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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Alternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Quality Payment ProgramRisk
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…
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ACOsAdvanced Alternative Payment ModelsRiskValue-Based Health Care
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…
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Consumers & PatientsFuture of Health CarePopulation HealthValue-Based Health Care
December 5, 2018

Should Value-Based Health Care Help Improve Life Expectancy?

As Americans in a highly developed and prosperous economy, we have ascribed a value to our highly sophisticated, expensive health care system—that it should enable us to achieve better health. If we didn’t believe in the value of our health care system, we would not support health coverage, most people would not visit health care providers, and the public health system would not get be funded. This may sound all too obvious, but it isn’t. Whether our health care system actually achieves that ascribed value of improving health status is now in question. Given last week’s release of Center for…
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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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