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.

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.    

For years, we’ve heard that the Merit-based Incentive Payment System (MIPS) will provide a noticeable incentive for participants in this Medicare FFS program. And for years, there have been reasons why that has not occurred. First, CMS wanted to ‘start slow’ with the MIPS program in 2017 and 2018, so the caps on penalties and incentives were small. Then the potential penalties and incentives were raised, but the threshold for qualifying for an incentive remained low. This, coupled with the program’s budget neutrality meant there was not much revenue to distribute to high performers. Then COVID-19 negated much of the program for the last two years. So here we are, in year five, and we see that the program, for the first time, will have a significant downside and upside potential.

The last 90 days of the year. Many might be ready to say goodbye to 2020 as a year filled with challenges, adjustments and ever-shifting expectations in our personal and professional lives. For those clinicians who are eligible for participation in the Merit-Based Incentive Payment System (MIPS), the last 90 days of the year also represents the beginning of some measurement periods and the final opportunity to improve in others.

Quality and Cost are two fundamental focus areas in the Volume to Value-Based Care transition.  The Centers for Medicare & Medicaid Services (CMS), seeks to incentivize higher quality care at a lower cost through programs like MIPS.  In recent years, the primary focus of MIPS has been Quality reporting, however Quality and Cost will be equally weighted in 2022.  Mandated increases and lack of insight into current MIPS scores make it a top priority for practices to learn how Cost impacts their revenue.

Physician practices are confronting new operational and business challenges as a result of the COVID-19 pandemic. There is a mounting financial and administrative toll this pandemic has placed on practices, forcing all to adapt in a variety of areas.  Much of the conversation around COVID-19 has appropriately focused on addressing the pandemic and treatment of COVID-19 patients, however, we are also keenly aware of the other impacts on practices. 

The CY 2019 Medicare Physician Fee Schedule Final Rule involves a slew of regulatory changes that will apply to the 2019 performance year. Of course, wading through the final rule to find and understand the most important features of the policy can be grueling; but you’re in luck, because we’ve already done it so you don’t have to! In today’s blog, we’re focusing on the MIPS Cost category.

A recent perspective article in the New England Journal of Medicine begins with a bold claim: that patient relationship categories and billing-code modifiers, which clinicians have been able to voluntarily submit since January 1, 2018, “may be one of the least known but most important provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).” In today’s blog we’ll explore how patient relationship codes may, as the article predicts, end up impacting reimbursement.

As laid out in the 2019 MACRA final rule*, one of the ways CMS hopes to expand participation options in the program’s third year is by offering certain facility-based clinicians, if they participate as a group, the option to use facility-based Quality and Cost performance measures. CMS expects to release a facility-based scoring preview for this option, which does not require any data submission, in Q1 of 2019. In today’s blog, we’ll take an in-depth look at the details of facility-based scoring and how it will be applied.