary. There's no penalty. So if you are taking the hardship, just be sure that no one is reporting on your behalf if you do not intend to actually participate, cuz you could unintentionally get, uh, an unfavorable score because you didn't realize that you were actually getting reweighted to something that someone maybe was reporting for you on your behalf. Speaker 2 00:10:17 So looking at NIPS 2023, you basically have three options. Um, your option one, which is what we really just focused on, is to take that extreme unusual circumstances, uh, hardship again via that application submission. And uh, I didn't point it out but that portal, um, the portal address is right here that qpp.cms.gov, it's something that you know, if you've been reporting, you are very familiar with that website. So you can take the E S C via the application submission there. Um, you also have the option to go ahead and report metrics. I do have several larger practices or practices that participate in an A C O that really haven't stopped working towards improving their operations to actually meet these metrics. So as a reminder for 2023, uh, quality and cost are both at 30%. This hasn't changed from the previous year. And um, in accordance with, um, legislative reg regulations, quality and cost now have equal waiting. Speaker 2 00:11:26 Uh, PI is still at 25% of your total, um, uh, total consolidated score and then improvement activities are at 15%. These have not changed. One thing you should note too, and of course we're not gonna go through them here cuz there's a huge list. Metrics change from year to year. So especially if you've been taking a hardship the last couple of years and you wanna report this year or just in preparation for next year, as you see, uh, if you go back and look at what you've reported in the past, you wanna make sure that those, uh, metrics are still available to even report. Um, other things you may wanna make sure is that they haven't topped out, topped out metrics means that they basically give you no more credit. Everyone's done so well on it, so now you don't get any credit for it. Speaker 2 00:12:16 And the threshold for uh, 2023 is also 75 points. So that's also a bit of something to consider. 75 points is significantly higher. Um, I think we were at 60 and you know, when most people were reporting pre covid our um, threshold was, you know, 40. So we've come a long way. 75 is a pretty high threshold. Um, and there's no more exceptional performance category. So if you don't do exceptionally well, uh, or if you do exceptionally well, you're not gonna get an extra bonus like we used to in the past. Uh, it is harder to achieve that 75 point threshold, uh, primarily because a lot of our sort of floors are gone. So for example, you used to be able to report, um, some topped out measures and uh, there would be a floor of three or if the worst you could do for most measures was a floor of three. Speaker 2 00:13:12 So you couldn't get less than three points for a quality metric. Uh, now unfortunately that's gone away unless you're a small practice and if you report a measure that doesn't have a benchmark or has been topped out, then you actually could receive, uh, receive zero points. You can also receive zero points if you don't need meet your data completion requirements. So you're required to report 75% of your eligible reportable, um, occurrences or services that happen over the course of the year. If you don't report the 75%, then you actually, um, will also not get credit for that particular metric. Quality metric specifically when we look at things like PI or promoting interoperability and our, um, improvement activities, much like quality, those metrics change every year. And so it's important to go out and make sure that you're looking to see particular improvement activities. Is it still an activity? Speaker 2 00:14:08 Is it still weighted, um, in a way that you can get full credit that you need? And so just make sure you're checking that again at the portal. Option three is do nothing. This is the not good option, um, unless you're not eligible. So if you go check and you're actually not eligible for 20, uh, 23, then there's no penalty. There's really nothing to worry about. Um, but if you are eligible, that penalty would be applied in 2025. So make sure you're doing option one or option two, um, by the deadlines for 2023. So looking beyond, um, 2023 into next year, this is where I want people to really start thinking about where they are in terms of preparedness. It is likely that the p e related, um, hardship will go away in 2024. I actually expected it would go away in 2023. So I was quite, uh, surprised when we actually got the ability to apply for that p e related hardship this year. Speaker 2 00:15:11 So that means for most people in 2024, that reporting for for eligible req uh, providers is gonna be required. And that is a big steep 9% penalty if you don't participate. So, you know, it's time to dust off the MIPS reporting instructions, go log into the portal, make sure you still have access. Um, for those of you who have portal access, you know that if you don't log in within a year, they can suspend your access. Um, logging in seems to sometimes be half the feet of actually reporting, um, because the Q P P website is sometimes not easy to, um, get into. And then also make sure that you have, uh, reporting access through your system. So touching base with your vendors to ensure you can even still report outta your system. They could have updated their reporting module, you could have, uh, maybe you have to purchase something, maybe you have to turn some kind of functionality on that has changed since the last time you reported. Speaker 2 00:16:09 And all of those things need to be done prior to the start of the first year that you're going to be reporting. So if you're gonna be reporting in 2024 and haven't back since 2020, all of these things, it, it might be almost like, you know, reinventing the wheel somewhat. Um, we are here to help and answer questions obviously, uh, but there's a lot, a lot of changes that have happened in the last few years. I would start monitoring your performance now in 2023, meeting with your staff and your stakeholders to make sure that if there's operational changes that need to happen, that you take care of it. Now, even if you're not reporting in 2023, it takes a while to get behaviors to change. And so if staff, you may have new staff that have never been part of a reporting environment where you have to do certain things in the E H R to count, um, for metrics. Speaker 2 00:17:00 So those would be good things to kind of do an assessment for now and then put in place, um, kind of a set of steps to meet some milestones between now and when you need a report in 2024, again a assuming you aren't doing it this year, and then always pay attention to what happens with the final rule at the end of 20 23, 4 20 24, uh, we have this wonderful, uh, pattern that's going where about two days before the end of the year, they actually change the final rule. So we get this, we get our, um, preliminary rule, we get our final rule, and then we get though we're just kidding. This is really our final rule. And so the last two years we've gotten updates very close to the end of the year. So I just wanna remind everyone pay attention to that. It comes out. Speaker 2 00:17:49 Um, you know, we usually get, um, uh, preliminary proposed rule middle of the year with something more final around November. And then if they come back with some kind of weird change, it would typically be the very end of December. Um, so beyond 2024, traditional mips, like I said, is expected to sunset with the 2027 reporting year, but it doesn't go away. It's just gonna change to the MIPS value pathways, which will in theory become mandatory in 2028. Again, uh, like I said, a lot can happen between now and then. So pay attention to the rules and regulations and, um, have you have questions or any kind of concerns about kind of your status, always you're welcome to reach out to us. We have a whole team that does a lot of MIPS and are obviously getting really, really ready to ramp up and do it again in 2024. Speaker 1 00:18:42 Thank you for tuning into the kassouf podcast Network. Resources for today's episode are linked in the episode notes. Thank you to our producer Russ Dorsey and for Kassouf for powering this podcast. Be sure to stay up to date on new episodes and more information about today's episode by following at kassouf Co. Until next time, thanks for tuning in.

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