Payment & Delivery Models

Employed by a hospital? Yes, MIPS matters for you too

Hospital-employed physicians may think that Medicare’s new performance-based payment system, the Quality Payment Program (QPP), is only a concern for their colleagues in other practice settings. The AMA’s new comprehensive guide offers advice on how to best cope with a new system that may have a significant effect on their income and working arrangements.

The set of deep dive frequently-asked questions (FAQ) addresses the much-needed push to get physicians, regardless of practice setting, fully up to speed with the QPP requirements and other provisions of the Medicare Access and CHIP Reauthorization Act (MACRA).

The guide is intended only for physicians employed by hospitals—not for those in hospital-affiliated practices or other settings. It consists of 35 detailed questions and answers, grouped into eight sections  addressing topics such as compensation-related implications and EHR usage, among others.

The document makes a strong case that hospital-employed physicians are best served by being actively engaged in selecting and pursuing the employed practice arrangements that protect them and provide the best possibilities for their success. At the outset, the FAQ tells physicians that they should assume the QPP probably will affect them and why.

“Clinicians should expect that MACRA’s positive or negative payment adjustments will eventually impact the hospital’s financial position and the methods it uses to pay its employed physicians,” the FAQ says. “MACRA’s requirements apply to all eligible clinicians, regardless of practice setting, so its requirements can’t be avoided by hospital employment alone.”

How that might play out and how physicians can protect themselves is the major focus of the FAQ. In many cases, the hospital, as employer, will want to make the key decisions—for example, whether to measure performance at the group or individual-level—and the question turns to whether to modify that through employment contract and payment provisions.

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The FAQ encourages physicians to embrace an active role. That includes “ensuring that employed physicians have access to and use [certified electronic health record technology], promoting employed physician engagement in selecting and reporting on MIPS quality and improvement activity category measures, and encouraging peers in the physician enterprise to do their part in connection with individual or group measures.”

Today’s pay will affect tomorrow’s

 “Individual reporting has potential benefits in that you can select and report quality measures and other variables that are aligned with your practice,” according to the FAQ. “Under group reporting, all eligible clinicians in your employer [tax identification number] will be evaluated as a group.”

It’s important for physicians to know how they are paid now so they can follow and understand changes that may come about under MIPS. Moving forward, it is also crucial that physicians get reports and feedback on their performance, especially since it may change their compensation.

Just what that affect might be will vary by a physician’s employment and compensation structure. Relative value unit-based compensation plans traditionally have not been tied to overall revenue a hospital collects for those services. But as the FAQ warns, “While this may be beneficial today, it’s likely that hospitals and other physician employers using such models will seek to modify the arrangements over time as the financial implications of MACRA, MIPS and APM performance take effect.”

It is very likely that physicians with compensation tied to revenue from their services—for example, through percentage of collections or revenue-minus-expense models—will see their compensation change.

The full FAQ covers these and many other topics, including:

  • Private practice comparisons.
  • Impact on structure and relationships.
  • MIPS requirements.
  • Compensation-related implications.
  • Effect on electronic health records and usage.
  • Alternative Payment Model participation (including accountable care organizations).
  • Implications for other arrangements (for example, a medical director relationship with a hospital).

The FAQ is a supplement to the MIPS Action Plan, one of a number of AMA resources created to help physicians to have a successful transition to the new Medicare payment model.

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