Otolaryngology Coding Alert

Save yourself the hassle (and money) by making sure your practice is compliant with current MIPS measures.

The Merit-Based Incentive Payment System (MIPS) is a new Medicare initiative that, among other things, attempts to assess the quality of care providers are offering to their patients. Quality of care is assessed through measures reported on five different domains:

• Clinical care,
• Safety,
• Care coordination,
• Patient and caregiver experience, and
• Population health and prevention.

How Does MIPS Compare to PQRS?

CMS is abandoning the Physician Quality Reporting System (PQRS) initiative as of 2017. In its place comes MIPS, which, on the surface, looks a lot like its predecessor. The two systems overlap and differ in a few fundamental ways.

Key Similarities:

1. Both assess quality of care through the utilization of nearly identical quality of care measures.
2. Both offer financial incentives for participating in the program.
3. Both penalize providers that don’t participate/meet requirements through negative payment adjustments.

Key Differences:

1. MIPS requires the selection of only six measures (PQRS required nine).
2. MIPS does not have a domain requirement.
3. MIPS relies on a scoring system rather than a pass/fail system.

Jennifer M. Connell, CPC, CENTC, CPCO, CPMA, CPPM, CPC-P, CPB, CPC-I, Owner of E2E Health Solutions in Victoria, Texas, further explains that “PQRS is one of four parts of the MIPS program. CMS took the three programs of PQRS, meaningful use, and value-based modifier program and combined them into one program. Clinical Practice Improvement Activities is a new set ofmeasures.”

If your practice has yet to make the transition, you’ve got until July 15, 2017, to meet the regular enrollment deadline for MIPS reporting in 2017. While making the adjustment from PQRS to MIPS might sound daunting, there are a few steps you can take to make the transition as seamless as possible. Connell outlines her proposed transitional process as the following:

• “Review the measures for each category and select the ones that are best for your practice. If you were already reporting PQRS measures successfully, the same or similar measures may be available.
• “Review office policies, procedures, and operations workflow to determine the best way to document and report the measures. For example, this may involve changing the patient intake forms so that the patients help you document more of the required data.
• “Educate your staff from the front desk to the physicians. To successfully meet MIPS measures requires complete staff buy-in, starting with the physicians and administration. Billers and coders will have a crucial role as they will perform the final documentation review and coding assignments prior to claim submission.
• “Review and monitor your progress. Review your numbers, documentation, and reports weekly to ensure each physician is successfully meeting the requirements of the measures selected. If not, reassess the selected measures, policies, and workflows. Provide education and training to correct any problems or deficiencies.”

One final tip involves scenarios of patient non-compliance. Very few practices are aware that patient non compliance can be documented with a specific ICD-10 code: Z91.1X (Patient noncompliance with medical treatment and regimen).

Providers can use reports from EMRs and practice management systems to monitor patient noncompliance and improve their existing processes. These reports may also be useful in appealing negative payment penalties.

With MIPS, instead of providing nine measures across three domains, Medicare requires six documented measures across any domain. Medicare requests that you report one outcome measure and one cross-cutting (multi-specialty) measure, which we’ve listed below.