When Physicians Change Practices, Their MIPS Payment Adjustments Go With Them

Under MIPS, physician employers will be held accountable for their new recruits' past performances.

The Merit-Based Incentive Payment System (MIPS) is a new program that will impact Medicare payments to physicians. (It will also impact physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse anesthetists participating in Medicare Part B.) Under MIPS, eligible clinicians will submit data to CMS and be scored based on four performance categories: quality, resource use, clinical practice improvement activities, and advancing care information. A physician’s composite MIPS score will determine whether his/her Medicare payments will be positively or negatively adjusted in a future year.

MIPS Adjustments are Made on 2-Year Old Data

MIPS scores reflect physician performance over a full calendar year. The deadline for submitting data is March 31st of the following year. Payment adjustments do not take effect until January 1st of the second year. This means that a physician’s 2017 MIPS score will impact his/her 2019 Medicare payments.

Eligible Physicians Who Do Not Report Data in 2017 Will Have Negative Adjustments in 2019

Payment adjustments don’t start until 2019. However, 2017 is the first year to submit data. CMS has made the process a little easier by not requiring a full year of data be submitted for 2017. However, before March 31, 2018, eligible clinicians are required to submit at least 90 continuous days of 2017 data. Not participating in the program (i.e., not submitting any data) for the 2017 transition year will result in a negative 4% payment adjustment.

MIPS Scores Go with the Physician…And So Do the Payment Adjustments

Payment adjustments under MIPS will be applied at the individual National Provider Identifier (NPI) level. (The NPI is a unique identifier for an individual clinician and does not change.) In other words, MIPS scores follow the physician. For example, if an eligible physician works in Practice A during the 2017 performance period, and then starts work in Practice B in 2019, the physician’s 2017 MIPS score for Practice A will determine the payment adjustments the physician receives in 2019, while working at Practice B.

That said, an entity hiring a physician must accept payment adjustments based on the new hire’s performance at his/her previous job. While employers will benefit from hiring physicians who have qualified for positive adjustments, they will be hurt by physicians who have qualified for negative ones.

It Doesn’t Matter if the Physician was Measured as an Individual or as Part of a Group – Performance Still Follows the NPI

The MIPS program allows eligible clinicians to report data as an individual or as a group – and have their payments adjusted based on either their individual or group scores. It doesn’t matter if group or individual data were submitted, MIPS scores still follow the physician.

How Much Can MIPS Adjustments Hurt or Help?

Numerous factors will impact MIPS adjustments – so precise calculations are impossible. However, we do know that MIPS adjustments start at +4% (maximum positive) and -4% (maximum negative) in 2019. The potential adjustment grows each year, reaching +9% to -9% by 2022. Since annual Medicare payments are in the hundreds of thousands of dollars for many physicians, the impact of MIPS adjustments may be very significant.

Start Asking Physician Candidates About Their MIPS Data Now

Now that we are well into 2017, the time has come for physician employers to consider the impact that MIPS will have on their physician recruitment programs. Even though payment adjustments don’t start until 2019, employers need to start asking physician candidates about their MIPS submissions. If a candidate is not set to submit 2017 data, there will be a negative adjustment in the physician’s future.

It is also very important for employers to understand that, because Medicare payments will be adjusted at the NPI-level, they will be held accountable for their recruits’ past performances. Organizations need to be prepared to deal with departing physicians who take their adjustments with them, and they also need to be knowledgeable about, and prepared to deal with, the MIPS scores that new physicians bring to their organizations.

For more information on MIPS and the impact it will have on physicians who change practices, see Pages 77329-77332 of the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule. https://www.gpo.gov/fdsys/pkg/FR-2016-11-04/pdf/2016-25240.pdf

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