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What measures are you taking to prepare for MIPS?
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Disconnect may be the norm
I wish I could provide an intelligent response to this question. My office manager has been busily educating herself regarding the requirements and (hopefully) getting prepared to implement the required procedural infrastructure. That being said, my level of involvement in the process remains at this superficial level, at least for now. Hopefully, my confidence in my administrative staff to “get it right” will be well founded, or we will be in for a bit of a rude awakening.
As an aside, I suspect that my level of disconnect with the process — leaving it to the administrative staff to sort out — is more the norm rather than the exception. As the complexities of the regulations and reporting requirements increase exponentially (despite government attempts to “simplify” the process), it is becoming increasingly difficult for a busy practitioner to manage that process on top of a busy practice. For better or worse, we have to depend more and more on our administrative and support staff, as well as technology (for example, EMR software) to help us keep up.
Jodi Luchs, MD, FACS, is an associate clinical professor of ophthalmology at Hofstra Northwell School of Medicine. Disclosure: Luchs reports no relevant financial disclosures.
Facing changes head on
My first reaction to the new Merit-based Incentive Payment System (MIPS) was to scream and run as fast and far as I can. As I did with all the new CMS rulings, I paused, breathed deep and decided to face the changes head-on rather than let the changes overwhelm me. I have a small three-provider practice but embraced electronic health records early in 2009. The most important thing that I did was find the person in my office, the implementation officer (IO), who was most capable of figuring out the maze of Physician Quality Reporting System (PQRS) and Meaningful Use (MU) requirements. The IO is responsible for keeping up-to-date on any changes coming down the pipeline, implementing the changes and ensuring that the practice is prepared well in advance of the deadlines. As the years passed and the changes came at us almost quarterly, we partnered with our EHR vendor and relied on it to ensure that our EHR was certified and up-to-date with PQRS and MU reporting. It provided us with online education for our entire staff. The importance of a scribe in the new era of EHR and quality reporting cannot be underscored enough. Physicians struggle to keep up with all the requirements and documentation, while trying not to compromise patient care. A scribe can work with the IO, the EHR vendor and the physician to ensure that all existing and new documentation requirements are met.
There are four parts to MIPS: quality performance standards, advancing care information, clinical improvement activities and resource use. For those of us who are using EHR and have been busy reporting PQRS and MU, the transition will be much simpler. Essentially the first two parts of MIPS will replace PQRS and MU, respectively. My IO has, over the past several years, been in regular communication with our EHR vendor and partnered with Mingle Analytics to facilitate our PQRS reporting. She receives emails and webinar invitations monthly. More recently we have changed to the IRIS Registry, through the American Academy of Ophthalmology, for PQRS reporting. I feel comfortable that we will transition through the quality performance standards and advancing care information comfortably. Resource use is the one section that will not require physician reporting. The newest component to our practice will involve clinical practice improvement activities. The requirements for this category are relatively broad and flexible. They include activities that we already perform in our office and will likely require a change in how we report them. Our hope is to receive a bonus in 2019 by being organized, planning ahead and starting early.
Lisa K. Feulner, MD, PhD, is an ophthalmologist, surgeon and owner of Advanced Eye Care in Bel Air, Maryland. Disclosure: Feulner reports no relevant financial disclosures.