COVID-19Merit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
August 5, 2020

“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 mud of the pandemic. Rather than launching the next step of integrating CMS quality improvement activities, the Proposed Rule stays the current course for MIPS Quality Reporting to avoid additional stress on providers during the COVID-19 pandemic. But the Proposed Rule also continues to…
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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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COVID-19Future of Health CarePopulation Health
April 29, 2020

Restarting “Regular” Health Care Will Be Hard: How Providers Can Prepare Now

As states across the country begin to loosen restrictions for the coronavirus pandemic and return to a modified version of normal life, how will our health care system get back to providing regular care? In particular, how can providers pivot from the scale and aftereffects of COVID-19, and bring their patients back? In hot spot areas, that task will also require healing their own organizations. COVID-19 has upended traditional care delivery and revised priorities for patient care. It has changed status of providers and foisted enormous stress on front line staff, to the point of serious trauma and even suicide.…
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ACOsCOVID-19Future of Health CareValue-Based Health Care
April 15, 2020

Stretched to the Limit by COVID-19, Will Providers Get Relief from Medicare Value-Based Programs?

This article originally appeared in the April 2020 edition of Accountable Care News . COVID-19 continues its inexorable, exponential spread here in the U.S. Hospitals in New York City, now accounting for more than 7 percent of confirmed cases worldwide, have less than a quarter of the critical equipment and supplies needed to serve an overwhelming surge of patients. Our health care providers are facing impossible choices, even considering universal Do Not Resuscitate orders for patients with COVID-19. Less than one month ago, CMS was closing applications from providers willing to be part of a major movement to adopt financial…
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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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Consumers & PatientsFuture of Health CareValue-Based Health Care
October 16, 2019

The Hedge Bet for Risk is Patient Experience

Creating a good Patient Experience in health care has gained little traction, despite being touted as one of the Triple Aim’s key goals in Value-Based Health Care. Health systems have been more focused on how to increase patients via health plan negotiations and consolidating regional providers, rather than focusing on the slower paced process of improving customer appeal. But now Patient Experience appears to be gaining some attention, and some forward-thinking providers are innovating to be more attractive to patients. Why? Because in the fiscal landscape of Risk, growing patient volume is essential. Providers are beginning to realize that there…
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ACOsSpecialty PhysiciansSpecialty ServicesValue-Based Health Care
October 9, 2019

How Physicians Can Navigate to Get Better Value from Specialty Services

In recent articles, we’ve discussed how Value-Based Health Care must help consumers make good decisions. Equally as important, CMS is now emphasizing how physicians should serve as navigators for their patients, providing information and guidance. Let’s take a closer look at how the triad of primary care physician, specialist consultant, and patient can effectively engage in a process that improves Value through better outcomes and lower cost. To focus on the shifting role of primary care physicians (PCPs), we use “physician navigation” to describe PCP actions to coordinate care for their patients. To emphasize continuity of care at stake for…
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Future of Health CareMerit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
September 19, 2019

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 the right care? Does streamlining the program give providers a pass on quality? And, how do patients choose providers when there is no standardized measurement? In this second in our series on whether Value-Based Health Care is on track to meet its mission, we take…
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Future of Health CareMedical Decision-MakingResearch
September 11, 2019

Fixing Clinical Science Requires a Moonshot

“We chose to go to the moon” President John Kennedy’s statement instigated a monumental marshaling of resources to achieve a remarkable goal. Those famous words also established a powerful metaphor for aiming high. We need an equally monumental shift in purpose and commitment of resources for how we conduct clinical science. Nothing less than our nation’s health is at stake. In my view, there are only three possible ways research efforts might proceed: First, the conduct of research might not change, but continue to rely on observational studies and non-generalizable randomized trials (RTs). If so, populations of subjects included in…
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