Although not identified in Slavitt’s blog post, there is also an Option 5: a clinician may elect not to report any data for 2017. Clinicians selecting this option will be subject to the maximum 4 percent penalty in 2019 and will be assigned a low MIPS composite performance score. (The score will be more than zero, as some components are calculated by CMS using claims data.) That score will be reported publicly on the Physician Compare website.
What should you choose to do? – Familiarize yourself with MIPS
Until the details surrounding Options 1 and 2 are presented in the final rule, a clinician cannot make an informed decision regarding the best alternative in his or her circumstances. The one option a clinician should eliminate now, however, is Option 5, given the negative reputational impact of a low composite performance score as well as the financial penalty.
To that end, clinicians should be familiarizing themselves with the MIPS program, especially the quality reporting requirements. Just as a practice must have the capability to submit claims electronically to payers, a practice also must develop the capability to compile and submit quality data in order to receive full payment. Slavitt’s announcement of a temporary, partial easing of the MIPS requirements only confirms this fact.