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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ACO ReportingCOVID-19RiskValue-Based Health Care
May 6, 2020

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 end, being largely excused from remaining 2019 reporting and 2020 enrollment obligations. True to our predictions, this will slow, but not reverse CMS’s ultimate agenda to push providers to manage under risk. Those who interpret the Interim Rule as a reprieve will do so at…
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Future of Health CareRiskValue-Based Health Care
March 11, 2020

Value-Based Care Defined: Know the Vocabulary of Health Care Reform

Today, as we confront a viral threat that is challenging our health system, its capacity, and how care is financed, it seems appropriate to review some fundamentals. Health care reform has been speeding down a particular track, changing how health care is covered, paid, delivered, and organized. These reforms may seem to be about health care financing, but will make a future difference in health care access and patient outcomes. Medicare is driving the train with its huge budget and rulemaking capabilities. But insurance companies, in lockstep, are rapidly implementing similar changes. Understanding all those changes is no easy task.…
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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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ACOsAlternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Primary Care PracticesValue-Based Health Care
October 23, 2019

Roji News Roundup: Fall 2019 Edition

In a range of recent industry publications, Roji Health Intelligence CEO Terry Hush shares her insights on the latest moves by CMS and health care trends: Are Value-Based Models Helping or Hindering Care Delivery for Primary Care Providers AJMC Managed Markets Network, October 10, 2019 This article by Jaime Rosenberg summarizes Terry’s presentation at the National Managed Care Physicians 2019 Fall Managed Care Forum in Las Vegas. Value-based models continue to enter the health care system, affecting a variety of fields, including primary care. And while success stories have been shared by payers and CMS touts these models as a…
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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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ACOsFuture of Health CareValue-Based Health Care
September 5, 2018

Ready or Not, Providers Will Face Risk Under ACOs or Medicare Advantage

In any other industry, companies work hard to interpret purchasing and regulatory trends, and adapt quickly in times of change. Swift action is a hallmark of competitive business; those that linger risk failure. Examples of business adaptation are everywhere: a move to digital applications that help consumers and other purchasers connect and build loyalty; acquisition or spin-off of business services to enhance growth; immediate response to negative press. But in health care, the pace of change at the industry’s core—healthcare organizations and health systems—is slow and barely responsive to the market. Case in point: while government and private health plans…
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ACOsFuture of Health CareValue-Based Health Care
August 15, 2018

Proposed ACO Final Rule: 10 Essential Takeaways from “Pathways to Success”

The Final Rule for the Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO)  has been released, the first real revision since the program’s inception. Introducing the proposed rule, CMS stated that it is time to put real ‘accountability’ in Accountable Care Organizations, and this means that ACOs need to accept financial risk. The theme behind Pathways to Success is to end the one-sided risk model. ACO Savings Success Was Zero-to-Limited Under the Savings-Only Model Although ACOs were supposed to curb healthcare spending, data released earlier this year showed that CMS actually spent $384 million more, rather than saving $1.7…
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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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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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