MAY 18, The Hidden Impacts of MIPS

Transcription

1 MAY 18, 2017 The Hidden Impacts of MIPS

2 Speakers TOM S. LEE, PHD CEO & Founder SA Ignite MATTHEW BARRON Director, Advisory Services SA Ignite MATTHEW FUSAN Director, Solutions Consulting SA Ignite 2

3 Agenda What s Happening in the Field Top 3 MIPS Hidden Impacts Q & A 3

4 What s Happening in the Field The MIPS treadmill continues to accelerate - AHCA uncertainty not stalling activity 2018 QPP Proposed Rule coming soon Provider organizations realizing MIPS hidden impacts 4

5 MIPS Hidden Impact #1: Public Reputation CMS publishing clinician/group-identifiable MIPS scores & measure rates A low 2017 MIPS score sufficient to avoid a penalty will be published alongside competing scores Free downloadable data file for third parties to use Regulatory references: 2017 QPP Final Rule - p of 2,398-page PDF, Section II.E.10. MACRA legislation p65 67 of 263-page PDF, Section 101.(c).(1) inserting (q).(9) into Section 1848 of the Social Security Act (42 U.S.C. 1395w 4). 5

6 MIPS Score and Payment Adjustment Attached to Clinicians for 2 Years Performance Year Worksite Org A Org B Org C Reporting Individual s Score Group s Score Payment Year Worksite Org C is paid based on Org A score Org C is paid based on Org B score Credentialing & Contracting Compensation M&A 6 6

7 Where MIPS Scores Will/Could be Published Physician Compare Healthgrades.com Google Consumer Reports Yelp Angie s List 7 7

8 MIPS Hidden Impact #1: Public Reputation Estimated revenue impact of consumer choice influenced by clinician reputation: 1-star increase on Yelp s 5-star scale = 5% to 9% increase in revenue* Say 10 MIPS points = ½ star 2.5% to 4.5% consumer-choice revenue impact Compare to revenue impacts of 2017 MIPS payment-adjustment variations: For +/- 10 MIPS points centered around 50 points = +/ % For +/- 10 MIPS points centered around 80 points = +/- 0.43% Revenue impact of consumer choice 6x to 50x larger than payment adjustment! The Impact of Online Reviews on Customers Buying Decisions, July

9 MIPS Hidden Impact #1: Public Reputation Facts & Assumptions 21% of Medicare Advantage consumers in a health plan knew their plan s 5-Star Rating. Say 21% of consumers do not choose MIPS clinicians with score < 60 points, and 20% of all MIPS clinicians score < 60 points. CMS estimates 2017 MIPS paymentadjustment penalties of $199M/year Lost Revenue Consumers 21% MIPS Clinicians x 20% CMS Est. Payment x $110B CMS $ to All Clinicians = ~5B/yr Impact Revenue loss from consumer choice is ~ 25x larger than 2017 MIPS penalties! 9

10 MIPS Hidden Impact #1: Public Reputation More information on MIPS public reputation impacts: Optimizing Provider Reputation Under MACRA and MIPS, HFMA Leadership, Oct 26, 2016 Docs risk reputation damage by reporting minimal MIPS data, Medical Economics, Apr 3,

11 MIPS Hidden Impact #2: Recruiting & Compensation Impact on clinician recruiting The hiring organization inherits payment adjustments from clinicians historical MIPS scores Impact on clinician compensation plans Organizations want to align clinician compensation with MIPS financial impacts on the organization Resulting impact on clinician recruiting Clinicians want to join organizations successful in enabling high MIPS scores 11

12 What We Hear from the Market If my plan has changed and I am personally responsible for more out-ofpocket costs of my health care, I'm going to want to know and I'm going to be more demanding and I'm going to be pickier. MGMA Healthcare Consulting Group Forty-five percent of consumers have viewed provider ratings/reviews online, 31 percent have selected a doctor based on a positive review, and 32 percent have avoided a doctor based on a negative review. National Research Corporation Every patient I see has found me through Google. Specialty clinician, Texas 12

13 How to Engage Clinicians Regarding MIPS? 1. Recognize importance of patient and clinician satisfaction Support from leadership aligns goals and strengthens programs 2. Collaborate with clinicians Physician engagement is critical; success is dependent on their involvement 3. Provide feedback loop to clinicians and staff teams Clinicians are competitive, but need to know what they are being judged on and where there are opportunities for improvement 4. Provide transparency Communicate efforts that are successful, and those that fail 13

14 MIPS Hidden Impact #3: APM Participants Why are Advanced APMs Still Tracking and Managing MIPS? 14

15 Many Organizations Participate in a Combination of MIPS/APMs/Advanced APMs Healthcare Organization Group 1 Group 2 Group 3 Group 4 Participating in an MSSP Track 1 ACO Clinicians participate in MIPS based on MIPS APM Scoring Standard Clinicians joining after September 1 must participate in full MIPS No APM participation Clinicians will participate in full MIPS Some clinicians participating in CPC+, other clinicians are not in any APM CPC+ clinicians will participate in the Advanced APM track Non-CPC+ clinicians will participate in full MIPS 15

16 MIPS APM Scoring Standard: 2017 Scoring applies to MIPS eligible clinicians who are not sufficiently participating in an Advanced APM, or are participating in a non-advanced APM. MIPS Performance Full MIPS Scoring MSSP or Next Gen ACO Other MIPS APMs Categories for Non-Advanced (examples of (exclusive of MSSP and APM MIPS APMs ) Next Gen ACO) Quality 60% 50% 0% ACI 25% 30% 75% IA 15% 20% 25% Cost 0% 0% 0% MIPS APM Example: Track 1 ACO MIPS APM Example: Oncology Care Model (one-sided risk) 16

17 APM Participation Snapshots Qualifying Snapshots Jan 1 Mar 31 Jan 1 June 30 Jan 1 Aug 31 Sept 1 Dec 31 Determines qualifying participants (QP) & APM participants ECs that have not been captured in a snapshot are subject to full MIPS 17

18 Summary MIPS Hidden Impact #1: Public reputation MIPS Hidden Impact #2: Recruiting & compensation MIPS Hidden Impact #3: APM participants 18

19 Q & A Connect with SA Ignite