If pricing favors QCDR, then registry will usually be less attractive. However, price differences can be substantial. __Most importantly, do not assume value delivered by QCDR is automatically better!__ It depends on Measure Selection and Analytical Support services Choosing poorly could cost a lot more money, without appropriate return.

In 2021 there were 45 MIPS measures with a 7 point ceiling. For 2022 there are 47. That's not a lot considering an inventory of 480 MIPS measures. The biggest Quality score reduction in 2022 will come from elimination of Quality Bonus points - which happens for both QCDR and for Registry.

Sophisticated providers new to QCDR tend to retain some of their prior year Registry Measures, plus a couple new QCDR measures.

But since QCDRs generally do not charge a lower amount for Registry Measures (compared to QCDR Measures), you are often paying a much higher (QCDR) price for little (or even no) new content.

And remember - QCDR Measures are not a slam-dunk success.

QCDRs offer new, fresh measures. But not all new measures work out. Some get so little use that CMS can't even calculate a benchmark. And measures without a benchmark are only worth 3 points. *That's not worth paying for*.

It takes 20 provider groups for CMS to to benchmark a measure. So you should study critically - if a measure has been around for three or more years without a benchmark, you should contemplate - why have providers not embraced it? And what is the chance that will change this year?

**Of the 306 total QCDR measures, 130 have never been benchmarked, and will only earn 3 points **

Here's the best "gamble" on QCDR measures. CMS allows a * minimum *of 7 points for a brand-new measure, and 5 points for a measure in its second year.

If at least 20 provider groups chose a new measure, it could receive an unpublished "current year" benchmark, and might earn you up to 10 points, depending on your score. But you won't know this part until around 5 months after year-end (that's the gamble).

**Of the 306 total, there are 111 in this category.** *Creating new measures is where QCDR's really shine!*

QCDRs generally (but not always) do a good job of avoiding this problem. But popular measures tend to develop high scores over time. Thus, popular measures result in benchmarks that are severely constrained. In these cases, a perfect score will earn 10 points. But if you fall * one case below perfect*, your score skips two or more deciles - sometimes as low as 5 points.

**Of the 306 total, there are only 13 in this category. QCDR Measures do better here than Registry Measures. But still - select these only if you are confident of perfection. **

These are what you seek! They have a robust history of submissions and smoothly distributed benchmarks earning from 3 to 10 points.

And while these measures are more relevant to you, remember competition is providers from your specialty. To benefit, you must out-perform providers * in your specialty*!

**Of the 306 total, we come down to 53 in this category. Select these when you believe your practice out-performs your specialty peers. **

Even for a QCDR that has many proprietary measures, you will probably submit a combination of Registry and QCDR content. To provide a ROI, QCDR Measures must *replace *Registry Measures. Before contracting, estimate your performance for each QCDR Measure and its benchmark to estimate your new MIPS Quality Score.

Then, use your MIPS Quality score to estimate the resulting MIPS Financial Benefit (before and after QCDR Measures), and compare that * increase *to the incremental cost of QCDR.

*(Note that estimating financial benefit can be a challenge, but the MACRA Monitor team has tools that enable easy calculations ... even for those who are not yet our customers.)*

There is a common perception among physicians that MIPS wastes time by causing providers to document conditions and initiate protocols that are unnecessary to some patient situations. Sometimes this is true. But it is not really a direct result of the MIPS Program, and is largely avoidable.

MIPS is complex. And few practices can afford the time to fully understand all nuances. Naturally, MIPS * coordinators *tend to choose the easiest approach. And the easiest approach is often selecting a "standard" set of CQMs offered by your EHR, or your billing team's expertise. When those measures fail to parallel physician practice profiles, the workload falls on

Measure selection starts with matching up with the top set of protocols your physicians normally follow. It moves on to evaluating the benchmark and CMS scoring patterns of each protocol, then checks the cost of coding and system tracking, and ultimately winds up with determining other costs (such as QCDR fees).

A well-matched set of measures reduces physician burnout, while improving scores. With the dramatic increase in amount of money available to successful providers in 2022, this is the year to up your game with sophisticated selection and ongoing fine tuning of your MIPS measure set.

Did you know that the MACRA regulations have added thousands of pages of Federal Register content since the beginning of the program? Finding the right nuances can impact your Medicare Reimbursement. All QCDRs are experts on their own measures. But not all are experts on those thousands of pages of content you need to know. Before contracting, interview the concierge staff you will have. Ask them about regulations. Listen critically about their formal programs for education and analysis. Ask them to estimate much money you will make with their help. ** If they only answer in broad generalities and percentages, then how can they advise you on whether their service has an ROI to you? **

A good model offers a formal program starting with quarterly meetings to analyze your progress. Expect a concierge who can repare a detailed statement of your scores, the financial implications of your position, and recommendations on what might improve your result. With increasing competition, and increasing financial potential, make sure you are not going it alone.

If your existing Registry is doing a good job on four or five high-scoring measures, and a QCDR offers only one or two additional measures, wouldn't it be a better idea to pay the QCDR premium o* n only the extra they bring to the table*? Standard QCDR arrangements don't work this way. A QCDR wants all of your business - even where you already do well - and all of it at a higher rate. And they expect you to not know the difference.

What if you could find a high-touch registry offering Registry measures at a "commodity price" plus premium-priced measures from one (or more) QCDR , all as a single contract. That would be a level of sophistication could can profit from.

C3 Partners, LLC 414-640-2817 28717 Blue Crane Court, Waterford, WI

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