Future of Health CareMerit-Based Incentive Payment System (MIPS)Quality Payment ProgramRiskValue-Based Health Care
November 7, 2018

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 so much laid out in black-and-white, but recognizing the context within the rule enables you to prepare for the future—spelled R-I-S-K. The Final Rule is very close to what was proposed back in July and has been similarly justified—CMS continues to cite Meaningful Measures, Patients…
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Alternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Qualified Clinical Data Registry ReportingValue-Based Health Care
July 25, 2018

The Proposed 2019 Quality Payment Program (QPP) Rule: What You May Have Missed

Whoever said bureaucracy doesn’t foster change did not anticipate CMS’s Proposed Rule for the Quality Payment Program (QPP), 2019 performance year version, released on July 12. While the familiar overarching structure of MIPS remains, there are a number of revisions that activate newly developed policies. These include “Patients Over Paperwork” and “Meaningful Measures” efforts that CMS initiated in 2018 to streamline the requirements-heavy MIPS program. To be honest, there are some rough patches within the wrangling of old and new MIPS provisions in the 1,473 page 2019 Medicare Physician Schedule Proposed Rule, set to be published in the Federal Register…
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ACOsClinical Data RegistryMerit-Based Incentive Payment System (MIPS)Performance ImprovementValue-Based Health Care
July 18, 2018

No More MIPS Cost Score Details? 5 Ways Providers Can Still Take Control of Costs

CMS is urging providers to participate in ACOs with downside risk, but they might be eliminating one of the keys that providers need to prepare. It couldn’t come at a worse time, when providers already stand to lose under risk-based models if they can’t identify where their cost issues lie. That data is only available from claims data made available by payers. Up until now, practices have had access to indispensable data on costs that are attributed to their providers, showing specifics of where they are above the norm. These were previously part of Quality and Resource Use Reports (QRURs)…
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ACOsAdvanced Alternative Payment ModelsAlternative Payment Models (APM)MedicareMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
June 13, 2018

Medicare Paths to Value-Based Health Care: Which Way is Up?

If you’re scratching your head about the direction of Value-Based Health Care (VBHC) in Medicare, you’re not alone. The current mix includes a swirl of separate initiatives, some new and others recently re-labled. As CMS pushes toward VBHC, providers may feel confused and frustrated as concepts emerge that will affect multiple programs. Within the last several months, the Patients Over Paperwork and Meaningful Measures initiatives have shaken up CMS value-based care programs, particularly: Merit-Based Incentive Payment System (MIPS) Medicare Shared Savings Program ACOs (MSSP ACOs) Direct Provider Contracting (DPC) Even more confounding, CMS is taking a non-linear development path for…
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Future of Health CareMACRAMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
March 7, 2018

Who Wins and Loses If CMS Kills MIPS?

Last month, the new Health and Human Services (HHS) Administrator, Alex Azar, tolled the death knell on MACRA MIPS quality reporting. Even as the MIPS program just began its second year, Azar reinforced what MedPAC (Medicare Payment Advisory Commission) has been suggesting since June 2017: trash MIPS quality reporting and speed up provider transition to APMs (Alternative Payment Models). MedPAC is so eager to engineer this that it recently suggested even more incentives to help physicians make the switch. If you believe the hype, both providers and patients will win if MIPS is eliminated or vastly rewritten. Certainly, the notion…
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Merit-Based Incentive Payment System (MIPS)Performance ImprovementQualified Clinical Data Registry ReportingValue-Based Health Care
November 29, 2017

Convention Lesson: MIPS Improvement Activities Are Woefully Misunderstood

With only a month left of 2017, practices should be wrapping up their Improvement Activities. MIPS requires at least 90 consecutive days of participation in order for a group or clinician to attest that an Improvement Activity is complete—meaning that the last day to start was October 2. The Improvement Activity portion of MIPS is the only component that is not a direct descendant of a previous program, increasing the challenge of implementation. Recently, we attended a national conference for those in healthcare practice and administration; one of our goals was to learn more about how practices were adapting to…
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Alternative Payment Models (APM)MACRAMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
November 8, 2017

The 2018 Quality Payment Program Final Rule: What You Need to Know

Halloween may be over, but CMS has given us one more scare—a 1,653-page Final Rule for Year 2 of the Quality Payment Program. The Proposed Rule represents the next phase of the transition into a full-fledged Quality Payment Program. For eligible providers, more is required to avoid penalties, but CMS has defined the process to favor those making efforts to avoid penalties. Of course, the program is designed to facilitate improvement—not just to meet a minimum participation threshold. Success will not be quantified in terms of avoiding penalties but, rather, by demonstrating exceptional performance and improvement. With these guidelines established…
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Future of Health CareMACRAMerit-Based Incentive Payment System (MIPS)Performance Improvement
September 20, 2017

Physicians Aren’t Engaged in Performance Because Measure Results Aren’t Real

According to management guru Peter Drucker, “If you can’t measure it, you can’t fix it.” Quality measurement and reporting have been rooted in similar reasoning. The idea is that we find out what’s wrong, and then we launch programs to improve it. That’s the linear route mapped out by Medicare starting with Meaningful Use, PQRS quality reporting, Value Modifier comparisons, and moving into current MACRA MIPS and APMs. But physicians have known something for a while that others have been unwilling to accept: quality reporting measures don’t give you a foundation for improving outcomes. Why? Because performance measurement does not…
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MACRAMerit-Based Incentive Payment System (MIPS)Qualified Clinical Data Registry Reporting
September 6, 2017

October 2 Is Almost Here: Are You MIPS-Ready?

Calendar check! October 2, the last chance to start your continuous 90-day participation in MIPS, is nearly here. Those who meet minimum standards in the “Pick Your Pace” transition year will avoid a whopping 4 percent penalty on their 2019 Medicare Part B reimbursements. Those who exceed these requirements and perform strongly in MIPS stand to earn incentive payments on top of the regular reimbursement schedule. To make sure that you’re among those who will earn incentives (or at least avoid penalties), take an opportunity to review MIPS requirements, assess what’s in place and close the remaining gaps. What Do…
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Alternative Payment Models (APM)MACRAMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
August 23, 2017

CMS Eliminates Episode Groups in MIPS Cost Tracking for 2018—But Providers Should Not

It’s no surprise that Cost is one of the most significant targets of Medicare Value-Based Health Care initiatives, as well as those in the private sector. So it was a real surprise last month to learn that CMS would delay weighing Cost as a component of MACRA MIPS total scoring. Equally significant is the CMS plan to scrap the ten episodic cost measures that were part of the cost calculation for provider groups in exchange for new, “to be determined” versions. Does this retreat from Cost and episodic costs calculation signal a big shift in the direction of Medicare Value-Based…
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