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Health Affairs article suggests CMS may need to support small practices more for MIPs

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The Centers for Medicare & Medicaid Services (CMS), in its zeal to reinforce the need for value-based care among all healthcare providers, may be slighting smaller independent practices, according to an article published in Health Affairs earlier this year. Performance data from CMS’s Merit-based Incentive Payment System (MIPS) shows that “small practices performed considerably worse in terms of Composite Performance Score (CPS) and financial penalties compared to their large practice counterparts.”

Health Affairs suggests a number of ways in which CMS can be more supportive of the many small practices participating in MIPS, so that all can be more profitable and more successful.

Medicare could implement additional incentives for quality reporting. Small, independent practices may not have the resources available to them for “information technology and other support systems to facilitate automatic reporting, perform manual reporting, or achieve the MIPS end-to-end quality reporting bonus.” As a result, they often are not able to adhere to CMS reporting requirements that are necessary to earn the bonus. Health Affairs suggests that possible solutions could include “scoring adjustments that apply only to small practices, such as a higher end-to-end reporting bonus amount (for small practices only) or increasing the bonus points per measure (i.e., earning more points for fewer measures reported for small practices only).”

CMS could modify MIPS rules to reduce quality reporting burden for small practices. Simplifying or reducing the 50 potential measures for independent physicians to report would significantly reduce the reporting burden on those smaller practices. In fact, “CMS has set a precedent in the Improvement Activities domain, where small practices receive double weighting for reporting relevant activities.”

CMS could also adapt approaches from other payment models to provide small practices with resources necessary to meet MIPS goals related to quality reporting or care redesign. Other models, including the Accountable Care Organization (ACO) Investment Model and the Comprehensive Primary Care Plus (CPC+) model offer alternatives for financial strategies and incentives.

Finally, the article suggests, “new fee-for-service billing codes implemented through the Physician Fee Schedule could be encouraged, or their use could even be incentivized as part of quality measures, among small practices in MIPS to offset costs from initial investments required to deliver care coordination services, improve quality, and/or contain costs.”