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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

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

Why All the Fuss About BPCI Advanced?

On January 9, 2018, the Center for Medicare and Medicaid Innovation (CMMI) announced a new voluntary episodic payment model, Bundled Payment for Care Improvement Advanced (BPCI-A).  In addition to new revenue, BPCI-A offers providers the opportunity to gain experience with, and develop necessary infrastructure for, value-based payments. Like other episodic payment models, BPCI-A participants will … 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

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

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

IPPS Provider Reimbursement Update and Sept. 30 Worksheet S-10 Deadline

Some providers could see significant changes to their Medicare reimbursement come October 1, 2017, when the Centers for Medicare & Medicaid Services (CMS) will start paying providers their 2018 Inpatient Prospective Payment System (IPPS) rates.  Significant items to note include changes to Uncompensated Care (UCC) payments, Low-Volume Adjustments (LVA), and Medicare Dependent Hospital (MDH) reimbursement. … 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

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

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

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

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

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

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

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

May 31 Deadline for 2017 Medicare Shared Savings Program

An organization interested in participating in the Medicare Shared Savings Program (MSSP) as an accountable care organization (ACO) must file a non-binding notice of intent (NOI) by 5:00 pm EDT Tuesday, May 31.  Only those organizations that file an NOI will be permitted to file an MSSP application, which will be due by 5:00 pm … 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

Addressing Confusion Around Comprehensive Primary Care Plus

In the immediate aftermath of the Center for Medicare and Medicaid Innovation’s (CMMI) announcement of Comprehensive Primary Care Plus (CPC+), we have fielded numerous questions regarding the interplay of this new program with other Medicare initiatives.  Specifically, we have been asked how a provider should decide between participating in CPC+ and joining or continuing to … 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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