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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ACOsBundled PaymentsFuture of Health CareSpecialty PhysiciansValue-Based Health Care
September 26, 2018

Five Strategies for Specialists: How to Safely Navigate ACO Arrangements

Amidst the furor over health care access and affordability, most consumers believe that the exceptional quality of America’s health care is due to specialty medicine. But Value-Based Health Care may well dramatically change specialty practice by putting specialists under financial risk arrangements. That’s because the most prestigious and flourishing providers in health care are also the most expensive for ACOs and health plans. That makes them a target for cost control. We have spoken about the need for ACOs to evaluate specialists carefully and ensure that specialists have input into ACO assessments of their cost and quality. Here we address specialists…
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Alternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Qualified Clinical Data Registry ReportingValue-Based Health Care
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…
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ACOsClinical Data RegistryMerit-Based Incentive Payment System (MIPS)Performance ImprovementValue-Based Health Care
July 18, 2018

No More MIPS Cost Score Details? 5 Ways Providers Can Still Take Control of Costs

CMS is urging providers to participate in ACOs with downside risk, but they might be eliminating one of the keys that providers need to prepare. It couldn’t come at a worse time, when providers already stand to lose under risk-based models if they can’t identify where their cost issues lie. That data is only available from claims data made available by payers. Up until now, practices have had access to indispensable data on costs that are attributed to their providers, showing specifics of where they are above the norm. These were previously part of Quality and Resource Use Reports (QRURs)…
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ACOsAdvanced Alternative Payment ModelsAlternative Payment Models (APM)MedicareMerit-Based Incentive Payment System (MIPS)Value-Based Health Care
June 13, 2018

Medicare Paths to Value-Based Health Care: Which Way is Up?

If you’re scratching your head about the direction of Value-Based Health Care (VBHC) in Medicare, you’re not alone. The current mix includes a swirl of separate initiatives, some new and others recently re-labled. As CMS pushes toward VBHC, providers may feel confused and frustrated as concepts emerge that will affect multiple programs. Within the last several months, the Patients Over Paperwork and Meaningful Measures initiatives have shaken up CMS value-based care programs, particularly: Merit-Based Incentive Payment System (MIPS) Medicare Shared Savings Program ACOs (MSSP ACOs) Direct Provider Contracting (DPC) Even more confounding, CMS is taking a non-linear development path for…
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ACOsFuture of Health CareValue-Based Health Care
May 23, 2018

Tipping Point Test for ACOs: Consent to Financial Risk

Last week the conversation about financial risk for providers in ACOs took on a decidedly different and more contentious tone. After months of CMS reports of ACO growth and success, while retreating on MIPS quality reporting requirements as concessions to “provider burden,” CMS signaled that they were finished waiting for providers to accept financial risk under Value-Based Health Care. With a third of Medicare patients served by an ACO and an even higher number of patients receiving health care via private sector ACOs, the industry seems on track to adopt ACOs as the preferred model of health care contracting and…
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ACOsAdvanced Alternative Payment ModelsFuture of Health CareValue-Based Health Care
April 4, 2018

ACO Economics 101: Optimize the Physician Network For Patient Choice

The inaugural MIPS 2017 submission period closed in a fog of uncertainty. The demise of MIPS looms on the horizon, with little discussion of opportunities for improvement. Heath and Human Services Secretary Azar has advocated for removing the quality reporting component of MIPS, while the Medicare Payment Advisory Committee (MedPAC) recommended scrapping MIPS altogether and pushed for a transition to Alternate Payment Models . Note that neither of these recommendations advocate a return to a simple Fee for Service model—it is not sustainable financially. Value-Based Health Care is here to stay, but Advanced Alternate Payment Models (AAPMs) with financial risk are…
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