MIPS Challenges for Inpatient Clinicians in 2024

Quality will continue to be the most influential category in the MIPS scoring process for inpatient clinicians, accounting for 55% of their total MIPS scores. However, the scoring threshold to avoid penalties is scheduled to increase to 82 points – a hurdle that many inpatient clinicians may find hard to surmount.

And as the scoring threshold rises, scoring limitations within the available quality measures impose additional challenges for inpatient physicians. The Hospitalist Specialty Measures Set, which caters specifically to inpatient clinicians, contains only 4 measures. Unfortunately, 3 of these measures are capped at a maximum of 7 points each. This limitation means that even with perfect measure performance, the highest Quality score attainable for inpatient clinicians would be 42.6, significantly lower than the 55 points achievable by outpatient clinicians. When combined with maximum scores within the Cost and Improvement Activities categories, the highest final score an inpatient clinician could hope for is approximately 87.6 – dangerously close to the penalty threshold.

Moreover, among the Hospitalist Specialty Measures Set, two measures have a high likelihood of falling below the 20-patient volume threshold for individual clinicians. This could result in a score of 0 points for the measures, even if the physician maintained perfect performance on those measures. If an inpatient clinician failed to reach the low volume threshold on a single measure, that 0-point allocation would automatically make the 82-point penalty threshold impossible to reach.

Advocating for Change

Given these constraints, the question arises: How can inpatient physicians compete on equal terms with their outpatient counterparts, who have access to a wider array of measures without the imposition of 7-point scoring caps? As the penalty threshold continues to rise in subsequent years, the challenge for inpatient clinicians will only grow more daunting. It is crucial for every inpatient physician and practice administrator to express their concerns and advocate for a more equitable scoring system for inpatient clinicians.

The comment period for the Proposed Rule is open until September 11, 2023. You can submit your comments on the proposed rule via the CMS website: https://www.regulations.gov/commenton/CMS-2023-0121-1282. Constructive and well-reasoned comments tend to be more persuasive.

White completing the comment form, ensure you select the appropriate description of your industry role in the “What is your comment about?” field. For example, if you’re a clinician, you might choose options like ‘Physician’, ‘Nurse Practitioner’, and so on. If you’re an administrator, options like ‘Hospital’ may apply. Alternatively, if none of the available options accurately represent your role, you can opt for ‘Other’ from the list. This ensures your comment is categorized correctly.

Suggestions for Equitable Scoring

When providing feedback, it’s recommended to use your own words, as those comments carry more weight than form letters or copied messages. Highlight the issue that inpatient clinicians are restricted to a small set of available measures, while significant scoring hardships are inherent within those limited measures.

In a scenario where there are fewer than 6 measures available in a Specialty Measures Set, clinicians who successfully report all measures from that set should be exempt from the 7-point scoring caps and the 20-patient case count requirement. This would provide inpatient clinicians with the opportunity to compete fairly with their outpatient counterparts, based on their actual performance on the measures.

In Closing

Positive change within the MIPS scoring paradigm is unlikely without significant input from inpatient practices. While outpatient clinicians benefit from a broad selection of available measures, their inpatient counterparts face limitations that unfairly impact their scores and revenue. If this discriminatory scoring policy remains, legal recourse might be the only way for inpatient clinicians to level the playing field and safeguard their financial future.

Want to learn more about MIPS benefits, Consequences, and Financial Impacts? Check it out here.