2022 QPP Performance Report
ACOsAlternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Quality Payment Program
May 23, 2024

2022 QPP Experience Report: Address 3 Key Findings Now to Avoid Future Penalties

At first glance, CMS’s recently released 2022 QPP Experience Report (PDF) seems reassuring, because the majority of clinicians avoided financial penalties under MIPS. Don’t be fooled! While overall success and failure rates in the report may lead you to conclude that merely participating in the QPP (either in MIPS or as an APM) is enough to do well, trends in the report tell a very different story: Without a concerted and cohesive strategy to simultaneously improve efficiency and demonstrably improve quality, providers will begin to see their consistent results fall short of minimum performance thresholds. The QPP Experience Report details participation…
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Merit-Based Incentive Payment System (MIPS)MIPS Value PathwaysQuality Payment ProgramValue-Based Health Care
November 10, 2021

The 2022 CMS PFS and QPP Final Rule: A Warning Shot to Provider Holdouts of Value-Based APMs

CMS has released the 2022 Physician Fee Schedule and Quality Payment Program (QPP) Final Rule, and the message of these 2,414 pages is clear: CMS wants to push providers into value-based care arrangements. That intent was foreshadowed by the Proposed Rule released over the summer, which confirmed our predictions of trends under the Biden administration. Specifically, we saw a push to move providers into value-based care arrangements with an emphasis on closing the health equity gap, and a shift toward measuring progress through enhanced quality reporting requirements within a value-based care arrangement. To that end, in the Final Rule CMS…
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ACOsMerit-Based Incentive Payment System (MIPS)Quality Payment Program
July 19, 2021

The 2022 CMS PFS and QPP Proposed Rule: 7 Things to Know

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 gap and a lack of useful data available to healthcare consumers as major challenges to overcome. We’re highlighting the seven biggest takeaways from the newly proposed Rule. Here’s the short version: The bar is higher, with substantial MIPS scoring changes ahead, and providers and organizations…
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ACO ReportingACOsAPM Performance PathwayMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
June 2, 2021

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 options now. ACOs, however, have staged a push-back to the APP based on a number of assumptions about their impact on ACO economics, success in reporting, and elements of reporting. A lot of these are simply untrue, based on faulty assumptions about reporting through the…
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ACOsAPM Performance PathwayMerit-Based Incentive Payment System (MIPS)RiskValue-Based Health Care
May 24, 2021

New ACO Playbook: To Show Standout Performance, ACOs Must Rethink Quality

The health care media are full of articles asserting that ACOs have proven their mettle in delivering health care of highest quality. Citing ACO quality reporting results, CMS and advocates point to the majority of ACOs passing CMS quality standards, and that ACOs are improving their results on quality measures over time. The vast majority of ACOs meet quality measures, with 92 percent passing the qualification for shared savings in 2019. But is quality performance a distinguishing feature that ACOs can use competitively—and sustain the payment model’s long-term prospects? To earn permanency and competitive advantage, ACOs must show that the…
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ACOsFuture of Health CareMerit-Based Incentive Payment System (MIPS)RiskValue-Based Health Care
December 9, 2020

7 New Value-Based Health Care Directions You’ll See in 2021

Everyone who's reeling from 2020 is hoping for light in 2021. Health care, especially—systems, hospitals, clinical practices and their providers—wants the pain to stop. What might lie ahead for health care next year? Here's what we're thinking about the near future, and what you should watch for in 2021. 1. Health care providers will be fortified. If one thing is clear from the election results, it's that relief is coming to help providers on the pandemic’s front line. Money won't be free-flowing, but it will be targeted to areas of financial distress. We should expect initiatives to centralize purchasing and…
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ACOsMerit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
December 2, 2020

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 The most substantial change is that 2021 will mark the introduction of the Alternate Payment Model (APM) Performance Pathway, known as the APP. The APP aligns MIPS and APM participation more effectively in the Quality Payment Program (QPP). The APP is a pre-defined set of…
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COVID-19Merit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
August 5, 2020

“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 mud of the pandemic. Rather than launching the next step of integrating CMS quality improvement activities, the Proposed Rule stays the current course for MIPS Quality Reporting to avoid additional stress on providers during the COVID-19 pandemic. But the Proposed Rule also continues to…
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COVID-19Merit-Based Incentive Payment System (MIPS)RiskValue-Based Health Care
June 26, 2020

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 consequences of maintaining and expanding MIPS efforts. MIPS Is Not Going Away The day before releasing 2020 MIPS flexibility guidance, CMS announced the creation of the Office of Burden and Health Informatics, which has grown out of the Patients Over Paperwork initiative. In this notice…
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Alternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
November 6, 2019

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 changes. CMS’s desire to move providers into Alternate Payment Models (APMs) comes through loud and clear, both in terms of its vision for MIPS 2.0 and in its more stringent scoring policies. As it stands now, MIPS has not evolved into the program CMS envisioned…
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