Caravan Health Brief Examines Impact of ACOs on MIPS Payments for All Eligible Clinicians
With the first performance year for the new Merit-Based Incentive Payment System (MIPS) underway, eligible clinicians must strategize payment implications under the program. Unlike the Physicians Quality Reporting System, Meaningful Use and the Value-Based Modifier, MIPS places the performance of each clinician on a curve, and adjusts payments based on their precise location in the distribution compared to others.
Lynn Barr, MPH, CEO of Caravan Health, and LeeAnn Hastings, JD, MPH, Compliance Officer for 23 Medicare Shared Savings Program ACOs, have released an issue brief, Impact of ACOs on MIPS Payments for All Eligible Clinicians, comparing MIPS payment adjustments of ACO participants versus non-ACO participants. The brief illustrates that Medicare Shared Savings Program (MSSP) participation will enhance MIPS performance and increase the likelihood of receiving the exceptional performance bonuses. Exceptional performance bonuses are only available the first five years of MIPS and, depending upon the number of exceptional performers, could receive up to ten percent in addition to the maximum positive payment adjustment, which is up to three times the penalty for the first five years of the program. Taking into account the’s scaling factor and the exceptional performance bonus, a top-performing practice could theoretically earn up to a 25% payment adjustment in the 2018 performance year.
According to Ms. Hastings, “MACRA requires that 30% of the MIPS score is based on Resource Utilization. Track 1 ACO participants, however, are held accountable for cost in their ACO and not MIPS. As a result, Track 1 ACO participants can more easily achieve high scores compared to other MIPS participants, increasing the likelihood of avoiding MIPS penalties and earning the exceptional performance bonus.”
To predict MIPS bonuses, Barr emphasizes that clinicians must know both their performance score and estimate the score of the rest of the providers in the MIPS pool. Up to 40% of eligible clinicians in the pool are expected to be participants in Track 1 Medicare Shared Savings Program ACOs. Those ACOs will receive special scoring causing most other MIPS-eligible clinicians to receive lower adjustments in comparison.
Barr states, “Small practices should consider joining an ACO to avoid penalties for generally lower scores due to lack of infrastructure, and providers in rural areas may want to join ACOs to avoid MIPS penalties due to their higher cost structures. Community hospitals can earn high bonuses and support their community physicians, particularly specialists, by enrolling them in their ACO, protecting their incomes and reducing their administrative burden.”
Caravan Health, who currently supports 160 community hospitals and 250 practices in 23 Medicare Shared Savings Program ACOs, is holding weekly webinars to help providers navigate the ACO process and fully understand how to maximize their incentive payments. Participants will receive step-by-step financial guidance on how to calculate potential penalties and bonuses under MACRA.
Webinars are held on Fridays at 8:30am PT/10:30am CT/11:30am ET. To register, visit www.carvanhealth.com/upcomingevents/.
The full brief, Impact of ACOs on MIPS Payments for All Eligible Clinicians, is available for download at www.caravanhealth.com/macra.