The prospect of “performance scores” has raised questions among psychiatry physicians. Every independent behavioral health practitioner has concerns about the Merit-based Incentive Payment System, aka, MIPS, and how it will affect Medicare reimbursements.
Your Composite Performance Score (CPS) will determine whether you get financial rewards – or penalties.
You can earn significant financial rewards for providing excellent patient care under this MIPS plan. You can also be penalized.
Composite Performance Score (CPS)
MIPS provides small inflationary adjustments, but the incentives and penalties tied with the CPS adjustments are more substantial.
Every psychiatry physician’s performance is ranked according to specific measures. Every CPS point translates directly into higher or lower reimbursement.
These CPS scores allow Medicare clinicians to be paid for providing high-quality, efficient care through success in four performance categories:
- Quality – 50% of your CPS score
- Advancing Care Information/Meaningful Use – 25%
- Clinical practice improvement activities– 15%
- Cost/Resource use – 10%
The CPS earned by a clinician for a given performance year then determines MIPS payment adjustments in the next calendar year.
The Good, The Bad, and The Potential
If a clinician earns a CPS of 100 points, the reward is +4%. An additional “exceptional performance bonus” escalates up to +10%. An excellent CPS number will yield 4% + 10% = +14%. A physician with excellent CPS numbers could accrue incentives reaching 37% of Medicare Part B payments by the fourth year of the program.
However, if a clinician has a CPS of zero, the penalty assessed is -4%, the maximum penalty. Maximum penalties can grow to -9%.
How will CPS scoring affect you?
It’s expected that very few eligible clinicians will get a zero payment adjustment. Each psychiatry physician’s CPS number will now be made public, so this new level of transparency will likely push clinicians to achieve high CPS numbers right out of the gate.
The first results of these CPS adjustments will start in 2019. At that point, psychiatrists will start seeing all Medicare payments with a MIPS adjustment (based on 2017 CPS scores).
Exempt psychiatrists
Certain psychiatrists are not included in the MIPS reward program – those who have just enrolled in Medicare that year, had a “low volume” of Medicare patients or claims, or qualified for the MACRA/APM bonus. Psychiatrists can also form “virtual” groups with other physicians for the purposes of reporting.
Start preparing now
The best way for independent psychiatrists to prepare for MIPS is to start participating in the Physician Quality Reporting System (PQRS) and Meaningful Use program this year or be prepared to do so in 2017, the first MIPS reporting period.
APA will help streamline MIPS reporting
The American Psychiatric Association (APA) has begun preliminary steps toward creating a registry to streamline MIPS reporting and significantly decrease the administrative burden for individual practitioners.
The APA website has detailed instructions to help psychiatrists participate in PQRS and Meaningful Use. The APA will be adding MIPS resources as the process is further fleshed out.
Also, the APA is one of just 39 organizations chosen to participate in the CMS Transforming Clinical Practice Initiative, which will help connect psychiatrists with Practice Transformation Networks in their region. The networks will provide practices with on-the-ground support as they prepare for these changes.
Watch for MIPS updates
At this printing, MIPS is scheduled to take effect January 1, 2017. The department of Health and Human Services has until November 1, 2016 to publish the quality measures. However, what you’ve just read is the most recent and accurate information we’ve gathered to date.