When Federal Regulations Mean Less Cash Flow


Tips for radiology practices on compensating for a loss from MIPS.

The Medicare-Incentive Payment System (MIPS) made its way into industry lexicon as part of the Medicare Access & CHIP Reauthorization Act of 2015. It’s played a big role in quality improvement, but now it’s time to start paying attention to how it could impact your professional wallet.

According to Don Good, president of healthcare revenue cycle solutions company InContext, you’re set to see your cash flow drop over the next decade - and you should start to compensate for that loss now.

For example, he said, within the decade, your payment for an abdominal and pelvic CT scan will likely fall from $320 to approximately $165.

“You’re going to have to find a way to replace that revenue,” he said.

Monitoring and bolstering your performance under MIPS could be an effective way to safeguard any incentive payments you could receive to off-set lags in revenue. This year marks the first time CMS will collect MIPS data on cost. But, the information won’t impact your quality scores or potential incentives until 2019.

Expectations for quality performance will rise in 2019, though, he said, so getting yourself and your practice or department started on the right foot could save you headaches down the line. The better your MIPS scores, the more incentive monies you can anticipate bringing home.

So, to proactively maximize your scores, Good recommended several steps you should take.

1. Check your QRUR: CMS publishes the Quality and Resource Use Report as a way for you to see how you compare to your colleagues nationwide on quality and cost. Your performance helps determine your Medicare Part B fee-for-service payments. Being low cost/high quality is optimal.

For the most part, the comparison data is helpful, but, Good said, between 5% and 10% is inaccurate. CMS frequently records duplicated or incorrect information that can adversely affect your performance. Check your 2016 report to ensure accuracy, he said.

“Many organizations aren’t receiving incentives - and should be - due to incorrect data,” he said. “I encourage you, if you haven’t looked at your QRUR, call your practice administrator, and look at it.”

2. Review specialties: When determining incentives and penalties, CMS compares you to your peers. However, in some instances, CMS has erroneous data about the providers in your department or group, making a direct comparison impossible.

Check to ensure CMS has correctly identified each of your provider’s specialties. If interventional radiologists make up half of your provider base, CMS should not have them all labeled as diagnostic radiologists. This type of error could affect how your performance is judged, particularly when considering whether a provider is patient-facing or non-patient facing, Good said.

3. PQRS measures: In addition, check your Physician Quality Reporting Measures for 2016. If they’re inaccurate, contact CMS. Eventually, this data will appear on the Physician Compare website.

4. Cost measures: There are two cost measures you should monitor that CMS initiated under MIPS, Good said.

Total per capita: CMS assigns each Medicare beneficiary to a provider responsible for most patient services, usually a primary care provider. However, not every Medicare beneficiary sees a primary care provider annually. If a primary care physician doesn’t provide the majority of services to the patient, CMS will assign the beneficiaries tax ID number (TIN) to the provider that did render most evaluation and management services. That could be you, as a radiologist.

If you have 20 such patients attributed to you, you can be scored on this measure. 

Medicare spending per beneficiary: If you qualify to be scored on this measure, you’ll be held even more responsible for services for which you have little to no connection. If CMS attaches a patient’s TIN to you, the agency can retroactively review any services provided during the three days before a hospital admission to 30 days post-discharge, including any hospital readmissions.

Currently, having 35 such patients mandates you’ll be scored on this measure, and by 2019, your performance will count as 30% of your MIPS score.

If you get overwhelmed trying to navigate MIPS, he said, remember that, while it is a relatively new name in health care, the program itself isn’t all that unique. Roughly 85% of it has been culled for existing programs, and 15% is pulled from improvement activities, such as bolstered patient communication.

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