Healthmonix Advisor

With the introduction of MIPS reporting in 2017, and the launch of MIPSPRO, now is the time to be considering efficient ways of fulfilling MIPS requirements. CMS is conducting a study with the aim of better understanding practice's experiences quality reporting that will satisfy the Improvement Activities Performance Category of the Merit-Based Incentive Payment System (MIPS). Applications for this study are going to be accepted from January 1 - 31, 2017.

As I sit in my office, I hear the Christmas decorations coming down.  There is comfort in the known passing of the seasons and excitement at Healthmonix as we move into MIPS for 2017.  Our new platform for MIPS is ready for launch.  We are excited to see our efforts pay off for healthcare.

While the national election means that the Affordable Care Act will likely be changed, MACRA was passed with wide bipartisan support so will likely be staying in place. We at Healthmonix don’t believe the change in administration will affect the underlying efforts to transition to value-based care, either for MIPS or any other initiatives that we currently support.  The triple aim (better care, lower cost, better patient experience) is still at the heart of what we do.    

When reporting individual quality measures, whether it be for PQRS this year, or for one of the performance categories of MIPS next year, you are expected to report at least 50% of your eligible instances for each measure. In our experience, this concept can be confusing when practically applied. Luckily, it can be disambigusted in five easy steps!

 Consider All Patient Visits for the Performance Period

A performance period for PQRS is based on a complete calendar year beginning on January 1 and ending on December 31. 

For MIPS reporting, the performance period can range from a continuous 90-day period to the full calendar year.

Last night, a very surprising article was promoted, "CMS waves Physician Quality Reporting System penalties for 2017, 2018 after massive ICD-10 update clogs system." This post makes it seem as if only the Value-Based Modifier (VM) program penalties and incentives would still be in effect based on PQRS reporting done in 2015 and 2016. This is a dangerous misconception.

Once you've selected how you will report, the next step is to determine what you will report. This is called your reporting method. You have two options: reporting a measures group or reporting individual measures. 

Last week, we discussed the first step to reporting PQRS in 2016, selecting a submission mechanism. To briefly recap, there are three submission mechanisms that are viable for practices starting to report at this point in the year: Registry, EHR, and QCDR. Of these three options, Registry reporting has the highest rate of success and ease of submission. 

We call it “Informal Review Season”.  You could also call it “the Nightmare Vaguely Before Christmas” for
 providers who bill Medicare Part B services.  The 2015 PQRS Informal Review season (this year September 26th through November 30th) is that most wonderful time of the year when practitioners and practice administrators nervously await the release of feedback reports in September.  Instead of children wondering whether or not they’ve made Santa’s list, you’ve got providers and practitioners feverishly paging through their QRURs to see exactly how naughty or nice they are, according to CMS.  (Note: Documents released in the fall of 2016 pertain to the 2015 PQRS or VBM reporting period).

Reporting PQRS in 2016 is just as important as ever, with up to 6% of your Medicare Part B reimbursements on the line in 2018. According to the latest PQRS experience report^[1], about 66% of eligible providers are participating in PQRS. Of these participating providers, 68% are still reporting using the claims-based reporting mechanism, which has an abysmal 40% success rate in avoiding the PQRS penalty. Just taking these numbers into account, this takes us up to at least 61% of PQRS eligible providers not avoiding the PQRS penalty.

Thanksgiving is almost here! For me, this means reflecting on the things in my life that I am thankful for. Along with the tasty food I am about to consume with my loved ones, this year I am grateful for the MACRA Quality Payment Program. This may sound perplexing to you, as the MACRA Quality Payment Program has been causing a lot of alarm in the healthcare industry since the Notice of Proposed Rule Making (NPRM). However, with the release of the final rule came many provisions that I believe will improve the ease of reporting for clinicians while continuing to improve the quality of care for patients.

To briefly refresh before jumping in, the MACRA Quality Payment Program is split into two paths: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). MIPS streamlines pre-existing CMS quality initiatives (like PQRS and Meaningful Use), while Advanced APMs are designed to encourage innovative value-based payment models.

 On October 14, 2016, the Department of Health and Human Services release the MACRA Quality Payment Program Final Rule. According to the Executive Summary of the Final Rule, the aims of the Quality Payment Program are to : "(1) support care improvement by focusing on better outcomes for patients, decreased provider burden, and preservation of independent clinical practice; (2) promote adoption of Alternative Payment Models that align incentives across healthcare stakeholders; and (3) advance existing efforts of Delivery System Reform, including ensuring a smooth transition to a new system that promotes high-quality, efficient care through unification of CMS legacy programs."^[1]

In past weeks, we’ve looked at some reasons why bundled payments are taking off, and investigated a few specific CMS bundled payment initiatives happening now and in the near future. This week we’ve put together a list of three steps you can take right now to make bundled payments work for you and your practice.