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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ACOsAlternative Payment Models (APM)Consumers & PatientsMedical Decision-MakingValue-Based Health Care
June 6, 2018

Where’s the Value for Physicians in VBHC? Four Strategies for ACOs and Other APMs

When we talk about “value” in Value-Based Health Care (VBHC), we’re referring to the high-quality/lower-cost services that buyers want from health care providers. Who are the buyers? Health plans, Medicare and other governmental purchasers, plus employers (for the most part, the term is notably not interpreted to include patients). What do buyers want? “Truth in purchasing” for the best health care they can get. Indeed, the very term “Value-Based Health Care” implies that buyers are on a righteous quest for good care from irresponsible providers. Provider organizations, in turn, have sometimes adopted a similar attitude toward physicians. The generation of…
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ACOsAdvanced Alternative Payment ModelsFuture of Health CareValue-Based Health Care
April 4, 2018

ACO Economics 101: Optimize the Physician Network For Patient Choice

The inaugural MIPS 2017 submission period closed in a fog of uncertainty. The demise of MIPS looms on the horizon, with little discussion of opportunities for improvement. Heath and Human Services Secretary Azar has advocated for removing the quality reporting component of MIPS, while the Medicare Payment Advisory Committee (MedPAC) recommended scrapping MIPS altogether and pushed for a transition to Alternate Payment Models . Note that neither of these recommendations advocate a return to a simple Fee for Service model—it is not sustainable financially. Value-Based Health Care is here to stay, but Advanced Alternate Payment Models (AAPMs) with financial risk are…
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ACOsAlternative Payment Models (APM)Consumers & PatientsFuture of Health Care
March 28, 2018

Reluctant Providers Can Benefit from Fresh Approach to ACOs

It’s no secret that CMS wants to move providers away from MIPS and the Fee-for-Service payment system, toward an Alternative Payment Model (APM) like an Accountable Care Organization (ACO). This past January’s announcement of an additional 124 new ACOs implies that we have reached a tipping point, with ACOs becoming more prevalent than standard Fee-for-Service payments. But that optimism overstates the status of ACOs, both in terms of numbers and success. Despite a steady increase of new ACO approvals and ACO provider participation—including an attractive 5 percent bonus for providers who participate in an Advanced APM (AAPM) with financial risk—the…
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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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Alternative Payment Models (APM)Bundled PaymentsFuture of Health CarePerformance ImprovementValue-Based Health Care
January 24, 2018

BPCI Advanced Means Financial Risk Is Coming for Specialists

In case you missed Medicare’s messages about its reimbursement direction in recent years, CMS just reminded us that financial risk is well on its way. If you’re developing strategies that assume the status quo, it’s time to reassess your organization’s financial footing. CMS has already stated its intention to shift 50 percent of Medicare provider reimbursement into Alternative Payment Models (APMs) by the end of this calendar year. And those APMs are quickly transitioning toward putting providers at financial risk, because CMS is rewarding them to do so. CMS’s goal to impose financial risk was front and center again this…
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