Challenges continue for small and rural practices under MIPS, GAO report finds

The same challenges that made it difficult for small and rural practices to succeed in Medicare value-based incentive programs in the past are likely to continue under the incentive program known as MIPS, according to a new GAO report.

Small and rural practices will continue to face administrative, technological and financial challenges under the Merit-based Incentive Payment System (MIPS) that made it difficult for small and rural practices to succeed in Medicare value-based incentive programs.

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For the report, GAO investigators interviewed 23 stakeholders, including physicians and practice managers in small and rural practices, associations that represent physician practices, groups that have done research on Medicare payment incentive programs and CMS contractors that provide technical assistance to small and rural practices.

“According to the 23 stakeholders we interviewed, small and rural practices faced challenges in Medicare legacy payment incentive programs that are likely to continue under MIPS,” the report said. For instance, small practices may struggle to maintain and operate an electronic health records system and have enough staff time to track and report quality measures.

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In 2015, small physician practices with 15 or fewer providers, whether or not they were in rural areas, were more likely to receive a negative payment adjustment in Medicare payment incentive programs than were larger practices, the GAO said. Those programs included both the Physician Quality Reporting System and the Value-based Payment Modifier.

The Centers for Medicare & Medicaid Services (CMS), which implemented the MIPS program, has estimated that a higher percentage of larger practices will be successful in MIPS than small practices, but that small practices would be more successful in MIPS than they had been in those previous incentive programs.

CMS officials told the GAO they have responded to the worry about small and rural practices’ ability to succeed in MIPS and have actions underway to help address those challenges. For example, CMS has developed educational resources, contracted with organizations to provide technical assistance to practices and incorporated flexibility into MIPS, including allowing small practices to participate as a virtual group, where they share resources.

Whether those steps are successful in helping small and rural practices to succeed in MIPS and achieve a positive or neutral payment adjustment remains to be seen. However, CMS reports that 91% of all clinicians eligible under MIPS participated in the first year of the program, exceeding the agency’s goal for year one.