Archives: Healthcare Reform

Subscribe to Healthcare Reform RSS Feed

Understanding Proposed Changes in Hospital Uncompensated Care Payments

The Centers for Medicare & Medicaid Services (CMS) published the 2019 Inpatient Prospective Payment System (IPPS) Proposed Rule April 24, 2018.  If finalized, many hospitals are likely to experience significant changes to their Medicare reimbursement, specifically their uncompensated care payment. First, CMS proposes to increase the size of the uncompensated care pool— from $6.77B to … Continue Reading

CMMI’s Next Big Thing: Direct Provider Contracting

Last fall, the Center for Medicare and Medicaid Innovation (CMMI) asked the public to submit recommendations on the agency’s future direction.  On April 23, CMMI made public a 4,643-page document and a 6,380-line Excel spreadsheet containing the responses it received from approximately 1,000 individuals and organizations.  Stay tuned for our high-level summary of these comments. … Continue Reading

Meeting New Medicare Requirements for Implantable Cardioverter Defibrillators

On February 15, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a Decision Memorandum revising the National Coverage Determination (NCD) 20.4 on implantable cardioverter defibrillators (ICDs).  This is the first update to NCD 20.4 since its implementation in 2005.  (As of April 13, 2018, NCD 20.4 has not been updated online and there … Continue Reading

What Congress Did to MIPS (And Why It Matters)

Almost every Merit-Based Incentive Payment System (MIPS) presentation includes a graphic like the one below illustrating upcoming payment adjustments of 4%, 5%, 7%, and eventually 9% on Medicare Part B payments, based on an eligible clinician’s performance on specified measures. Due to changes enacted as part of the Bipartisan Budget Act of 2018, however, clinicians’ … Continue Reading

Proving the Financial Impact of Chronic Care Management Services

Over the last four years, the Centers for Medicare & Medicaid Services (CMS) has expanded Medicare reimbursement for chronic care management (CCM) services based on the agency’s belief these services can lower the total cost of care.  While the clinical case for care management is compelling, the evidence supporting CMS’ conclusion has been limited to … Continue Reading

Risking Irrelevance?

Last November, we asked “Is CMS Changing Course on Value-Based Payments?”  We posed this question in response to a New York Times article highlighting how the Trump administration was slowing down and shrinking other Medicare pay-for-performance programs initiated under the Obama administration.  At the time, we offered four compelling reasons why providers should continue their efforts around … Continue Reading

Is Your Productivity-Based Physician Comp Model Undercutting Your Value-Based Contracting Strategy?

Many health systems now are making enormous financial investments in population health infrastructure, including IT solutions and care management infrastructure, to succeed under emerging alternative payment models (APMs).  And consolidation continues at a brisk pace, as systems look for cost synergy and capacity to manage risk. As systems position themselves for value-based contracting with these … Continue Reading

Mid-January Deadline for Initial Comments on CMS-Proposed Key Changes to Medicare Advantage for 2019

The Centers for Medicare & Medicaid Services (CMS) has set a mid-January 2018 deadline for public comments regarding recently published proposed policy and technical changes to Medicare Advantage (MA) for Contract Year 2019 (CY19).  Beneficiary enrollment in MA plans has grown steadily over the last several years, up to 19 million this year.  According to … Continue Reading

Survey Reports Significant APM Growth in 2016, With More to Come

On October 30, the Health Care Payment Learning and Action Network (the LAN) released its second annual payer survey on the transition to alternative payment models, or APMs.  The report shows nearly 30% of all payments for healthcare services – representing more than $350 billion – flowed through APMs in 2016. Formed in March 2015, … Continue Reading

CMS Cancels Episode Payment Models: Now What?

Back in June, when the Centers for Medicare & Medicaid Services (CMS) announced it would delay the effective date of the mandatory acute myocardial infarction (AMI) and coronary artery bypass graft (CABG) bundles to January 1, 2018, the agency stated: [W]e disagree with commenters who suggested that CMS withdraw these models altogether and/or delay them … Continue Reading

‘WannaCry’— Actions Your Healthcare IT Professional Wants You to Take Now

Thousands of computers across the globe were “held hostage” during the recent WannaCry ransomware attacks that encrypted files on Microsoft Windows operating systems that had not been either patched or upgraded.  The dust has now settled, and what we have learned from those attacks is that they could have been prevented. As a former hospital … Continue Reading

Taking a Closer Look at the MIPS Improvement Activities Component

While the Quality and Advancing Care Information components account for more significant percentages of a provider’s overall Merit-Based Incentive Payment Systems (MIPS) score (60% and 25%, respectively), one also needs to focus on the work required under the Clinical Practice Improvement Activities component, which comprises 15% of the MIPS score. The Centers for Medicare & … Continue Reading

Am I Included in MIPS? New On-Line Lookup Tool

The lookup tool is available on the Quality Payment Program website.  To use it, an individual provider need only enter his or her 10-digit NPI.  The lookup tool then generates a personalized report for the provider, stating whether he or she is excluded from MIPS under the low-volume threshold. Specifically, the report lists each TIN … Continue Reading

Watch Your Mailbox! MIPS Participation Letters Coming Soon!

In early May, each practice enrolled in Medicare Part B  (identified by its Taxpayer Identification Number, or TIN) will receive from its Medicare Administrative Contractor a letter regarding the Merit-Based Incentive Payment System (MIPS) participation status of the TIN and each physician and non-physician practitioner who bills under that TIN (identified by National Provider Identifier, … Continue Reading

MIPS Reporting: Getting Off on the Right Foot

A physician who did not report performance on quality measures to the Physician Quality Reporting System (PQRS) for 2015 now faces a 6% penalty on all Medicare Part B payments.  The same penalty will apply in 2018 for physicians who do not report performance for 2016. In addition to PQRS penalties, a 3% penalty now … Continue Reading

21st Century Cures Act – Patient Safety Act Protections Extended to HIT Vendors

As we discussed in a previous blog, the 21st Century Cures Act, signed into law December 13, 2016, includes a wide variety of provisions impacting healthcare providers.  One key provision of the Cures Act extends the protections of the 2005 Patient Safety and Quality Improvement Act to health information technology vendors. The Patient Safety Act … Continue Reading

Clock Ticking on New Revenue Opportunity for MSSP ACOs

On December 8, the Center for Medicare and Medicaid Innovation (CMMI) announced two new models to increase patient engagement in care decisions by putting more information in the hands of Medicare beneficiaries. Under one of these models, the Shared Decision Making (SDM) Model, CMMI will pay ACOs participating in the Medicare Shared Savings Program or the … Continue Reading

Key Provisions of the 21st Century Cures Act

With the focus on the future of the Affordable Care Act, the most recently enacted federal healthcare law—the 21st Century Cures Act—is getting less attention than it deserves.  The Cures Act, which weighs in at 312 pages, gained passage in both chambers by wide margins (392-26 in the House, 94-5 in the Senate) and was … Continue Reading

4 Need-To-Know Provisions in the 2017 Medicare Physician Fee Schedule Final Rule

On November 15, CMS published its 393-page 2017 Medicare Physician Fee Schedule Final Rule.  Here are 4 need-to-know provisions likely to have a direct impact on practicing physicians in the upcoming year. 1. Conversion Factor Under the Medicare Access and CHIP Reauthorization Act of 2015, MPFS rates are scheduled to increase by one-half percent each … Continue Reading

Has the ACA Been Trumped? Only Halfway

Presidential candidate Donald Trump promised that “[o]n day one of the Trump Administration, we will ask Congress to immediately deliver a full repeal of Obamacare.”[1]   President-elect Trump now has signaled a willingness to retain a few popular provisions (e.g., coverage for pre-existing conditions), but it seems likely Obamacare will be replaced with some form of … Continue Reading

Our Top Ten PQRS Reporting Readiness Tips

It has been a busy fall for physicians with the publication of the new Quality Payment Program (QPP) Final Rule and the 2017 Medicare Physician Fee Schedule (MPFS) Final Rule, the release of the 2016 Quality Resource Utilization Reports (QRURs), and the announcement of the Physician Compare preview period.  In addition, many physicians now are … Continue Reading

Medicare Advantage “Shopping Season”

The annual enrollment period (AEP) for Medicare beneficiaries to “shop” for their Medicare Advantage plan officially began October 15, 2016, and will end December 7, 2016.  This 54-day shopping season can be filled with anxiety, and many Medicare beneficiaries turn to their providers for input as a result.  Providers can help their patients in several … Continue Reading

MIPS Final Rule: Who’s In, Who’s Out, and Who Cares?

On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) published its final rule implementing the new Medicare Quality Payment Program, including the Merit-Based Incentive Payment System, or MIPS.  In response to providers’ concerns, CMS has made significant modifications to the proposed rule to ease program implementation.  Specifically, CMS has made four key … Continue Reading
LexBlog