The Price and Cost of MIPS Submission

How do you compete with free? - was a challenging question posed to me by one of our partners recently. She had just met with a large practice. The practice had successfully completed their MIPS submission for 2017 using the CMS portal. However, that practice encountered many challenges during the process and wanted to be better prepared for 2018. The practice had found MyMipsScore while researching options. They reached out to our partner for a live demo and were very impressed with the features. Finally, the practice administrator asked the tough question – How much will it cost as compared to the “Free” option of submitting MIPS data directly to CMS?  

The price of submitting MIPS data is not same as the "cost" of submitting MIPS data. It is important to understand the difference. Read more...

I am often asked how does MyMipsScore differ from the many “submission” options available in the market. A demo of our solution usually answers that question satisfactorily. But how do you compare yourself with a free option provided by the government? I am going to address that elephant in the room today.

Difference Between Price And Cost  

I will start with a simple question: Do you know the difference between Price and Cost? 

The Price of submitting your data with CMS is zero. There is no catch in that. We worked with a lot of providers in 2017 to submit their data to CMS using our free app. It is true that many providers had issues related to their EIDM accounts, but CMS did an amazing job of resolving all the issues timely. I am not aware of any providers who didn’t get it resolved before the extended submission deadline. This was the first submission year and I am pretty sure that CMS will have it all streamlined for 2018.

However, MIPS is not only about submitting the data. Most providers still don’t understand the paradigm shift from “pay for reporting” to “pay for performance” that is happening under value based care. I feel that CMS’s campaign of “pick your pace” was really misleading. Many providers wouldn’t realize the cost of the pace they picked in 2017 till later this year when MIPS score become public on the Physician Compare website.

Submission” of MIPS data is similar to filling your tax return. You can use a submission software available in the market or you can file the taxes directly with the government for free.

“Submission” of MIPS data is similar to filling your tax return. You can use a submission software available in the market, or you can file the taxes directly with the government for free. Many people do not worry about their taxes till January and it might be okay for their situation. For others, it is important to plan throughout the year.

Just like the taxes, the planning (or lack of it) throughout the year for MIPS could depend on various factors that would ultimately determine what it costs you, irrespective of how you submit the data.

Total Cost of MIPS Submission = Price of Submission + Cost of Missed Payment Adjustment + Cost of Online Reputation + Cost of Time

Determining the Cost of MIPS Submission 

There are 3 key factors that you should take into consideration to determine the true cost of MIPS submission for you. These will also help you determine if you could/should wait till January or need to start planning now.

  1. Your Medicare Part B Payments: It is very important to understand that the payment adjustments under MIPS are based on your actual score, not just on the act of submitting data like in previous programs. Your estimated Medicare Part B payments for 2020 will determine the direct financial impact of MIPS for you. You can use a MIPS Calculator to estimate the payment adjustments for your practice.

  2. Your Online Reputation: CMS will publish MIPS scores of every Eligible Clinician to a public website such as Physician Compare for everyone to see. The reputation impact of MIPS could potentially be a lot more than the direct impact on payment adjustments.

  3. Cost of Your Time: The above two factors can help you determine if you can afford the cost of waiting till January 2019, or you need to plan to manage MIPS data throughout the year. If the stakes are high for you, you need to make sure you understand the nuances of MIPS scoring to make sure you get the highest possible score.Just like the taxes, you can plan to do this yourself or can hire someone to do it. MIPS scoring is complicated but it is based on a set of well-defined rules which are clearly documented on CMS website. You can read our concise 10 step MIPS guide to quickly familiarize yourself with different aspects of MIPS 2018 and dig deeper into any of the topics by visiting our MIPS Learning Center. The decision you make really depends on the cost of doing it yourself versus hiring someone.

So, back to the question where we started - How do we compete with free MIPS submission? We don’t. We are a CMS Qualified Registry but we are not in the MIPS submission business. If you are an EHR vendor or a professional association, contact us to learn how you can offer unlimited submissions to all your users through MyMipsScore. If you are provider and interested in submitting your MIPS data to CMS for free, stay tuned for our free app at the end of year. If you want more than just submission, check out our partners who can not only help you with MIPS submission, but can also help you maximize your MIPS score and the payment adjustment.

We don't do price match for submissions. However, if you really understand the true costs of MIPS, we can do a cost match for you. Our goal at MyMipsScore is to help providers understand and excel under value based care programs. We do this through a set of tools and guidance throughout the year.