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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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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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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ACOsFuture of Health CareSpecialty PhysiciansValue-Based Health Care
May 9, 2018

ACOs and Specialty Physicians: How Episodes of Care Create a Win-Win Cost and Quality Strategy

Specialty care is a thorny cost and political issue for ACOs and physicians alike. No ACO can provide good or comprehensive patient care without specialists. But if ACOs are to produce savings, they will almost certainly need to address how, when and at what cost those specialists will be used. The degree of concern about specialist-generated costs for most ACOs currently depends on the ACO’s structure. ACOs that are hospital-led or formed by multi-specialty health systems or networks may be less apt to look to specialty care for savings, except when the specialists are outside the ACO. Physician-led groups with…
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Future of Health CareMedical Decision-MakingPerformance ImprovementQualified Clinical Data Registry ReportingValue-Based Health Care
January 17, 2018

Time Out! How Strategic Pauses Can Enhance Medical Decision-Making to Improve Outcomes 

Health care providers are under increasing pressure to improve outcomes for patients with chronic conditions. There is pressure to meet quality measures, to establish programs that improve outcomes, to decrease costs for these conditions (utilization as an outcome)—or a combination of goals. At issue: what works, what is affordable, what is acceptable to patients and clinicians. The answers are elusive because there are many factors involved in the care of patients who have numerous chronic conditions, co-morbidities and medications, as well as multiple healthcare professionals providing their care. Adding to this complexity, any outcomes improvement for patients with chronic conditions…
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Future of Health CareMedical Decision-MakingPatient EmpowermentPerformance Improvement
December 14, 2017

Is Shared Decision-Making the Path to Improved Provider Performance?

As an escalating percentage of Americans (including children) are diagnosed with diabetes and hypertension, the health care system is straining to control costs and demonstrate good clinical outcomes. No surprise that providers blame patients for lack of compliance with therapies or lifestyle changes that will improve their health status. Hence the uptick—some say warranted—in incentives or penalties assessed by insurers or employers on patients who don’t “behave.” But this punitive finger pointing is neither equitable nor productive. Just as it’s unfair to hold physicians, alone, to be fully accountable for patient outcomes in quality reporting and cost, without giving them…
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Merit-Based Incentive Payment System (MIPS)Performance ImprovementQualified Clinical Data Registry ReportingValue-Based Health Care
November 29, 2017

Convention Lesson: MIPS Improvement Activities Are Woefully Misunderstood

With only a month left of 2017, practices should be wrapping up their Improvement Activities. MIPS requires at least 90 consecutive days of participation in order for a group or clinician to attest that an Improvement Activity is complete—meaning that the last day to start was October 2. The Improvement Activity portion of MIPS is the only component that is not a direct descendant of a previous program, increasing the challenge of implementation. Recently, we attended a national conference for those in healthcare practice and administration; one of our goals was to learn more about how practices were adapting to…
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Clinical Data RegistryFuture of Health CareMedical Decision-MakingValue-Based Health Care
November 15, 2017

Choose the Right Strategies and Technology to Improve Cost Performance in Health Care

Fee for Service (FFS) reimbursement is going the way of the dinosaurs, but many providers are ignoring the signals. Here are two clear indicators: Medicare’s adoption of episodic cost models and the planned movement to financial risk models for both Medicare and Medicaid. Indeed, most Medicaid plans have now transitioned the majority of beneficiaries into managed care plans. Private health plans, many of which were burned by capitated HMO plans in years past, are aligning with providers to develop ACOs and moving again toward risk. Recent health care mergers and acquisitions evidence a blurring of lines between health plans and…
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Future of Health CareMACRANarrow NetworksPerformance ImprovementValue-Based Health Care
November 1, 2017

Providers Should Believe in Health Care Cost Control Now—If They Want to Stay in Business

Despite MACRA and other Value-Based Health Care efforts, many health care providers believe that controlling health care costs is impossible to do. They cite lack of comprehensive data about their patients and where they obtain services, and lack of control of patients’ decisions. But the real issue that providers have with cost control is much simpler: Why give up revenues under Fee for Service by reducing volume of services? That system has rewarded them well, fueling the growth of consolidated health systems, technology expansion and purchase of physician practices by ensuring a patient base. Controlling costs is now a relatively…
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