JANUARY 29, 2019

Welcome to the MACRA MIPS/APM Update eNewsletter
Editor: Philip L. Ronning
This issue sponsored by the
National Pay for Performance (PfP) Summit, the National Population Health Colloquium,
and the Combined National ACO, Bundled Payment, and MACRA Summit.

Eligible Clinicians: Report 2018 MIPS Data through April 2
CMS is reminding physicians that the data submission period for 2018 Merit-based Incentive Payment System (MIPS) data is now open. MIPS-eligible clinicians who participated in the second year of CMS' Quality Payment Program (QPP) have until April 2 to report their 2018 MIPS data. Those submitting data should follow these steps outlined by CMS:

  • Go to the QPP website.(qpp.cms.gov)
  • Sign in with QPP access credentials. (See directions below.)
  • Submit 2018 MIPS data.

Users will use the new HCQIS (Health Care Quality Information Systems) Authorization Roles and Profile (HARP) system to sign in and submit data. It's important to note that clinicians previously received their credentials through the Enterprise Identify Management (EIDM) system; however, according to CMS, all clinicians who had an EIDM account have automatically been transitioned to the HARP system. (American Academy of Family Physicians, January 14, 2019)

Findings and Implications from MIPS Year 1 Performance Data
The Centers for Medicare and Medicaid Services (CMS) recently published 2017 MIPS performance data from the first year of the Quality Payment Program (QPP). Implemented through the Medicare Access and CHIP Reauthorization Act of 2015, QPP is a value-based payment program with two participation options: the MIPS track and the Alternative Payment Model (APM) track. MIPS is a nationwide pay-for-performance program that aims to reward clinicians who provide high-value care with upward professional services payment adjustments, while penalizing clinicians who do not with downward adjustments. As discussed in a previous post, multiple factors are used in MIPS payment adjustments, some of which are determined only after the end of the performance year. As a result, clinicians may find it challenging to estimate their expected payment adjustments and make informed choices regarding the appropriate QPP participation track. Examples of these complexities include dynamic composite performance score (CPS) thresholds that differentiate between high and low performers, scaling factors that ensure payment adjustments remain budget neutral, and funding earmarked for "exceptional performance." (Health Affairs Blog, January 18, 2019)

Rural, Small Practice MIPS Performance Lagged Behind Large Peers
Data from the 2017 MIPS performance period showed lower scores and fewer exceptional performance bonuses for rural and small practices. Rural and small practices fared worse than their large peers in MACRA's Merit-Based Incentive Payment System (MIPS) in 2017, new research shows. Nearly one in five small practices received a negative MIPS payment adjustment compared to five percent of all program participants that year, revealed the analysis of 2017 MIPS performance data published in the Health Affairs blog. Additionally, many large practices qualified as exceptional performers during the value-based program's first performance year with mean and median composite performance scores (CPS) of 74.37 and 90.29, respectively. In contrast, most small practices did not qualify for incentive payments for exceptional performance in 2017. Small practices had a mean and median CPS of 43.46 and 37.67, respectively. "The 2017 MIPS performance data suggest that many clinicians in the program will face uncertainty about reimbursement adjustments," wrote the researchers from the University of Washington and University of Pennsylvania. "Though the magnitude of positive adjustments is expected to increase with planned program changes, performance varied considerably by practice size. This fact underscores the urgency facing policymakers to both support additional research and consider policy measures that support clinicians in smaller practices as they move towards value-based payment and care." (RevCycle Intelligence, January 22, 2019)

Get Ready for Health Care Disruption
Just like you, I'm trying to make sense of the world around me. But there are no templates for the bridge that health care's building for its future. All we can do is listen to weak signals and amplify them. Recently (and finally), CVS bought Aetna for $69 billion. I spoke to someone intimately familiar with the deal. He called it "vertical stacking" -- to expand what CVS customers can get -- from drugs to MinuteClinic consultations to now insurance. But it seems more like CVS disrupting itself before Amazon does. Earlier in the year, Amazon bought PillPack, an online pharmacy (CVS and others lost $11 billion in market value on the day of the announcement). The market is rife with speculation that Amazon is going to be the biggest company in health care (fancy signing up for Amazon Prime Health?). After such buzz, do you think other insurances or pharmacies will stay quiet? In the M&A world, more begets more. In fact, the entire health care industry is in an M&A frenzy. As of June 2018, health care was only third in line (#1 is energy, #2 is media) regarding size of deals. (Kevin MD, January 27, 2019)

Medicare Payments Won't Cover Costs for Many Physician Practices in 2019, Poll Finds
Medicare reimbursement isn't cutting it for many physician practices. Some 67% of medical practices said that the Medicare payment rates for 2019 will not cover the cost of their delivering care to patients, according to an MGMA Stat poll. In the poll conducted this month, only 16% of the 478 respondents said they expected their practice's Medicare payment rates would be above what it costs to deliver care to beneficiaries, and only 17% said they expected the rates would be equal to covering their costs. More than two-thirds of practices, however, said they expected a shortfall, leaving many practices to rely on contracts with private insurance companies covering non-Medicare patients to offset their loss. "Medicare fee-for-service can't be entirely abandoned. Below-cost rates coupled with limited APM [alternative payment model] opportunities won't sustain the transition to value-based payment and will potentially impact access to care," said Anders Gilberg, the Medical Group Management Association's senior vice president for government affairs. While Medicare rates are lower, those patients often require more care. The Medicare "population is more complex, more sickly and has comorbidities that you don't see elsewhere. It takes more resources to manage their conditions," said one of the survey respondents quoted in an MGMA commentary. Under the payment system put in place by the Medicare Access and CHIP Reauthorization Act (MACRA), Medicare fee-for-service payments are not keeping up with inflation or the cost of running a physician practice, MGMA officials said. "As medical practices transition toward a value-based payment environment, fee-for-service does not need to be abandoned entirely, but it does need to be updated appropriately," they wrote. "Even if a payment system provides the right incentives, if the underlying reimbursement rates are too low, the system is not sustainable for physicians to continue providing high-value care." (FierceHealthcare, January 22, 2019)

MACRA, Burnout and Advanced Practice Providers: Oncologists Share their Views
Recent changes in the oncology industry -- including the adoption of electronic health records, a significant growth in the average number of new patients per physician (358 in 2015, versus just 235 in 2003) and the shift to value-based care -- have created new and dynamic challenges for physicians, pharmaceutical manufacturers and other healthcare stakeholders. Among those challenges, concerns about shifting reimbursement models and increasing practice demands rank highly. Physician burnout has also been thrust into the spotlight of academic and media interest. Recently, more than 160 US oncologists weighed in on these important topics as part of recent research conducted by Cardinal Health Specialty Solutions and published in the fourth edition of Oncology Insights. The findings reveal both optimism and apprehension around these key developments in oncology care. (Cardinal Health, January 16, 2019)


(Physicians Practice, January 9, 2019)

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Panel II: Making the Business Case for Value-Based Care: Real-World Provider Case Studies Show Evidence that Focusing on Value is a Better Business Model than Maximizing Volume

Karen Conway
Vice President, Healthcare Value, Global Healthcare Exchange

David B. Muhlestein
Chief Research Officer, Leavitt Partners, LLC

Sanjay Doddamani
Senior Director in Population Health, Geisinger Health System

David Nace
Chief Medical Officer, MarkLogic