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.
The long-awaited CY 2021 Medicare Physician Fee Schedule Final Rule update is now here. Despite the disruptions of the Public Health Emergency COVID-19, participation in performance year 2019 was strong. Thus the 2021 Final Rule moved forward with finalizing a number of proposed changes, including a higher performance threshold for performance year 2021, anticipated changes in weight to the Quality and Cost performance categories of the Merit-based Incentive Payment System (MIPS), and the introduction of the APM Performance Pathway. Other expected initiatives, such as MIPS Value Pathways, the requirement for registries to build their own benchmarks for certain measures, and the sunsetting of the CMS Web Interface, have been pushed back to at least the 2022 performance year.
In the last couple of weeks, some major changes have been made to the immediate future of Value-Based Care payment models.
Some of these updates include:
- The extension of the Oncology Care Model (OCM) until June of 2022. The Centers for Medicare & Medicaid Services (CMS) is also giving practices the ability to abdicate downside and upside risk performance during the COVID-19 outbreak.
- The delay of starting the new Direct Contracting model to April 1st, 2021.
- The extension of the Next-Gen ACO model until December 2021.
- The option for participating entities in the Bundled Payments for Care Improvement Advanced (BPCI) payment model to eliminate upside or downside risk.
- The removal of COVID-19 episodes of care for certain Medicare ACO models.
We know the current regulatory updates for the Quality Payment Program (QPP) program. To date, the Centers for Medicare & Medicaid Services (CMS) has issued many changes. The 2019 MIPS reporting requirement had an extended deadline and options for hardship exemptions. The 2020 MSSP program reporting period had many changes in both of the interim final rule with comment periods (IFCs) issued by CMS, at the end of March and the end of April. CMS has also added a COVID-19 improvement activity to the 2020 program, that provides full credit for the Improvement Activity category for MIPS, if an individual or 50% of a group (TIN) participates in clinical trial reporting. No changes to the reporting window or other parameters of the program have been issued.
As public health experts determine that it is safe to see patients, and governments lift stay-at-home restrictions, physician practices are challenged to strategically plan when and how best to reopen. As the AMA points out, there are many components of reopening.
When the time is right, it will be critical to be prepared to reopen, ready to communicate and live a new practice “normal”. In these uncertain times, making sure physical practice changes, staff training, workflow and supplies align, will be important for a successful reopening. Filling your schedule in safe and meaningful ways will help the practice sustain itself and your team. Marketing and communication to patients will help restore confidence and build trust.
COVID-19 has presented clinicians with many new challenges that are transforming the entire care delivery model. It is crucial for health IT companies to do everything possible to support clients with navigating these rapid changes and keeping patients healthy. Strategic integration partnerships are an extremely effective method to provide clinicians with a reliable network that is packed with the resources needed to provide quality care. By working together, health IT organizations will play a vital role in overcoming the challenges and adjustments brought forth by the COVID-19 pandemic.
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 Centers for Medicare & Medicaid Services (CMS) continues to relax regulations to enable hospitals, clinics and other providers to boost their front-line medical staff during the COVID-19 pandemic. This pandemic has created an urgency for expansion of the use of virtual healthcare to reduce the risk of spreading the virus. It has also created a need to relax practice restrictions and allow more flexible care practices to meet the needs of patients.
The Centers for Medicare & Medicaid (CMS) is working rapidly to update policies and allow healthcare providers to flexibly apply best practices in response to the COVID-19 pandemic. Programs such as Hospitals without Walls and the existing Patients over Paperwork have been deployed. Removal of barriers have resulted in exponential growth of telehealth and remote patient monitoring. Advanced payments to healthcare providers are being provided to counter the effects of changing patterns of healthcare use, reduction in elective procedure, increase in ICU utilization and other ongoing unanticipated changes.
There is a tsunami of information coming at us all about COVID-19, the impact to healthcare practices, the business climate, and the federal government response. On Friday, we saw monumental legislative changes. I haven't read the entire 887 page document yet, but here are a couple of the best recaps I've seen.