August 14, 2019
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 Prospective Payment System (OPPS) rule. Competition Among Risk Models Will Strongly Affect the Course of Change With so many CMS programs and models now in flux, the whole is more than the sum of its parts. It’s worth the effort to pay attention to the…Read More
July 31, 2019
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 to Congress on its concerns that MIPS is overly burdensome and complex, and doesn’t translate into better care. That theme repeatedly shines through the 1,704 page proposal. CMS is using this rule as an initial salvo indicating that MIPS as we know it is headed…Read More
July 24, 2019
Can ACOs Survive the Complicated New Landscape in Medicare Risk?
What a difference a year makes. In Spring 2018, many Accountable Care Organizations (ACOs) pondered a walkout over Medicare plans that included downside risk in ACO financials. Nonetheless, CMS finalized its plans to make provider risk a reality for all ACOs in its Pathways to Success overhaul of the Medicare Shared Savings Program (MSSP). ACOs’ lukewarm reception to the goal of compelled savings, however, was not forgotten. Fast forward to April 2019, when CMS announced five Primary Care Models to propel physician groups to adopt risk-based reimbursement directly—including capitation. Those models are now under fast-paced implementation, with application deadlines approaching.…Read More
June 5, 2019
Can Small PCPs Succeed in Medicare’s Primary Care First?
Medicare’s announced primary care models will provide an interesting test of whether financially-motivated primary care practices (PCPs) can improve hospital utilization, the key outcome measure that will determine provider revenues under the pilot. While provider risk for costs of patient care is inevitable for most physicians in the future, providers don’t have the same potential for financial success. That is especially true for PCPs, whose volume and roles in health care have been eclipsed by specialists and industry consolidation. Whether Value-Based Health Care can restore primary care to a central role of coordination—with the potential for cost reduction—is at the…Read More
May 22, 2019
Can Provider Risk Cure High Medical Costs?
Fee-for-Service (FFS) has been on a slow march toward risk-based reimbursement for two decades. But FFS has proven to be remarkably resilient—until now. In the last six months, Medicare has doubled down on creating new provider risk models for ACOs, specialists and primary care physicians. All of them have methods to ensure that providers are held accountable for medical expenditure targets. Wait. Haven’t we been here before? What‘s different between now and the 1980s, when HMOs and provider risk first prevailed in the market—and then were purged as both ineffective and unpopular? Is provider risk a cure for high medical…Read More
May 8, 2019
How Will New Primary Care Models Affect Providers in VBHC?
Embraced by some provider groups and disparaged by others, CMS’s five new payment models for practices focused on primary care include much to consider. All reflect a key departure of Medicare’s Value-Based Health Care (VBHC) efforts to date: they are direct efforts by Medicare to transition physician practice revenues to risk without the necessity of ACO participation. The primary care models will affect both providers and patients. In this article, we’ll address the provider issues. How patient choice of care and outcomes for patients and patient populations will be affected deserves dedicated scrutiny in a future post. No Surprise that…Read More
January 9, 2019
Pathways to Success: How CMS is Encouraging ACO Participation Despite Impending Financial Risk
CMS closed 2018 with a farewell to upside-only ACOs. Perhaps the biggest surprise in the “Pathways to Success” Final ACO Rule is its consistency with the Proposed Rule, which floated the revamped ACO Track back in August. Citing superior performance among two-sided participants, as well as the belief that upside-only tracks reduce patient choice and increase costs, CMS has finalized its proposal to push all ACOs into two-sided arrangements. Not coincidentally, this rule was simultaneously released with NextGen ACO model results, which showed that these 44 downside-risk ACOs saved $164 million. The rule, which will go into effect on July…Read More
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…Read More
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…Read More
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…Read More