November 7, 2018
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…Read More
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…Read More
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…Read More
November 8, 2017
The 2018 Quality Payment Program Final Rule: What You Need to Know
Halloween may be over, but CMS has given us one more scare—a 1,653-page Final Rule for Year 2 of the Quality Payment Program. The Proposed Rule represents the next phase of the transition into a full-fledged Quality Payment Program. For eligible providers, more is required to avoid penalties, but CMS has defined the process to favor those making efforts to avoid penalties. Of course, the program is designed to facilitate improvement—not just to meet a minimum participation threshold. Success will not be quantified in terms of avoiding penalties but, rather, by demonstrating exceptional performance and improvement. With these guidelines established…Read More
August 16, 2016
Can MACRA Help Patient-Centered Medical Homes Succeed?
The concept of a Patient-Centered Medical Home (PCMH) fits neatly into Value-Based Health Care: patients who are well should incur lower costs. And, if primary care providers help patients who are not well to manage chronic diseases and better navigate the system, outcomes and costs should also improve. But those results are not yet proven. Like any new delivery model, the solution can only work if providers have the commitment and tools to realize its potential. This is why MACRA’s new emphasis on the Patient-Centered Medical Home includes many incentives to engage providers. The PCMH features strongly under MACRA. Medicare’s…Read More