Healthmonix Advisor

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 Quality Performance category.

On April 22, the U.S. Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) announced the CMS Primary Cares Initiative, a new set of payment models that are part of HHS Secretary Alex Azar’s value-based transformation initiative. The CMS Primary Cares Initiative will be administered through the CMS Innovation Center. CMS expects the new programs to shift at least one quarter of people in traditional Medicare out of fee-for-service.

According to a recent announcement from the National Association of ACOs (NAACOs), CMS failed to adequately communicate significant changes to measure ACO-17, Preventive Care and Screening, Tobacco Use- Screening and Cessation Intervention, until after 2018 quality reporting had begun. NAACOs believes that CMS’s failure to communicate these changes will result in unintended consequences such as lowered or even eliminated shared savings rates for ACOs that consequently received a lower performance score or failed to meet quality standards.

The U.S. Department of Health and Human Services (HHS) recently proposed a new rule to support the access, exchange, and use of electronic health information (EHI). The proposed rule encourages the adoption of standardized application programming interfaces (APIs), which will help allow individuals to securely and easily access structured EHI using smartphone applications. This facilitates a patient's ability to access their health information by requiring that patients be able to electronically access all of their EHI for free. It also implements the information blocking provisions of the Cures Act.

The rule gives seven exceptions to the definition of information blocking (proposed at 45 CFR 171.201–207). If an actor (a healthcare provider, HIT developer, or HIE or network) satisfies one or more exception, their actions would not be treated as information blocking and they would not be subject to civil penalties and other disincentives under the law. These seven exceptions are outlined below (this information based on the CMS fact sheet found here).

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 how MIPS final scores will be calculated, as well as factors that may lead to reweighting, in 2019.

Since the latest Physician Fee Schedule and Quality Payment Program final rule was released in November 2018, organizations across the country have scrambled to understand key changes that have been made and adapt to their implications. In today’s blog, I want to focus on one change that may well prove significant to billing and Revenue Cycle Management teams: groups of 16 or more can no longer report via claims.

When the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law, it created two distinct pathways for reporting: the Merit-Based Incentive Payment System (MIPS), and the Advanced Alternative Payment Model (Advanced APM). Under MIPS, Medicare Part B payments are tied directly to clinician performance based on Composite Performance Scores (CPS), whereas the Advanced APM track encourages groups of clinicians to take on greater risk (and reward) for cost and quality of care.

In this week’s blog, we’re taking a deep dive into Qualifying APM Participant (QP) and Partial QP Determinations, as laid out in the 2019 QPP final rule.

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.

If your organization invested significant money and time into achieving a high MIPS score in 2017, the final incentive payment you received may have felt… well, disappointing. As easy as it may be to recognize the ideological importance of shifting from fee-for-service to value-based care, many clinicians and organizations feel unable to practically justify such an investment in the absence of a meaningful financial incentive.

But there’s good news: incentives will continue to rise in coming years, and those achieving the highest scores will soon find their efforts rewarded on a much larger scale. Here’s why.

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.