How Will MIPS Impact Your Behavioral Health Practice?

How Will MIPS Impact Your Behavioral Health Practice?

With the Merit-based Incentive Payment System, better known as MIPS, on the horizon, what can psychiatrists and behavioral health specialists expect from the changes?

First, there’s a renewed focus on improved patient care – and practitioners will be rewarded (financially) for those improvements. CMS is also placing greater emphasis on value, as it applies to patient care and to EHR technology.

Better patient care, smarter spending and healthier people

Health care delivery improvements are integral to MIPS. Better care, smarter spending and healthier people – those are the “Big 3” goals for MIPS. For physicians, this translates as an emphasis on:

  • Physician performance metrics (with financial incentives for providing high-quality patient care)
  • New Medicare reimbursement formula
  • Information-sharing via EHR systems

In this structure, MIPS links fee-for-service payments with quality and value – not on quantity, and not on simply having an EHR system. EHR technology slips into a supportive role for patient care, with an emphasis on better-connected systems.

One physician’s EHR system should be able to communicate with another clinician’s system. Patient records should be transferrable – so that patients can receive optimal care wherever they are in their travels. If they see another provider, the flow of patient records should be seamless.

A patient’s psychiatric or other health conditions should be immediately known to every behavioral health professional he or she sees. This is critical when patients travel or relocate, and invaluable when patients interact with law enforcement or need emergency services.

When all entities understand the big picture, the result is optimal care, respect and empathy for that patient. That is the goal for MIPS.

Ending the SGR component of the payment formula

With MIPS, the reimbursement formula is also changing. Booted out is the Medicare Part B Sustainable Growth Rate (SGR) reimbursement formula.

The new arrival is a value-based reimbursement system called the Quality Payment Program (QPP). The QPP has two tracks: The MIPS track or the Advanced Alternative Payment Models (Advanced APMs).

In 2019, you’ll be able to choose between the two – although MIPS offers rewards you might not want to pass up.

New rewards system

MIPS creates a new rewards system for improving the delivery and value of care. Behavioral health clinicians participating in MIPS will have:

  • A small, annual inflationary adjustment to the Part B fee schedule. 
  • MIPS payment adjustments (incentives or penalties) based on the MIPS 100-point Composite Performance Score (CPS).

The inflationary adjustment is an annual 0.5% increase for 2016 to 2019.

Payment adjustments (rewards) via MIPS are potentially much more substantial. Note: The MIPS penalties can be just as substantial.

MIPS = Better Patient Care = Financial Incentives

MIPS is designed to provide incentives for excellent patient care. With that comes a Composite Performance Score (CPS) program that rates each clinician’s performance in 4 categories:

  • Quality (50%)
  • Advancing Care Information (ACI, renamed from Meaningful Use) (25%)
  • Clinical Practice Improvement Activities (CPIA) (15%)
  • Resource Use (10%)

The CPS earned by a clinician for a given performance year will determine MIPS payment adjustments in the following year.

Starting in 2018, psychiatrists in small practices (of up to 10 clinicians) may be able to form “virtual groups” for joint MIPS reporting and assessment. The infrastructure is still being developed, however.

MIPS Incentives & Penalties

The Good News: If a behavioral health clinician earns a CPS of 100 points, then the incentive is 4%. There is an additional “exceptional performance bonus” that escalates up to 10% for progressively higher performers within the top ~30%. This is for the top 75% of those earning an incentive.

The Bad News: If a clinician has a CPS of zero, the penalty assessed is 4%, the maximum penalty.

Bottom Line: Every ranking in between is possible. The top-to-bottom MIPS potential impact on Part B payments for 2017 is likely to be from a 14% incentive down to a -4% penalty, or a total 18% top-to-bottom swing.

MIPS scores go public

That’s right, CMS will release each clinician’s annual CPS performance to the public.

For the first time, consumers will be able to see their providers rated on a scale of 0 to 100 and how their providers compare to peers nationally. This goes beyond existing programs. VBM, for example, calculates quality and resource use scores — but does not publicly publish the results.

Don’t panic about MIPS!

The MIPS program is a lot for behavioral health professional to digest, and may feel intimidating. Don’t panic, as we’ll lay out steps you can take to prepare for the changes.