June 25, 2024 | Net Health

7 min read

Navigating MIPS Compliance: Tips for Medicare Wound Care Providers

One of the many challenges wound care providers face is ensuring they remain compliant with the many regulations governing wound care today.

One of the most crucial of the compliance requirements, especially for providers caring for Medicare patients, is The Merit-Based Incentive Payment System (MIPS). MIPS reporting is due December 31, 2024. Because it is so complex–and crucial–it’s never too early to review the basics and ensure your reporting is accurate and timely. And if you’re in the middle of upgrading processes, or considering purchasing new wound care technologies, a primer is even more crucial. So here we go . . .

Do I Need to Participate in MIPS?

This is the key question before you read on, isn’t it?  MIPS is still relatively new in wound care.  Most providers in our world didn’t start fully reporting until 2023. Here are some questions to ask:

  • Are you a solo/individual wound care practitioner?
  • Do you practice wound care within a medical group, outpatient clinic, or ACO?

You should also participate in MIPS if you:

  • Bill more than $90,000 for Part B covered professional services in each 12-month segment.
  • See more than 200 Part B patients in each 12-month segment.
  • Provide 200 or more covered professional services to Part B patients in each 12-month segment.

MIPS, Medicare, and You

If you are or will soon participate in MIPS, here’s some additional information you should know. MIPS is a key payment model used by the US federal government for clinicians serving Medicare patients. Established by the Centers for Medicare and Medicaid Services (CMS) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), MIPS aims to enhance the quality and reduce the cost of Medicare healthcare delivery.

Medicare makes up a significant portion of many providers patient base.  According to a 2018 article in Value Health, nearly 15% of Medicare beneficiaries (8.2 million) had at least one type of wound or infection.  Healogics reports that approximately 70-80% of patients requiring wound care are covered by Medicare.

The goal of MIPS is to incentivize clinicians to improve performance in Medicare services, rewarding those who meet high standards with payment increases. Conversely, clinicians who fail to meet these standards face payment reductions. As part of the Quality Payment Program (QPP), MIPS encourages best practices and discourages wasteful, redundant healthcare activities.

By understanding and complying with MIPS, healthcare providers can ensure they deliver high-quality, cost-effective care to their Medicare patients while also benefiting from the program’s financial incentives.

Call-out – Net Health has developed an excellent overview of the crucial compliance requirement for outpatient providers – MIPS. You can view the full report here.

In light of the importance of MIPS and compliance in general, we’ve created a summary of the key MIPS regulations to take note of through the rest of 2024. Making note of these items now will help to ensure your end of year reporting goes smoothly and efficiently.

Promoting Interoperability

In 2022, MIPS included a measure aimed at Promoting Interoperability (PI). Objectives are four larger categories used to organize the general types of care that will be provided. Measures are smaller sections of an Objective that refer to specific documentation criteria. Your wound care electronic health record (EHR) provider should be able to support documentation for the reporting year for each of the following:

Health Information ExchangeSupport Electronic Referral Loops by Sending Health Information
Support Electronic Referral Loops by Receiving and Reconciling Health Information
Provider to Patient ExchangeProvide Patients Electronic Access to Their Health Information
Public Health and Clinical Data ExchangeReport the following:
1. Immunization Registry Reporting 2. Electronic Case Reporting
Option to report one of the following for bonus points: 1. Public Health Registry Reporting 2. Clinical Data Registry Reporting 3. Syndromic Surveillance Reporting

You can find additional details and references at the Net Health website here.

Outpatient Physician eCQM Measures

The Outpatient Physician eCQMs are a subset of the MIPS Quality Measures that support services provided within an outpatient setting. According to CMS, “Electronic clinical quality measures (eCQM) are specified in a standard electronic format that use data electronically extracted from electronic health records (EHR) and/or health information technology (IT) systems to measure the quality of health care provided.”

A few items are measured under this field.

  • Closing the Referral Loop: Receipt of Specialist Report
  • Documentation of Current Medication in the Medical Record
  • Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%)

While some of the general MIPS measurement lists may seem irrelevant to wound care, several are essential to optimal outcomes. For example, preventive care and screening for tobacco use is an eCQM. Its relevance for wound care providers is that ensuring that patients are not using tobacco can lead to better outcomes, faster healing times, and fewer complications. Providers can help through screening, education, and counseling resources for their patients with chronic wounds.

Traveling Physician MIPS CQM for the 2024 Performance Year

Traveling wound care providers—like those that visit Skilled Nursing or Long-Term Care facilities—must ensure they comply with MIPS CQM, another subset of the MIPS Quality Measures.

If you provide wound care outside of a hospital and participate in MIPS, you will need to report your Quality Measure data through the Registry Export file provided by your EHR vendor.

Diabetes, preventive care, reporting on social drivers of health, connections to community service providers, and elder maltreatment are important criteria for this measurement.

Visit Quality Measures Report for more information.

Medicare Access and CHIP Reauthorization Act (MACRA) – 2024 Edition

Wound care providers have been working under The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) since 2016.

There are two paths for participation in the CMS QPP:

  1. Alternative Payment Model (APM). The APM approach rewards those who provide high-quality and cost-efficient care with added incentive payments. APMs can apply to a specific clinical condition, a care episode, or a population. By participating in this track, practices can earn more for taking on more risk for a patient’s outcome. Different criteria are required of providers who choose to enroll in an APM.  Note that not all EHRs support APM.  Indeed, many providers choose not to participate in APM because it is complex and requires significant changes to practice operations and extensive documentation.
  2. MIPS – which we mentioned earlier. Note that clinicians participating in MIPS can earn a positive, neutral, or negative performance-based payment adjustment for their Medicare claims.

Hardship exemptions may be available for Promoting Interoperability and Extreme and Uncontrollable Circumstances.  Review the Quality Payment Program website here for more information. 

Both of these paths are crucial areas for providers to explore. MACRA changes how Medicare pays clinicians who provide care to Medicare beneficiaries to provide the best possible care while reducing costs. These changes create a Quality Payment Program (QPP), ending the Sustainable Growth Rate (SGR) formula for determining Medicare payments for health care providers’ services.

Research which model is most suitable for your organization carefully and reach out to experts and consultants to ensure you make the right choice for you and your organization.

Improving and Streamlining MIPS Reporting

If all this seems overwhelming, don’t worry. It doesn’t have to be. Working with an advanced specialty EHR and a partner committed to your success are important steps. For example, make sure your vendor is focused on workflow and is fully certified for interoperability and data sharing as outlined by the CURES ACT.

In this day and age, remember to check about security features offered and what can and will be done if there is a breach. Important security features for wound care platforms include:

  • Strict HIPAA compliance.
  • Highly restrictive data access to pre-authorized users.
  • End-to-end data encryption.

There are multiple other essential features to consider, but remember that software that helps you identify problems—especially those crucial for MIPS—and key performance indicators. EHRs that offer easy-to-use dashboards and robust reporting are crucial for MIPS and will help your practice efficiently manage all reporting requirements.

We’ve Got Six Months

As of June, it is a mere six months from the MIPS reporting deadline. Take the steps needed now to ensure your practice and you comply with the latest MIPS compliance guidelines and simplify and streamline the process for you and your team.

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