CMS Reveals Motive for MACRA Proposed Rule MIPS Changes

The Healthcare Business Management Association (HBMA) Government Relations Committee was fortunate to have the opportunity to meet with Centers for Medicare & Medicaid Services’ (CMS) directors and Senate Ways and Means Committee staff the day the proposed rule was published.  

As I think we all have recognized, the most significant changes are intended to help small providers and practices. The proposed threshold increases in patient volume or dollars have, in effect, exempted many providers from participating in the Merit-based Incentive Payment System (MIPS). The ability to form virtual groups is also intended to allow maximum flexibility.  Those are positive steps in recognition of the challenges MIPS presents.

In addition, many new options are proposed. For example, the ability to report 2018 quality measures via multiple methods as opposed to only claims, registry, etc. More measures have been added to increase successful reporting choices and opportunities for participating providers.  

The Flip Side of the Coin

While these increased options and choices may sound good at first blush, the fact is that complexity and, therefore, cost for providers also increases. The thoughts and work behind the changes are well-intentioned.  However, as author Dean Koontz said, “One man’s idea of perfect order is another man’s chaos.”  

Some of the most basic informed decisions that providers must make are whether they want to work toward a bonus, remain revenue neutral, or accept a penalty.  Accurately performing those projections based on specialty and practice-specific variables requires increasingly sophisticated software support and data analytics.  

The unfortunate fact is that providers can make the best efforts to do everything right and still not be guaranteed of a bonus or even the amount of the bonus.  Because the program must be revenue neutral, for every winner there must be a loser.  One observation is the fact that “most providers will be forced to the middle”—and, in my opinion, that is the crux of the problem with MIPS. 

How much money and work will providers invest when there is no return on that investment?  We already know a very large percentage of eligible clinicians never participated in the Physician Quality Reporting System (PQRS).  Are we really going to accept that none of those physicians or practices are providing quality care?  Are we really going to accept that every physician or practice that does participate is providing the best quality care?  I hope not, for that is a false belief that reporting data is the same as providing quality care.  

While CMS’s intent to ensure all beneficiaries receive high quality care at a reasonable cost is a noble one, the methodology to achieve it is flawed.  Adding myriad options that simply increase cost and complexity for physicians and their representatives, with no return on those investments, continues to whittle away at the precious time physicians have for their real job, which is patient care.  That’s where quality happens, not in data-reporting.  

Let’s help physicians get back to what they do best by removing the overwhelming administrative burdens. Then we will see real and meaningful quality.