Archives: Pay for Performance

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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 CMS Changing Course on Value-Based Payments?

This November, the Centers for Medicare & Medicaid Services (CMS) released a slew of regulations establishing Medicare payment policies for 2018.  Some argue the agency is hitting the brakes on moving Medicare from volume-based to value-based payments, citing CMS’ decision to slow down implementation, and scale back penalties under the Merit-Based Incentive Payment System (MIPS). … 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

MIPS 2017: 15 Minutes to Save Four Percent

As we near the end of 2017, you may think you’ve missed the chance to participate in the Merit-Based Incentive Payment System (MIPS), and thus resigned yourself to a 4% cut in your Medicare Physician Fee Schedule payments in 2019.  That translates to thousands of dollars in lost revenue for most physicians. What if we … 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

New Mandatory Episodic Payment Models: Slight Delay, But Not Going Away

During the last weeks of the Obama administration—on January 3, 2017—the Centers for Medicare & Medicaid Services published a final rule implementing new mandatory episodic payment models (the “EPM Rule”) to take effect July 1, 2017.  These models include the following: Acute Myocardial Infarction (AMI) Model: Acute care hospitals in 98 selected metropolitan statistical areas … 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

The Intersection of MIPS and MSSP: How the APM Scoring Standard Works

Previously, we highlighted several advantages of participating in the Medicare Shared Savings Program (MSSP) as an accountable care organization (ACO).  Our list included the more favorable manner in which a physician’s score is calculated under the Merit-Based Incentive Payment System (MIPS) if he or she is part of a Track 1 (no downside risk) MSSP … 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

Optimizing Your MIPS Score: Quality Measure Benchmarks and Reporting Mechanisms

The Medicare Quality Payment Program has officially launched, meaning most physicians (and most non-physician practitioners) now are in the initial performance period under the Merit-Based Incentive Payment System (MIPS).  With 60% of the MIPS composite score based on quality measures, the selection of the most appropriate measures, and the manner in which to report, is … 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

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

MIPS Pick Your Pace: What Will You Choose to Do?

In response to complaints that the planned January 1, 2017, launch date for the new Medicare Merit-Based Incentive Payment Program (MIPS) is too much too fast, CMS Acting Administrator Andy Slavitt announced in a September 8 blog post the “Pick Your Pace” opportunity. According to Mr. Slavitt, MIPS-eligible clinicians – including nearly all physicians and … Continue Reading

Making a Go/No-Go Decision on CPC+: Key Factors to Consider

On August 1, the Center for Medicare & Medicaid Innovation (CMMI) announced the 14 regions that will be part of the Comprehensive Primary Care Plus (CPC+) program.  These include the 7 regions now participating in the Comprehensive Primary Care Initiative (now known as “CPC Classic”) and 7 new regions. Primary care practices located in the … Continue Reading

Ambulatory Care Management Programs: New Revenue Opportunity for Specialists

Ambulatory care management programs generally are viewed as services offered by primary care providers.  However, specialists – oncologists, urologists, rheumatologists, cardiologists, pulmonologists, to name a few – caring for patients with chronic conditions should evaluate this opportunity. By providing patient education, performing medication reconciliation, and arranging for support services, clinical staff bring care outside the … Continue Reading

2017 Medicare Physician Fee Schedule Proposed Rule: Expanded Payments for Care Management Services

Since 2013, the Centers for Medicare & Medicaid Services (CMS) has been expanding Medicare payments for care management services.  This trend continues in the 2017 Medicare Physician Fee Schedule Proposed Rule.  Specifically, CMS proposes the following: Simplify the chronic care management (CCM) billing rules. Pay for complex CCM. Pay for care plan development. Pay for … Continue Reading

MACRA Delay? Don’t Count On It

You may have seen a headline or two last week stating that the Centers for Medicare & Medicaid Services (CMS) may delay MACRA’s effective date.  However, the agency has not announced any such delay.  Instead, CMS’ top official indicated the agency is considering some adjustments to the initial performance period. The U.S. Senate Finance Committee … Continue Reading

MIPS Proposed Rule: Big Changes to Medicare Physician Payments Starting in 2017

Good news:  2016 is the last year physicians have to report performance measure scores to the Centers for Medicare & Medicaid Services (CMS) to avoid up to a 9% reduction in Medicare Physician Fee Schedule (MPFS) payments under the Physician Quality Reporting System (PQRS), the Value-Based Modifier Program, and the Meaningful Use Program. Not-so-good-news:  A … Continue Reading

CMS Announces New Alternative Payment Model for Primary Care Providers

Back in 2012, the Center for Medicare and Medicaid Innovation (CMMI) launched the Comprehensive Primary Care Initiative (CPCI), joining with 38 payers to support 500 practices across 7 regions in transforming primary care.  With CPCI scheduled to end later this year,  CMMI announced (April 11) the launch of its largest investment in advanced primary care … Continue Reading
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