Medicare Compliance & Reimbursement

MPFS suggests more technical overhauls ahead for MIPS.

Over the last year, an abundance of health IT-forward policies have come down the pike from CMS. The tech-heavy initiatives suggest that if you aren’t on the EHR bandwagon yet, now might be the time to jump on. New Quality Payment Program (QPP) proposals rely heavily on electronic health change-ups that will impact your Part B reimbursement.

Nuts and bolts: The CY 2019 Medicare Physician Fee Schedule (MPFS) proposed rule, released on July 12 and published on July 27 in the Federal Register, is permeated with Merit-Based Incentive Payment System (MIPS) initiatives that support and promote the electronic exchange of health data. Back in May, CMS spearheaded a health IT renaissance with its rebrand of Advancing Care Information (ACI) and Meaningful Use (MU) to Promoting Interoperability (PI).

You can see the MPFS proposals at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf.

“We are advancing the MyHealthEData Initiative which promotes the interoperability of electronic medical records. Patients must have control of their medical information; and physicians need visibility into a patient’s complete medical record,” maintained Seema Verma, CMS Administrator in a “Note to Doctors” on the MPFS quality proposals. “Having all of a patient’s information available to inform clinical decision-making saves time, improves quality, and reduces unnecessary and duplicative tests and procedures.”

Verma expounded, “CMS is taking action to make this vision a reality, including recently proposing a redesign of the incentives in the Merit-Based Incentive Payment System or ‘MIPS’ to focus on rewarding the sharing of healthcare data securely with patients and their providers.”

Here’s What’s on the MPFS Checklist for PI

The agency hopes that its suggested technical updates will make MIPS participation easier and more efficient, but remember stakeholder feedback may impact the finalized rule slated to come out in the late fall. There will be significant changes to PI going forward, according to the MPFS guidance. Consider these three breakdowns of MIPS PI proposals from Mike Schmidt, Vice President of Client Success and Regulatory Affairs for Eye Care Leaders in Charlotte, North Carolina:

• PI scoring revisions. “The concept of Base vs. Performance vs. Bonus scores are being eliminated,” explains Schmidt. He notes that “instead the MIPS PI score will be entirely performance oriented” with “four objectives: e-Prescribing, Health Information Exchange (care coordination), Provider to Patient Exchange (patient engagement), and Public Health and Clinical Data Exchange (registry reporting).”
• Certified EHR Technology (CEHRT) 2019 requirements. “2015 Edition CEHRT is mandatory for MIPS PI, as expected, however performance period requirements stay the same as 2018,” advises Schmidt. “In particular [the requirement] will be only 90 days for MIPS PI, thus implicitly giving further allowance for implementing 2015 Edition CEHRT during 2019.” The policy also mandates that providers “must have 2015 Edition CEHRT live by Oct. 3, 2019,” he cautions.
• Improvement Activities. CMS proposes getting rid of some MIPS PI bonus points for specific Improvement Activities that utilize CEHRT. “This cross-connection between the two performance categories is eliminated,” stresses Schmidt. “There may be resistance to this change in the public comment process, so wait and see.”

Resource: Review the QPP fact sheet on the CY 2019 MPFS proposed rule at www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-QPP-proposed-rule-fact-sheet.pdf.