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 […]
Amplify Your APP Payoff: Boost Quality and Costs with 3 Essential Data Types
Many ACOs are in the throes of planning to adopt APP Reporting. It’s a massive undertaking that can be costly, depending on your ACO’s configuration of practices. If your ACO is scrambling to sort this out, you’re not alone in your abrupt initiation into the world of EHR data. Welcome to the joy ride. In […]
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. […]
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 […]
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 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 […]
Are Patients at Risk when Quality Measures Scale Back?
CMS is now poised to roll back quality reporting requirements in 2021, vastly altering the direction of quality measurement. Simultaneously, CMS will reduce the weight in Value formulas dedicated to quality, transferring the balance to Cost over the next five years. As providers face risk-based reimbursement, what protections are needed to ensure that patients get […]
Five Actions ACOs Should Take Now: Takeaways from Proposed CMS Rulemaking
Last week CMS released a proposed rule addressing revisions in the Physician Fee Schedule (PFS) and the Quality Payment Program (QPP), along with a few other matters. Of 1,704 pages, only about 20 addressed ACOs issues directly. But ACOs should take a holistic approach to reading this proposed rule, as well as the proposed Outpatient […]
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 […]