MIPS ACOs could be sending money from North to South

Regulations sometimes result in Unexpected Consequences. Here's one.

First, recall two key background facts:

MIPS Creates Competition. Your MIPS reimbursement depends on how you score against a broad peer group (i.e., All ACOs are compared against each other, and high scoring ACOs get the money that low scoring ACOs pay in penalties).

Quality is the biggest differentiator. Your score on Quality contributes at least as much to your overall MIPS Score, as all other measures combined. In fact, it is likely be be more impactful than its 50% weighting factor implies. See our blog entry here for an explanation.

Here is the scenario under which MIPS money moves from Winter climates to Summer Climates. It starts with the rules under which ACOs submit their Quality Measures, using CMS Web Interface. This method (required for ACOs), always uses the first 284 Medicare patient encounters of the year. Let's assume those patient visits occur in January and February.

If you live in Florida, or Arizona you know about a phenomenon that happens around January (give or take a month) of each year. Affluent and healthy retirees (Medicare Recipients, all) go south for the winter, leaving a sort of "adverse selection" behind of those who are too ill or less affluent.

So think about the impact on CQM scores. Providers in Winter climates have their healthiest patients pulled from the population. Their CQM scores are likely to be lower in January and February than later in the year. With lower CQM scores, come lower MIPS scores ... and reduced MIPS Adjustments.

Interesting, isn't it? I would like to credit this observation to Nancy Schlichting, CEO of Henry Ford Medical Systems in a letter she posted to CMS commenting on the MIPS Proposed Rule. Thank you, Ms. Schlichting.

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