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 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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]