Healthmonix Advisor

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 1^st, 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.

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.

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.

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.  

It felt as if the Medical Group Management Association (MGMA) Annual Conference, which we have attended for years, was smaller this year. The hall was down 10 percent, and the foot traffic was slower. Regardless, we left with plenty of insights into the state of the industry. Here are some of the highlights of what we learned:

The Merit-based Incentive Payment System (MIPS) can be rewarding for those who optimize their scores, and devastating for those who fall behind. 2019 is no longer considered a transition year, which means that the program is doing away with much of the leniency that made reporting easier in the past. The financial risk is now as high as 7%, while the performance threshold has increased to 30 points.

As the stakes continue to rise, it’s more important now than ever before that organizations strategize about their MIPS reporting process for 2019 and beyond. And in the course of that effort, one major decision they will need to weigh carefully is whether to report as individuals (at the NPI level) or as a group (at the TIN level).

Since 2017, the Centers for Medicaid and Medicare Services (CMS) Merit-Based Incentive Payment System (MIPS) has provided eligible clinicians a score of zero -100 annually based on the clinician’s efforts and data collection in four program categories: Quality, Improvement Activities, Promoting Interoperability, and Cost. A clinician’s final score for each year’s MIPS performance ultimately dictates a payment adjustment that is applied to his or her Medicare Part B reimbursement rate two years later. In practical terms, this means that a clinician’s 2017 performance impacts all of his or her Medicare claims that are filed in the 2019 calendar year.

In last week’s blog I laid out the case for opting into MIPS, an option that allows clinicians and groups to still receive a MIPS payment adjustment if they exceed 1 or 2, but not all, elements of the low-volume threshold. Although this option can be beneficial for a wide range of clinician types depending on their situation, today I want to focus on psychologists in particular. Because in my experience, they provide some of the most striking examples of this “MIPS hack” in action.