CMS’s Merit-Based Incentive Payment System (MIPS) is Back Online — What Now?

One of the toughest challenges I had at my previous practice, Resurgens, was leading the group through a change of electronic medical record (EMR) systems, which — as anyone knows who has been through it — is something a practice should only do if the end-goal is really clear, important, and measurable. The dominant reason for this shift was to position Resurgens to participate more successfully in the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) pathways, specifically MIPS (Merit-Based Incentive Payment System) and other alternative payment models. CMS’s reengagement with the physician community in this space — as summarized in a recent Practical Economics piece in CORRelations — takes me back to the struggles practices had with these programs before the pandemic. These are not fond memories.

The issue with these governmental programs is that they are difficult to understand and even harder to navigate. Our group found that solutions for MACRA are so resource-intense that practices must get outside vendors to comply with any reasonable efficiency or effectiveness, thus the EMR shift for our group. For a practice to drive the solution themselves, the internal workload and physician attention would be substantial or prohibitive. As a result, almost all practices manage this process through their EMR vendors, or they just ignore the rule altogether. It may be reasonable not to participate, but ignoring the rule without thinking it through is a potential missed opportunity, as some practices really stand to benefit.

The AAOS has worked to make compliance with these programs much easier, and there are many commercially available options as well. But whatever you do, don’t be passive and let these changes hurt your practice.

Here are two other specific suggestions to consider:

• Do the cost analysis to see if the penalties outweigh the costs for complying with the rule, but be aware that CMS will continue to urge physicians toward compliance.
• Engage with your EMR vendor to better understand how it submits your data to CMS.  This is a very complicated process, full of non-intuitive abbreviations and language. Ensure the vendor can submit your quality data to CMS and explain to you how it happens. Also, ask whether they are aware of best practices learned from other practices they service that may enable you to be more successful with MACRA.