Healthmonix Advisor

The Centers for Medicare and Medicaid Services (CMS) have initiated the development of a Universal Foundation of quality measures to improve healthcare quality and transform care.

CMS operates more than 20 quality programs, each with its own set of quality measures. The lack of alignment across these programs has contributed to challenges for clinicians, facilities, and health insurers in prioritizing meaningful outcomes for patients.

By identifying CMS's priority areas for measurement and revealing gaps, the Universal Foundation will evolve over time, with the intent of reducing provider burden and improving patient outcomes.

If you are a dermatology practice, you probably breathed a sigh of relief when the Centers for Medicare & Medicaid Services (CMS) announced that dermatologists, along with many other specialists, would no longer be attributed patients for the Total per Capita Cost (TPCC) measure, as part of the Cost component of the Merit-based Incentive Payment System (MIPS).  However, in 2022, CMS introduced a Melanoma Resection Cost measure that is attributed to those specialists that perform these resections. So the Cost category is back for many dermatologists.  Even if this is the only Cost measure that is attributed to your practice, it is worth 30 of your total 100 MIPS points - as much as all your Quality measures combined!

With the release of the 2023 PFS Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized most of the proposed changes for the QPP / Merit-based Incentive Payment System (MIPS) program that had been released in the Proposed Rule last July.  

We are seeing that while the payment threshold is holding at 75 points, it can be tougher to achieve that threshold score with the changes in the program for 2023.

Electronic health record (EHR) companies have their single biggest technical update to complete by September 2023, as announced in a recent a meeting with the Deputy National Coordinator of Health Information Technology.  All EHR enhancements that are required to comply with the 2015 Cures Act standards must be completed by September 2023.   All data that is shared must be normalized by that time and EHR technology vendors are required to certify with real world testing.  

If you are managing a Medicare Shared Savings Program accountable care organization (MSSP ACO), you have heard the mandate from the Centers for Medicare & Medicaid Services (CMS) to move to eCQM/CQM reporting, replacing the Web Interface reporting.  You may also be aware of the significant pushback that ACOs, collectively and independently, have provided to CMS.  At this year’s fall National Association of ACOs (NAACOS) conference, the tenor changed to accepting the move, optional in 2022 through 2024, but required in 2025.

As you report your MIPS data, it can feel like a lot of work with little ROI for the last two years. But wait. Sometimes we need to step back and evaluate the bigger picture. While we often focus on "getting the job done", there are changes in the healthcare economy that are occurring that are strategic.

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Physician Fee Schedule (PFS) Final Rule which governs MIPS and other quality payment programs. Anticipated changes were made to MIPS, making the program more challenging in 2022 and signaling additional changes to the program in coming years.

With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Final Rule, CMS has demonstrated that MIPS will be both financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond.

The NAACOS Fall 2021 Conference was the first live meeting that the Healthmonix team attended since HIMSS 2020 was cancelled in March of that year. It was certainly reinvigorating to meet in person, discuss the state of payment models, and hear from CMS regarding their vision.

With the release of the 2020 feedback report detailing the 2.2% maximum possible payment adjustment and the release of the 2022 Proposed Rule, MIPS participants find themselves wrestling with lingering disappointment from participation in the program in previous years, and resistance to the idea that MIPS will be financially rewarding and challenging, in terms of reporting requirements, in 2021 and beyond.    

This is the second in a series of blog posts on the 2020 payment adjustment and the 2022 Proposed Rule, that will address this sense of disappointment and show how the future of MIPS will contain much more rigorous program requirements and create greater financial rewards.  To see financial and program success, you will need to be prepared to meet the new challenges.  We have the guidance you need to succeed in 2021 and beyond.