The Ugly Truth About MIPS

The Merit-based Incentive Payment System (MIPS) is a quality payment program introduced by the Centers for Medicare and Medicaid Services (CMS) in 2017. MIPS reporting is essential for healthcare providers who participate in Medicare, as it affects their reimbursements AND reputations. However, many providers make the mistake of only focusing on MIPS reporting during the fourth quarter of the year. This approach can lead to a lot of stress and frustration, as well as missed opportunities for improvement.

MIPS reporting is a year-round initiative

While the submission period is in Q1 of the following year, the data collection period spans the entire calendar year, 1/1/23-12/31/23. This means that providers need to monitor their performance and data constantly to ensure they meet the requirements for each category. Let’s take the Quality category, for example. This category requires providers to report on six measures, one of which must be an outcome measure. This means that providers need to identify their top 7-10 measures and monitor their performance on these measures throughout the year to ensure they are meeting each measure’s requirements.

Constant data monitoring is crucial because it allows providers to identify areas where they need to improve and take corrective action before the end of the reporting period. Our Government Incentives Team at DAS Health always recommends a proactive approach to MIPS all year long. If you are reactive to your data, you will fall behind and it will result in a penalty or lower reimbursement rate.

Here are some tips and tricks we recommend when monitoring MIPS performance year-round:

• Run your reports no less than monthly! Avoidance is never a good strategy, especially with MIPS, trust us! 
• Provide proactive workflow training to end users each measure will impact. Don’t wait for performance to dip to provide education. Create resources that are easily accessible for office staff and clinical team to reference at point of care.
• Create a reporting strategy and break it down into manageable action items you can prioritize throughout the year.
• Share measure results consistently with providers, clinical team and office staff to gain buy-in. Celebrate key increases in performance while also sharing any decreases in performance to motivate team members.

By following these action items breaking down MIPS reporting into smaller time frames, you can avoid the stress and pressure that comes with last-minute reporting and improve performance to earn higher reimbursements.

The exception to the rule

Now for 2023 only, there is an exception to the “MIPS Reporting is a Year-long Initiative” mindset. For 2023 only, practices can get away with only tracking data for 90 days. How? Well, if a provider/ practice is reporting on the Promoting Interoperability (PI) and Improvement Activities (IA) categories and is utilizing the COVID-19 Extreme and Uncontrollable Circumstances (EUC) hardship exemption for Quality and Cost, they may only need to report for a 90-day period in 2023. This exemption was newly announced by CMS for the 2023 MIPS performance year and is designed to provide relief to providers who were affected by the pandemic. HOWEVER, even in this scenario we recommend our clients still track their Quality data throughout the year to identify areas for improvement and education to gear up for next year’s reporting as it begins immediately on 1/1/24.

So we are back to the ugly truth: you never really get a break from MIPS if you want to be successful and reap the financial benefits of the program. But don’t worry! You do not have to face MIPS alone, your DAS Health Government Incentives team is here to help!