- Small and rural practices are more likely to struggle with Merit-based Incentive Payment System (MIPS) participation, the Government Accountability Office (GAO) explained in a recent report. Legacy program requirements, lacking financial and staff resources, and technology issues can all contribute to the MIPS participation challenges.
Physician practices with 15 or fewer providers located in rural or non-rural areas are more likely to receive a negative payment adjustment in legacy Medicare payment incentive programs than larger practices, GAO stated, citing CMS data from 2015.
CMS then projected that in 2017 and 2018, larger practices using legacy program data would see a higher percentage of success in MIPS than small practices. GAO defined success as positive or neutral payment adjustments.
“CMS also projected that small practices would be more successful in MIPS than they had been in the legacy programs,” report authors explained.
CMS assumed that small practices would increase their participation in MIPS because of the flexibilities built into the program that would help make practices successful,” the report continued. “If CMS assumed that small practices would participate in MIPS at historical legacy program participation rates, a lower percentage of small practices would be expected to receive a positive or neutral payment adjustment under MIPS.”
GAO interviewed 23 stakeholders and identified challenges facing small and rural practices that participated in Medicare legacy programs.
Technological problems, such as practices purchasing EHR systems that are not suited to meet their needs, was one key challenge identified.
Practices can also face issues with financial and staff resources. For example, an organization may not have the necessary financial resources to hire additional staff needed to manage participation in the program, GAO noted.
Additionally, legacy program requirements can create challenges. A practice that has fewer staff to monitor changing program requirements may not be able to stay current, report authors pointed out.
“CMS officials told GAO that CMS has actions underway that they believe address these challenges,” the report explained.
“For example, CMS has developed educational resources; contracted with organizations to provide technical assistance to small and rural practices; and incorporated flexibility into MIPS, such as allowing practices with 10 or fewer providers to participate as a virtual group that can work together and share resources.”
CMS is working to lower MIPS participation barriers and reduce associated burden for small practices and those located in rural areas, GAO noted.
“CMS officials said that they have heard challenges and suggestions similar to the ones we identified and that many of their efforts related to the design of MIPS are responsive to these challenges and suggestions,” report authors said.
“CMS officials told us that instead of requiring providers to meet a number of Advancing Care Information category requirements, CMS will review whether providers make progress on a few key uses of EHR technology, such as engaging with patients via EHR systems and exchanging health information with other providers,” GAO continued.
“In terms of the stakeholder suggestion to increase the oversight of EHR vendors and standardization of EHR products, CMS officials said that, to address this issue, CMS allows providers to use an older version of EHR certified technology in MIPS year 2 and to apply for hardship exceptions.”
CMS is also trying to ensure that there are quality resources available to small and rural practices. For example, there are online Quality Payment Program resources, including information about the four MIPS performance categories and the ability to check whether a specific provider is required to participate in MIPS.
Webinars and presentations providing MIPS eligibility information is also offered, where “CMS provides opportunities to answer providers’ questions, including during the presentation itself and also via a chat function.”
Earlier this year CMS noted success of MIPS participation, with 91 percent of eligible clinicians participating during the first year of the Quality Payment Program (QPP).
The goal had been to have 90 percent participation, CMS said in a May 2018 announcement.
“Remarkably, the submission rates for Accountable Care Organizations and clinicians in rural practices were at 98 percent and 94 percent, respectively,” CMS Administrator Seema Verma stated. “What makes these numbers most exciting is the concerted efforts by clinicians, professional associations, and many others to ensure high quality care and improved outcomes for patients.”
CMS also stressed the importance of reducing administrative burden, pointing out the agency has been working to visit healthcare facilities and meet with providers to better understand daily challenges.
“We’re also eager to improve the clinician and patient experience through our Meaningful Measures initiative so that clinicians can spend more time providing care to their patients and improving the quality of care their patients receive,” Verma wrote in a blog post. “Within MIPS, we are adopting measures that improve patient outcomes and promote high-quality care, instead of focusing on processes.”