When the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law, it created two distinct pathways for reporting: the Merit-Based Incentive Payment System (MIPS), and the Advanced Alternative Payment Model (Advanced APM). Under MIPS, Medicare Part B payments are tied directly to clinician performance based on Composite Performance Scores (CPS), whereas the Advanced APM track encourages groups of clinicians to take on greater risk (and reward) for cost and quality of care.

In this week’s blog, we’re taking a deep dive into Qualifying APM Participant (QP) and Partial QP Determinations, as laid out in the 2019 QPP final rule.

If your organization invested significant money and time into achieving a high MIPS score in 2017, the final incentive payment you received may have felt… well, disappointing. As easy as it may be to recognize the ideological importance of shifting from fee-for-service to value-based care, many clinicians and organizations feel unable to practically justify such an investment in the absence of a meaningful financial incentive.

But there’s good news: incentives will continue to rise in coming years, and those achieving the highest scores will soon find their efforts rewarded on a much larger scale. Here’s why.

With the new year comes a renewed focus on data analytics and interoperability.

Patients want to be treated with dignity and respect. And when they are, as the American College of Physicians (ACP) points out in a recent position paper on patient engagement, they are more likely to interpret their experience as a quality care encounter. Organizations can improve outcomes and adherence to care plans by helping patients and families feel central to their own care experience, and research even suggests that patient experience is a more important factor in patient loyalty than standard marketing efforts.

Have you checked your 2018 MIPS eligibility status? Since September?

CMS emailed physicians to let them know that their MIPS status for this year may have changed that recently--and some physicians may find that they are no longer eligible to participate. Although CMS conducted an initial review of Medicare Part B claims and Provider Enrollment, Chain, and Ownership System (PECOS) data between September 2016 and August 2017, further updates were made after a second review that took place between September 2017 and August 2018. If you are eligible, your 2018 performance will affect your 2020 Medicare payment adjustment.

Most post offices in the United States stay open late on April 15. The online voter registration portal for voters wishing to weigh in on Brexit crashed due to traffic two hours before the deadline. Our MIPS reporting customer support channels reach their peak traffic between on March 24, a week before the submission deadline. It is clearly human nature to procrastinate, so if you've reached December without a MIPS reporting plan, you're certainly not alone.

Bundled payments are on the rise. Last Thursday, Health and Human Services Secretary Alex Azar announced in a keynote speech at the Patient-Centered Primary Care Collaborative Conference that CMS will be revisiting mandatory bundled payment models, changing the way bundled payment programs have been treated by this administration under his predecessor, Tom Price.

Note: This article will update as we learn more, and to reflect any changes that may happen before the rule is officially published to the Federal Register on November 23, 2018. To view the entirety of the final rule, view the unpublished pdf version.

In August, the Centers for Medicare and Medicaid Services (CMS) released their proposed rule titled “Pathways to Success,” which outlined significant changes to the Medicare Shared Savings Program (MSSP) that encourage ACOs to move more quickly from one-sided to two-sided risk models. The proposed participation options for the MSSP--the largest ACO model with 561 participants--no longer include an “upside-only” risk model; instead, ACOs would be required to select one of two tracks, both of which ultimately include some downside risk.

EHRs have undoubtedly already changed the way healthcare works in America, and many of these changes have been for the better. Improved workflows and care delivery, enabled through EHR technology, are in many cases key to improving both patient and public health outcomes. But in the face of increasing requirements for providers, and the ever-looming need for health systems to justify their investment, EHRs must recognize that demand is high for a product that continues to improve and keep up with the changing times.