Monday Musings

For the past two Mondays in May, I have been talking about the new incentive payment program that will determine how Eligible Professionals (EPs) are paid, referred to as the Merit-Based Incentive Payment System (MIPS). Last week I told you that MIPS would be based on quality, resource use, meaningful use of an EHR and clinical practice improvement activities. Professionals will receive a composite performance score of 0-100 based on their performance in each of these four performance categories. Professionals will only be accessed on the categories, measures, and activities that apply to them. Scoring weights for performance categories, measures, and activities may be adjusted to ensure that individuals are measured on an equitable basis. Professionals will know what composite score they must achieve to obtain incentive payments and avoid penalties at the beginning of each performance period.

Each eligible professional’s composite score will be compared to a performance threshold. Eligible professionals whose composite performance scores fall above the threshold will receive positive payment adjustments and eligible professionals whose composite performance scores fall below the threshold will receive negative payment adjustments. Professionals will have the flexibility to participate in MIPS in a way that best fits their practice environment. These options include the use of qualified clinical data registries (QCDRs) like the US Wound Registry and the option to be assessed as “virtual” group, or with an affiliated hospital or facility.

Professionals will receive confidential feedback on performance in the quality and resource use categories at least quarterly, likely through a web-based portal. Professionals may also receive confidential feedback on performance through a QCDR. Needless to say, I’m paying close attention to everything they say about QCDRs since that is the best way forward for wound care professionals.

What is at stake?

The law increases physician pay annually 0.5%, starting in June, through 2019. Pay rates then remain flat through 2025. Starting 2026, the pay rate for physician services increases annually by 0.75% for physicians in alternative payment models. Those not in alternative pay models get only a 0.25% pay bump each year. Providers who get a substantial part of their revenue from alternative pay models also get a 5% bonus from 2019 through 2024, in addition to shared savings bonuses or fees they might receive for participating in those models.

Those with poor MIPS performance scores are penalized with 4% pay cuts, starting in 2019, and by 2022 the penalties are 9%. Those with excellent scores earn bonuses of up to 10% of their fee-for-service pay rate. The merit-pay system is similar to the current hospital value-based purchasing program. Eligible providers will not be subject to the new merit-pay program if they are in alternative pay models.

What will alternative payment models look like in wound care? I think they will start with “bundled payments”. Bundled payments are different from the “package pricing” that has already affected cellular and tissue based products. Bundled payments will combine episodes of care or various services into one payment in order to reward efficiency. However, they will be just the beginning.