ACOsMerit-Based Incentive Payment System (MIPS)Quality Payment Program
July 19, 2021

The 2022 CMS PFS and QPP Proposed Rule: 7 Things to Know

After the 2020 election, we predicted seven trends to expect in Value-Based Care. Our forecasts were right on track. Last week the Biden Administration released its first Physician Fee Schedule and Quality Payment Program Proposed Rule, a 1,747-page document that promotes restructured value-based care initiatives. As we predicted, it recognizes both a significant health equity gap and a lack of useful data available to healthcare consumers as major challenges to overcome. We’re highlighting the seven biggest takeaways from the newly proposed Rule. Here’s the short version: The bar is higher, with substantial MIPS scoring changes ahead, and providers and organizations…
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ACO ReportingACOsAPM Performance PathwayMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
June 2, 2021

The Real Registry Advantage for ACOs Reporting Via APP: 5 Myths Debunked

The clock is winding down on the CMS Web Interface, and the reality of mandatory quality reporting via the Alternate Payment Model Performance Pathway (APP) for ACOs in 2022 is setting in. In order for ACOs to develop and execute their APP quality reporting plan in time to avoid catastrophe, it’s imperative to begin evaluating options now. ACOs, however, have staged a push-back to the APP based on a number of assumptions about their impact on ACO economics, success in reporting, and elements of reporting. A lot of these are simply untrue, based on faulty assumptions about reporting through the…
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ACOsFuture of Health CareMerit-Based Incentive Payment System (MIPS)RiskValue-Based Health Care
December 9, 2020

7 New Value-Based Health Care Directions You’ll See in 2021

Everyone who's reeling from 2020 is hoping for light in 2021. Health care, especially—systems, hospitals, clinical practices and their providers—wants the pain to stop. What might lie ahead for health care next year? Here's what we're thinking about the near future, and what you should watch for in 2021. 1. Health care providers will be fortified. If one thing is clear from the election results, it's that relief is coming to help providers on the pandemic’s front line. Money won't be free-flowing, but it will be targeted to areas of financial distress. We should expect initiatives to centralize purchasing and…
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ACOsMerit-Based Incentive Payment System (MIPS)Quality Payment ProgramValue-Based Health Care
December 2, 2020

The 2021 QPP Final Rule: A Warning Bell for ACOs and a Wake-Up Call for MIPS Participants

In a mere 2,165 pages, CMS has solidified the provisions of the 2021 Physician Fee Schedule and Quality Payment Program (QPP) Final Rule. The Final Rule strongly resembles the Proposed Rule, and the implications, particularly for ACOs, are staggering. Medicare Shared Savings Program Accountable Care Organizations (MSSP ACOs) and the Alternate Payment Model (APP) Pathway The most substantial change is that 2021 will mark the introduction of the Alternate Payment Model (APM) Performance Pathway, known as the APP. The APP aligns MIPS and APM participation more effectively in the Quality Payment Program (QPP). The APP is a pre-defined set of…
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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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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 CareMedical Decision-MakingValue-Based Health Care
October 2, 2019

How Consumers Can Choose Quality in Value-Based Health Care

In our last article on how Quality should be reflected in Value-Based Health Care, we looked at the problematic route of quality measurement and reporting. The intent to develop payment for quality has resulted in a complex measurement system that produced provider-specific performance scores across hundreds of measures, yet has failed to advance achievement of better health care outcomes. The system creates flexibility for providers by allowing choice of measures, which eliminates consumers’ ability to see differences among providers. The quality agenda needs to mature. In its developmental period, there was a need to achieve consensus on the standard of…
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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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ACOsFuture of Health CarePrimary Care PracticesValue-Based Health Care
September 4, 2019

Will “Value” Help Consumers Choose?

In the emerging days of Value-Based Health Care (VBHC), “value” was defined by quality, cost, and experience of health care for patients—the “Triple Aim.” The movement’s initial defining goal: patients should be able to access high value health care services that improved outcomes, to get value for their dollars. Likewise, employers and other purchasers deserved similar value for their share of investment in health care benefit plans. Because incentives inherent in insurance and Fee-for-Service (FFS) payment systems reward volume over value, however, VBHC has also had a subagenda to make value pay for providers. But to reward better value instead,…
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