The Medicare Merit-Based Incentive Payment System (MIPS) is complex and requires physicians and practices to consider many options. This guest blog post from the American Society for Radiation Oncology (ASTRO) describes resources to help demystify MIPS for radiation oncology practices.
As part of the Centers for Medicare & Medicaid Services (CMS) Quality Payment Program (QPP), the Merit-based Incentive Payment System (MIPS) was created to reform Medicare payments while improving care and reducing costs across the entire healthcare delivery system. Started in 2017, MIPS consolidated Medicare legacy programs—including the Physicians Quality Reporting System, Value-based Modifier, and Meaningful Use—while adding a new Improvement Activities (IA) category, rolling these into one comprehensive program. CMS is implementing the transition to payment through MIPS in phases.
For 2018, MIPS-participating eligible clinicians' performance in four categories will impact their 2020 Medicare Part B reimbursement—from a negative 5 percent to a positive payment adjustment. Note that the overall payment adjustment for eligible clinicians participating in MIPS is determined by a Composite Performance Score (CPS), ranging from 0 to 100.
So not only is MIPS complex, but the program is evolving. For 2019, CMS introduced some significant MIPS updates, including:
- An overhaul of the Promoting Interoperability performance category including new measures and scoring,
- A requirement for all practices to use 2015 Certified EHR Technology (ARIA® v15.5, MOSAIQ® v2.7 and up),
- An opportunity for facility-based scoring, replacing the Quality and Cost MIPS requirements, for practices that are designated as hospital-based and have at least one service billed in the inpatient or emergency room, and
- The ability to utilize more than one mechanism to collect and report quality measures.
Scaling the Learning Curve
For radiation oncology clinicians and practices participating in MIPS, the American Society for Radiation Oncology (ASTRO) has robust educational resources to help stay up-to-date on MIPS, whether your goal is to avoid the penalty (negative payment adjustment) or to aim for a large positive adjustment. Visit the ASTRO website for comprehensive information and tools to determine eligibility, reporting options, and more, including a MIPS for Radiation Oncology 2019 video. You’ll also find the following ASTRO tools for success in MIPS:
- The QOPI Reporting Registry brought to you by ASTRO and the American Society of Clinical Oncology (ASCO). This data capture and reporting tool for MIPS can help drive quality improvement without added burden to your program or practice. A Qualified Clinical Data Registry, the QOPI Reporting Registry enables practices to aggregate data, sometimes from multiple EHRs; monitor performance over time; compare to benchmark data; and identify areas for improvement—all while satisfying federal reporting requirements. For 2019, the QOPI Reporting Registry has 34 measures to choose from including general medicine, medical oncology, and radiation oncology. Of these measures, 23 are reportable by radiation oncology practices.
The registry platform is EHR-agnostic and is currently used by practices with ARIA® and MOSAIQ® Radiation Oncology EHRs. With multiple data capture options, including electronic and manual data entry, the QOPI Reporting Registry can be used by all practices for MIPS reporting. ASTRO recommends using the system integrated electronic data capture method, if possible, to relieve data collection burden on practices. Learn more about the QOPI Reporting Registry here.
In 2019, individuals or groups need to attain at least 30 CPS points in order to avoid a 7 percent penalty in 2021. This year, practices must participate in multiple performance categories to avoid the penalty, and Improvement Activities have the ability to be the most meaningful for practice transformation. This category gauges participation in activities that improve clinical practice, such as on-going care coordination, shared decision-making, and patient safety practices. Clinicians can select from 118 improvement activities, designated by CMS as a medium- or high-weighted activity. Depending on a practice’s location and size and the activity weight, clinicians will need to attest to completing 1 to 4 activities for full credit. Two ASTRO programs can help radiation oncology clinicians meet the IA performance category requirements.
- RO-ILS: Radiation Oncology Incident Learning System® (RO-ILS) is a part of Clarity PSO, a federally listed patient safety organization (PSO). RO-ILS can fulfill the “Participation in an AHRQ-listed patient safety organization (PSO)” medium-weighted improvement activity. RO-ILS can also be used towards fulfilling the Part IV Physician Quality Improvement (PQI) Maintenance of Certification (MOC) requirements established by the American Board of Radiology (ABR). This meets an additional medium-weighted improvement activity. There is no fee to participate in RO-ILS, but the practice must contract with Clarity PSO.
Participating in RO-ILS brings benefits beyond MIPS. Through RO-ILS, users can track and review their own radiation oncology internal events including incidents, near misses, and unsafe conditions. The online, secure RO-ILS portal easy to access and consists of two sections. The front-end form includes less than 10 questions and allows for quick data input. Any member of the radiation oncology treatment team (radiation oncologists, medical physicists, dosimetrists, nurses, technologists, and practice administrators) can use RO-ILS to report an event to internal staff. This transparency reinforces that all members of the team are responsible for patient safety and quality care. Staff have the option to anonymously report an event which can help build a culture of safety within a practice. The second section of the portal allows designated advanced users, called “reviewers,” to enter follow-up analysis for an event and report the data to the patient safety organization. Reviewers also have access to the Analysis Wizard to identify trends in their data.
Clarity PSO, with the help of the Radiation Oncology Healthcare Advisory Council (RO-HAC), analyzes, interprets, and reports anonymous data on national data submitted into RO-ILS. RO-HAC is comprised of a multidisciplinary group of radiation oncology professionals with expertise in patient safety. RO-HAC develops regular aggregate reports that include case studies, graphs, and suggestions on how to prevent errors. Aside from these practice-specific benefits, RO-ILS users contribute to a national database and collectively improve the field of radiation oncology. Learn more. - The ASTRO Accreditation Program for Excellence (APEx®) requires a practice to focus on a culture of quality and safety, as well as patient-centered care. Evidence indicators form the compliance component required to achieve APEx accreditation. These currently map to 15 improvement activities. Completion of the APEx PQI template fulfills the Part IV MOC requirements established by the ABR. Aside from the MIPS benefits, APEx fulfills the radiation therapy component for the American College of Surgeons Commission on Cancer and NPABC accreditation programs. Any radiation oncology practice based in the U.S. may apply for APEx accreditation. Practices may be a single facility applicant or a multi-facility network.
Moving Beyond MIPS: What Lies Ahead?
With the transition to value-based care picking up speed, radiation oncology practices and programs need to explore strategic approaches that support innovation and viability. On March 20, the Association of Community Cancer Centers is offering a one-day Radiation Oncology Pre-Conference to the ACCC 45thAnnual Meeting and Cancer Center Business Summit, in Washington, D.C., where ASTRO Director of Health Policy Anne Hubbard, MBA, will be discussing new payment models, mandated bundles, and policy and regulatory shifts likely to impact radiation oncology; plus participants will hear clinical and economic perspectives on breakthrough treatments, practical strategies for streamlining pre-authorization processes, and much more. View the Radiation Oncology Pre-Conference Agenda. Attend and prepare for what lies beyond MIPS.
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Guest blogger Randi Kudner is Senior Quality Improvement Manager with the American Society for Radiation Oncology (ASTRO).
