After the 2020 election, we predicted seven trends to expect in Value-Based Care. Our forecasts were right on track. Last week the Biden Administration released its first Physician Fee Schedule and Quality Payment Program Proposed Rule, a 1,747-page document that promotes restructured value-based care initiatives. As we predicted, it recognizes both a significant health equity […]
The Real Registry Advantage for ACOs Reporting Via APP: 5 Myths Debunked
The clock is winding down on the CMS Web Interface, and the reality of mandatory quality reporting via the Alternate Payment Model Performance Pathway (APP) for ACOs in 2022 is setting in. In order for ACOs to develop and execute their APP quality reporting plan in time to avoid catastrophe, it’s imperative to begin evaluating […]
The 2021 QPP Final Rule: A Warning Bell for ACOs and a Wake-Up Call for MIPS Participants
In a mere 2,165 pages, CMS has solidified the provisions of the 2021 Physician Fee Schedule and Quality Payment Program (QPP) Final Rule. The Final Rule strongly resembles the Proposed Rule, and the implications, particularly for ACOs, are staggering. Medicare Shared Savings Program Accountable Care Organizations (MSSP ACOs) and the Alternate Payment Model (APP) Pathway […]
“Push-Pull” for Providers in Medicare’s Proposed 2021 Rule for Physician Fees and Quality Reporting
The newly published 2021 CMS Physician Fee Schedule and Quality Payment Program (QPP) Proposed Rule reflects our harsh reality: Operate under the constraints of the COVID-19 pandemic, while moving toward uniformity and Risk. That tension is palpable in the Proposed Rule’s “push-pull” of CMS trying to continue to advance a Value agenda while stuck in […]
The Fallacy of “Relief”: The Dangers of MIPS Extreme and Uncontrollable Circumstances Applications
Under the banner of “relief,” CMS has announced that clinicians will have the opportunity to file an Extreme and Uncontrollable Circumstances application to qualify for re-weighting in some or all components of the Merit-Based Incentive Payment System (MIPS). This possibility may sound intriguing, but don’t be fooled—those who take this route are overlooking the longer-term […]
The Interim ACO Rule Explained: A Pause, Not a Reprieve
As the coronavirus pandemic continues to upend health care in the U.S., pressure has mounted on CMS to adjust its efforts to drive providers to adopt risk. In response, at the end of last week CMS announced a carve-out of COVID-19 patient expenses from certain reporting requirements. In this round, ACOs were on the receiving […]
The Final 2020 Quality Payment Rule: Playing It Safe with MIPS No Longer Works
The common refrain within the 2475-page Medicare Final Rule for the Physician Fee Schedule and Updates for the Quality Payment Program (QPP) is “we are finalizing our policy as proposed.” This Rule follows the formula CMS adopted in its “Pathways to Success” ACO Rule: Propose a shake-up, reply to concerned commenters, and finalize policy without significant […]
A MIPS Rewrite is Certain: CMS Proposed Rule for the 2020 Quality Payment Program
The CMS Proposed Rule for the 2020 Physician Fee Schedule and changes to the Quality Payment Program picks up where the “Pathways to Success” ACO rule left off. This time, the “Pathways” shake-up is aimed squarely at MIPS, in the form of “MIPS Value Pathways.” We’ve described the growing frustration with MIPS, specifically MedPAC’s report […]
Pathways to Success: How CMS is Encouraging ACO Participation Despite Impending Financial Risk
CMS closed 2018 with a farewell to upside-only ACOs. Perhaps the biggest surprise in the “Pathways to Success” Final ACO Rule is its consistency with the Proposed Rule, which floated the revamped ACO Track back in August. Citing superior performance among two-sided participants, as well as the belief that upside-only tracks reduce patient choice and […]
The Final 2019 Quality Payment Program Rule: A Slow (but Steady) Push to Risk
Brew a pot of coffee! CMS has released a 2,378-page Final Rule covering the 2019 performance year for the Quality Payment Program, including the Merit-Based Incentive Payment System (MIPS). Those who dive into this document will gain insight into CMS’s vision for the future. It seems tortuous to suggest “reading between the lines” when there’s already […]