CMS has indicated its openness to flexibility and alternate methodologies on many parts of MACRA’s Quality Payment Program (QPP), so the final details are still TBD until the final rule drops (it’s anticipated November 1). But barring any delay in the start date, you could have as little as two months to prepare for the new scoring system.
The QPP’s MIPS and APM tracks will have more than a financial impact—it will also impact your reputation.
CMS employs public reporting, and physician scores are visible on the Physician Compare website. Consumers will see providers rated on a scale from 0-100, and they’ll also see how providers are related to their peers. As patients’ financial responsibility for their healthcare grows, they’re getting wise to quality and cost. MACRA addresses consumer demand for this information.
So while the rule is not yet final, you should be prepping like it is. Why? MIPS inherits many aspects of the current quality reporting programs like MU and PQRS, but don’t let this give you a false sense of security.
The Only MACRA/MIPS Prep Checklist You’ll Need (For Now)
- Educate yourself on proposed regulations and industry concerns. Websites for industry organizations often feature “advocacy” pages detailing legislation and analysis. The CMS website contains several clear, readable presentations on MACRA and the MIPS/APM scoring categories.
- Build awareness with providers on the importance of clinical documentation. Accurate and optimized documentation is non-negotiable if you want to benefit from reporting programs incentives and avoid penalties.
- Assess the skill levels of your coding team on capturing clinical documentation, especially in regards to the increased specificity that ICD-10 requires.
- Identify clinical conditions requiring ongoing treatment plans and increased patient monitoring for those being treated in your office.
- Perform a gap analysis for your current quality initiatives. A gap analysis helps you identify resources you have, resources you still need, and optimal allocation of those resources to position your practice to succeed under MACRA.
- Develop a plan of action for patient engagement. Engaged patients tend towards better outcomes, and MACRA emphasizes outcomes. Scoring is risk-adjusted, but this could be a stumbling block for physicians who treat large numbers of elderly or low-income patients or those with chronic conditions.
- Educate ancillary staff members in their roles for documentation.
- Work with tech vendors on patient recalls and notifications. Recalls ensure patient engagement and provide proof of your efforts to manage patient conditions, but they’re also simply a good business practice. Patient’s you don’t recall are patients who may not return—meaning lost revenue.
- Meet regularly with stakeholders to discuss progress and timelines.