Bundled payments are on the rise. Last Thursday, Health and Human Services Secretary Alex Azar announced in a keynote speech at the Patient-Centered Primary Care Collaborative Conference that CMS will be revisiting mandatory bundled payment models, changing the way bundled payment programs have been treated by this administration under his predecessor, Tom Price.

Note: This article will update as we learn more, and to reflect any changes that may happen before the rule is officially published to the Federal Register on November 23, 2018. To view the entirety of the final rule, view the unpublished pdf version.

In August, the Centers for Medicare and Medicaid Services (CMS) released their proposed rule titled “Pathways to Success,” which outlined significant changes to the Medicare Shared Savings Program (MSSP) that encourage ACOs to move more quickly from one-sided to two-sided risk models. The proposed participation options for the MSSP--the largest ACO model with 561 participants--no longer include an “upside-only” risk model; instead, ACOs would be required to select one of two tracks, both of which ultimately include some downside risk.

The new proposed rule for 2019 features a lot of changes to the Quality Payment Program, but CMS has also announced changes impacting Medicare reimbursement in general. One big change proposed would affect how much money a clinician receives for billing office or outpatient Evaluation and Management (E&M) visits for new and existing patients.

In a new proposal titled “Pathways to Success,” the Centers for Medicare & Medicaid Services (CMS) has laid out a modified set of participation options for ACOs (accountable care organizations) in the Medicare Shared Savings Program (MSSP). The proposed participation options would no longer include an “upside-only” risk model; instead, ACOs would be required to select one of two tracks, both of which ultimately include some downside risk.

Today, CMS posted CY 2019 Updates to the Quality Payment Program to the Federal Register. Many clinicians are still trying to wrap their heads around how to report MIPS in 2018, but the release of the 2019 proposed rule is advantageous in deciding what to conquer both this year and in the future.

Today, CMS posted CY 2019 Updates to the Quality Payment Program to the Federal Register. Many clinicians are still trying to wrap their heads around how to report MIPS in 2018, but the release of the 2019 proposed rule is advantageous in deciding what to conquer both this year and in the future.

Today, CMS posted CY 2019 Updates to the Quality Payment Program to the Federal Register. Many clinicians are still trying to wrap their heads around how to report MIPS in 2018, but the release of the 2019 proposed rule is advantageous in deciding what to conquer both this year and in the future. As the title suggests, this document also covers other Quality Payment Program tracks, like Advanced APMs; however, for now we will just focus on the MIPS component of the proposed rule.

In 2018, CMS is pushing even harder for the shift toward value based care. The minimum MIPS reporting score has increased from 3/100 to 15/100, and failing to report results in an automatic 5% reimbursement penalty. But if your practice or organization isn’t in a position to invest the kind of time, money, and resources that it takes to really go all in on VBC, you might be wondering: “what’s the minimum I can do to avoid the penalty?”

There is no one answer to this question, but the good news is that your practice has several options for how to report to earn a score of at least 15/100.

For many practices, one of the biggest differences between MIPS reporting for 2017 and 2018 is the amount of information that needs to be reported to achieve a high score. Gone is the test option that allowed clinicians to simply report on 90 days worth of patient visit information for the Quality performance category—now clinicians need to report on 60% of eligible patient visits per measure for all payers. This is typically a phrase I repeat a few times when discussing MIPS with practices who reported minimally for 2017.