January 22, 2019
Summary: The budget neutrality required by MACRA and the high performance by anesthesia and pain management groups in the Quality Payment Program so far means that providers within the specialty are unlikely to earn significant bonuses by participating in MIPS in 2019. However, compelling reasons to continue reporting remain: 1) insurance carriers continue to require it; 2) hospitals and facilities continue to request it; and 3) practice trend data is a valuable asset for organizational reviews. We encourage providers to review the quality measures awaiting approval by CMS through the MiraMed QCDR in order to begin planning for 2019.
As with any federal healthcare program, the Merit-Based Incentive Payment System (MIPS) continues to change and evolve. 2019 doesn’t break from that trend. This eAlert will review the currently available information regarding changes to the MiraMed Qualified Clinical Data Registry (QCDR) for anesthesia and chronic pain management providers resulting from the 2019 program updates. We will provide further information when the Centers for Medicare and Medicaid Services (CMS) publishes final notifications regarding the QCDR measures.
2019 MIPS Highlights
Many features of the MIPS program remain the same for 2019, providing a level of consistency for anesthesia and chronic pain management practitioners that we haven’t enjoyed so far under MACRA and MIPS. There are a few noteworthy items to keep in mind with regard to 2019 MIPS compliance. Specifically:
- Payment adjustments for 2021 based on 2019 reporting will increase to +/- 7% (bonus/penalty).
- The performance minimum threshold has increased from 15 points in 2018 to 30 points in 2019.
- Performance period requirements are the same for 2019 as they were in 2018:
- Quality: 12-month calendar year performance period
- Cost: 12-month calendar year performance period
- Promoting Interoperability: 90 days minimum performance period.
- Improvement Activities: 90 days minimum performance period.
CMS estimates that 91.2 percent of all MIPS eligible clinicians will receive positive or neutral payment adjustments. That level of participation will continue to depress the bonus that you could earn, so please keep that in mind when evaluating whether to participate in 2019. It is not likely that any anesthesia provider or group will receive the full 7 percent bonus for MIPS participation.
Quality Reporting Changes: What Did We Lose?
The program has grown in size and scope, but along the way, several measures have been classified as “topped out,” and therefore, CMS no longer considers these measures useful in evaluating providers. This elimination of topped out measures represents medicine’s continuing effort to find measures that meet the goals of proper evaluation of a provider’s and group’s quality without causing undue cost and workflow disruption to patient care. As we all continue to seek measures that balance these two competing drivers, we are bound to lose measures along the way.
The following measures are not eligible for reporting in 2019:
- MIPS426 – Post-Anesthetic Transfer of Care Measure: Procedure Room to a Post-Anesthesia Care Unit (PACU)
- MIPS427 – Post-Anesthetic Transfer of Care: Use of Checklist or Protocol for Direct Transfer of Care from Procedure Room to Intensive Care Unit (ICU)
- MM17 – Rate of Witnessed Gastric Aspiration
- MM18 – Unplanned Conversion to General Anesthesia from Regional or MAC for all scheduled cases
This is unfortunate for anesthesia, as these measures were widely reported; however, they did not show the level of quality differentiation that CMS was looking for. CMS states that if the average performance rate is above 95 percent, then the measure will be considered for exclusion. This approach presents a difficult challenge for anesthesia, as the specialty is considered to be one of high quality that delivers a large proportion of care in a high acuity environment. However, collaboration among the anesthesia registries may ease the specialty’s burden in the long run.
What Quality Measures Can Providers Report in 2019?
As the QCDRs continue to search for the quality measures that will best represent the specialty, the MiraMed QCDR has decided to work collaboratively with the other registries to bring additional measures to its clients. In some cases, we have licensed measures from other registries or harmonized measures drafted with other registries. These collaborative efforts allow the anesthesia specialty to work together towards our mutual success.
The MiraMed QCDR expects to support the following measures for 2019:
Additionally, the MiraMed QCDR will support the traditional MIPS measures such as:
If you are a current MiraMed QCDR client, materials will be distributed to you within the next few weeks that will include details for each measure; however, CMS requires the QCDRs to wait to distribute this material until they have officially approved the measures. In the meantime, to prepare to report in 2019, we recommend reviewing this list to identify the measures that look appropriate for your scope of practice.
Do You Need to Report?
Many providers are questioning if there is a need to report in 2019. While the financial incentives for anesthesia shown on CMS’s MIPS website (qpp.cms.gov), aren’t what you might expect, it is still advisable to report for three main reasons: 1) insurance carriers continue to require it; 2) hospitals and facilities continue to request it; and 3) trend data on your own practice is a valuable asset for organizational reviews.
If you have any questions regarding whether your practice is required to report, please use the participation status lookup on the CMS website (https://qpp.cms.gov/participation-lookup).