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Increasingly, Physician Practices Paying Fees To Receive Electronic Payments

Posted on October 13, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Virtually no one would argue that health plan reimbursement levels are particularly high. Adding a fee if they want to get paid electronically seems like adding insult to injury, doesn’t it?

Unfortunately, one in six medical practices report being hit with these charges, according to research by the Medical Group Management Association. Its recent survey found that some practices are paying a meaningful percentage of total medical services payments to get paid via Electronic Funds Transfer (EFT).

Under rules created by the Affordable Care Act, designed to decrease healthcare administrative overhead, CMS created a standard for EFT transactions. Health plans have been required to offer EFT payments if providers request it since 2014.

Health plans’ payment policies seem to vary, however. A recent MGMA Stat poll, which generated responses from more than 900 medical practice leaders, found that while 50% of practices were not paying fees for receiving payments via EFT, others are absorbing big surcharges.

For one thing, health plans are increasingly offering practices a “virtual credit card” they can use to receive payments. While 32% of MGMA respondents said they weren’t sure whether they paid an electronic payments fee or not, other research suggests that many practices end up using virtual credit cards without knowing they would be charged 3-5% per payment received.

Meanwhile, 17% of respondents told MGMA they were definitely paying transaction fees, and of that group, almost 60% said that the health plans in question used a third-party payment vendor.

MGMA sees this as little short of highway robbery. “Some bad actors are fleecing physician groups by charging them to simply receive an electronic paycheck,” said Anders Gilberg, MGMA’s senior vice president for government affairs.

The MGMA is asking CMS to issue guidance preventing health plans and payment vendors from charging EFT-related fees. The group argues that such fees are counter to the goal of reducing healthcare administrative complexity, the stated purpose of requiring health plans to offer EFT payments.

Also, the American Hospital Association and NACHA, the electronic payments association, are asking CMS to set standards on when and how health plans can implement virtual cards, as well as making it easy for practices to move to EFT.

The imposition of fees is particularly unfair given that health plans benefit significantly from issuing EFT payments, the group says. For one thing, health insurers save millions of dollars by sending payments via EFT, MGMA notes. Not only that, sending payments via EFT allows health plans to automate the re-association of electronic payments with the Electronic Remittance Advice.

While it’s true that physician practices used to save time staff would’ve used to manually process and deposit paper checks, that doesn’t make the fees okay, the group argues. “Beyond the material administrative time savings for all sides, the time and resources that physician practices spend on billing and related tasks are better spent delivering healthcare to patients,” it said in a prepared statement.

Why Delaying the Transition to 2015 Edition Technology Would Be a Problem for Patients and Families – MACRA Monday

Posted on September 11, 2017 I Written By

The following is a guest blog post by Erin Mackay, Associate Director, Health Information Technology Policy and Programs, National Partnership for Women & Families.  This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

The National Partnership for Women & Families recently weighed in on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for 2018 updates to the Quality Payment Program (QPP). In our comments, we express concerns that many of the proposed requirements would have a chilling effect on the country’s badly needed transition to a health care system that rewards quality and value over volume. Of particular concern to us is the proposed delay in clinicians’ transition to the 2015 Edition electronic health record (EHR) certification requirements.

Putting off requirements to use more advanced health IT would be a one-two punch to health transformation. First, new models of care that demand high-quality, efficient practices and coordinated care rely on robust health IT. Likewise, these new models only succeed when patients have the information – about their medications, health status, diagnoses and treatment received – they need to participate in their care and make informed decisions with their health care teams.

Here are three ways the proposed rule would delay critical functionalities that are foundational to a patient and family-centered health care system:

1) Delaying Availability of APIs for Consumer Access
It would undermine the commitment to patient engagement to delay the availability of application programming interfaces (APIs) as a way for patients and their caregivers to access, download and share health data. When available, APIs will let consumers choose from a range of apps that pull in health data from various health care providers and hospitals, helping form a comprehensive picture of their health and health care and facilitating information sharing. Gone will be the days when patients and family caregivers struggled to remember passwords for multiple patient portals, or were able to view only one aspect of their medical history at a time.

2) Slowing More Robust Collection of Demographic Data
To enhance health equity, we must first be able to identify disparities by gathering standardized, granular demographic data. Right now, certified EHRs are not designed to distinguish among Chinese, Indian or Vietnamese patients, for instance, instead collapsing these identities into a single “Asian” category. Similarly, EHRs cannot currently store structured information about patients’ sexual orientation or gender identity. In both these examples, this information has clinical relevance and is vital for improving health outcomes. For example, too often transgender individuals do not receive appropriate “gendered” preventive screenings such as Pap tests, mammograms and prostate exams.

3) Failing to Capture Information on Social Determinants of Health
In addition to better demographic information, to best support providers in delivering patient- and family-centered care, EHRs should also capture information about non-clinical factors pertinent to individuals’ health. The 2015 Edition includes a new criterion to capture relevant social, psychological and behavioral data. This includes information on financial resource strain, educational attainment, stress, depression, physical activity, alcohol use, social connection and isolation, and intimate partner violence. At the individual level, this information could help clinicians and care teams determine treatment options that address the unique needs of the patients and families they serve. To improve population health, clinicians, hospitals and community organizations need this information to identify communities that need additional support in order to get and stay healthy.

Conclusion
Overall, the proposed rule for QPP 2018 raises a number of concerns for the National Partnership, particularly the proposed delay of 2015 Edition certified health IT products. We strongly encourage CMS to maintain the current requirements and timeline for clinicians transitioning to the 2015 Edition to provide the necessary infrastructure for the kind of patient- and family-centered health system our country urgently needs.

Leveraging New Age Technology to Overcome MACRA Challenges – MACRA Monday

Posted on August 21, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The following is a guest blog post by Dr. David A. Goldman, CEO and founder, Goldman Eye and Ophthalmology Team Lead, Anterior Segment at Modernizing Medicine.  This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

MACRA and the Quality Payment Program (QPP) were implemented by the Centers for Medicare & Medicaid Services (CMS) to improve healthcare by focusing on the quality of care provided to patients. There are two paths under the QPP: the Merit-based Incentive Payment System (MIPS) track which covers most clinicians, and the Advanced Alternate Payment Models (APMs) track which applies to providers who have taken on some risk related to patient outcomes (Medicare Shared Savings 2,3 and Next Gen ACO participants for example).

MACRA and MIPS are intended to advance quality based care by implementing outcome-based payment adjustments. Providers will be measured across a number of different performance categories and will be paid on a curve. By 2022, physicians who outperform their peers may receive up to a 9 percent positive payment adjustment on their Medicare reimbursements based on their performance in 2020. Those who report poor performance may receive up to a 9 percent negative payment adjustment on their Medicare reimbursements in 2022.

Specialtyspecific Measures & Bonus Points

As previously mentioned, if you perform better than your peers when it comes to MIPS, you can substantially increase your Medicare reimbursements. Conversely, reporting a score below the performance threshold could prevent you from receiving a positive payment adjustment on your Medicare reimbursements, and not reporting on MIPS could cause you to be penalized.

Some MIPS categories will be the same across all specialties such as Advancing Care Information and Improvement Activities, whereas others can be geared towards a specialty, like Quality. Quality accounts for 60 percent of your total MIPS score in 2017. As an Eligible Clinician (EC), you should select six measures, including one Outcome Measure or if an Outcome Measure is not available, a High Priority Measure. After your first Outcome or High Priority Measure, any additional ones you report will count towards your bonus points (up to six points). In addition, an EC can earn another six points by doing end-to-end reporting. More information on the measure specifications can be found here.

Under the Advancing Care Information (ACI) category, ECs have the option to earn 5 bonus points by being in active engagement with a specialized registry, which are typically specialty-specific. The third category of MIPS is called Improvement Activities (IAs) which has over 90 activities to choose from. ECs, regardless of specialty, can choose activities that apply to their practice size and way of practicing like expanded practice access and closing the referral loop. Depending on the IA selected, ECs can also earn a 10 point bonus under the ACI category.

How can we turn this change into an opportunity?

A major factor in succeeding in MIPS is the use of today’s latest technology. Innovative electronic health record (EHR) systems, which can collect and organize clinical data in a structured format, empower doctors to extract meaningful insights at the patient and population levels. Instead of relying on any one physician’s narrative assessment or unstructured data for a diagnosis or treatment, physicians who have access to an interoperable platform can reference relative findings from their peers while eliminating redundancies, automating communications and improving patient outcomes.

How Do You Track Your Performance

The answer is certainly not using pen and paper. Look for a certified EHR vendor that has technology which provides services and products that can track data in real time and provide analytics to show your progress and outcomes. You want MIPS intelligence directly built-in to your EHR system.

Modernizing Medicine offers a specialty-specific suite of products and services that gives physicians added support. modmed Ophthalmology™ helps ophthalmologists transition to MIPS by providing them with quality data and reporting capabilities with the products and services they provide. Included within the suite is the company’s flagship EHR system, EMA™. EMA provides functionality for automated quality data capture, population health registries, real patient engagement and analytical tools, plus the ability to submit MIPS right to CMS.

I have been utilizing EMA for the past few years and am also a team lead on Modernizing Medicine’s ophthalmology team. As a practicing ophthalmologist, I have gone through the process of spending countless hours documenting patient reporting following a long day in the office. Couple that with ensuring my compliance measures are in check – it adds up. Now, my measures are completed efficiently, accurately and securely, ready to be submitted to CMS at the end of my reporting period. I even led a webinar on the topic of MIPS, if you want to see it in action.

EHR System Checklist for MIPS

From my unique perspective of working for an EHR vendor and utilizing the certified technology in my practice, I’ve shared a few qualities to look for in an EHR to support your reporting needs:

  • 2014 / 2015 ONC Certified
  • Integrated MIPS intelligence
  • Built in Improvement Activities
  • Qualified MIPS Registry
  • Automated data capturing and reporting
  • Built-in, real-time analytics reporting for Quality, Resource Use, Advancing Care Information and Improvement Activities
  • A vendor with an all-in on solution, including the ability to submit MIPS right to CMS
  • Advisory services and consultation during MIPS transition and reporting

While there is much work to be done in terms of keeping up with and understanding today’s fast-paced healthcare landscape, one thing is for certain – the proper use of specialty-specific technology can help alleviate hours of extra work, stress and physician burnout. As noted above, there are certain aspects of MACRA that apply across all specialties, whereas others are specialty-specific and working with a vendor that can guide you along this MIPS journey can be crucial to your financial success.

David A. Goldman, M.D. is the Ophthalmology Team Lead, Anterior Segment at Modernizing Medicine and founder of Goldman Eye in Palm Beach Gardens, Fla.

ONC To Farm Out Certification Testing To Private Sector – MACRA Monday

Posted on August 14, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

EHR certification has been a big part of the meaningful use program and is now part of MACRA as well. After several years of using health IT certification testing tools developed by government organizations, the ONC has announced plans to turn the development of these tools over to the private sector.

Since its inception, ONC has managed its health IT’s education program internally, developing automated tools designed to measure health IT can compliance with certification requirements in partnership with the CDC, CMS and NIST. However, in a new blog post, Office of Standards and Technology director Steven Posnack just announced that ONC would be transitioning development of these tools to private industry over the next five years.

In the post, Posnack said that farming out tool development would bring diversity to certification effort and help it perform optimally. “We have set a goal…to include as many industry-developed and maintained testing tools as possible in lieu of taxpayer financed testing tools,” Posnack wrote. “Achieving this goal will enable the Program to more efficiently focus its testing resources and better aligned with industry-developed testing tools.”

Readers, I don’t have any insider information on this, but I have to think this transition was spurred (or at least sped up) by the eClinicalWorks certification debacle.  As we reported earlier this year, eCW settled a whistleblower lawsuit for $155 million a few months ago;  in the suit, the federal government asserted that the vendor had gotten its EHR certified by faking its capabilities. Of course the potential cuts to ONC’s budget could have spurred this as well.

I have no reason to believe that eCW was able to beat the system because ONC’s certification testing tools were inadequate. As we all know, any tool can be tricked if you throw the right people at the problem. On the other hand, it can’t hurt to turn tool development over to the private sector. Of course, I’m not suggesting that government coders are less skilled than private industry folks (and after all, lots of government technology work is done by private contractors), but perhaps the rhythms of private industry are better suited to this task.

It’s worth noting that this change is not just cosmetic. Poznack notes that with private industry at the helm, vendors may need to enter into new business arrangements and assume new fees depending on who has invested in the testing tools, what it costs to administer them and how the tools are used.

However, I’d be surprised if private sector companies that develop certification arrangements will stay tremendously far from the existing model. Health IT vendors may want to get their products certified, but they’re likely to push back hard if private companies jack up the price for being evaluated or create business structures that don’t work.

Honestly, I’d like to see the ONC stay on this path. I think it works best as a sort of think tank focused on finding best practices health IT companies across government and private industry, rather than sweating the smaller stuff as it has in recent times. Otherwise, it’s going to stay bogged down in detail and lose whatever thought leadership position it may have.

The MACRA (QPP) API – MACRA Monday

Posted on August 7, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

When the MACRA program was announced, CMS also announced a new API for MACRA as well. In that announcement, CMS really just mentioned that the MACRA API would give developers access to the complete list of Advancing Care Information (ACI), Improvement Activities (IA), and quality measures for QPP 2017 (now called the QPP Measures Data Repository). While it was nice of them to offer this API, it really didn’t seem that useful.

Since then, CMS has launched what they call the QPP Submissions APIs which allow developers to submit MACRA data to CMS. This is much more useful and something that I believe will be adopted by many EHR vendors, data registries, etc.

Here’s a quick look at what these MACRA APIs can do:

  • Submissions API
    • Submit data as a single file or a set of smaller files throughout the reporting period, using QRDA-III or a new, streamlined QPP data format
    • Submit, update or delete ACI, IA and quality measures data during the reporting period
    • Receive feedback on the content and accuracy of a submission
    • Receive the preliminary score for a submission, based on the finalized policy
  • CMS Web Interface API
    • If you are registered for the CMS Web Interface, download your group’s beneficiary sample, modify it and submit it to the CMS Web Interface
    • Receive feedback on the content and accuracy of a submission
    • Receive a real-time composite score for a submission

For those that prefer a picture explanation of how the API works, you’ll enjoy this diagram of the current process and how the API works:

It’s great to see CMS really embracing APIs as part of MACRA. Now if we could just get the rest of healthcare and EHR vendors to implement high quality APIs.

MACRA Twitter Roundup – MACRA Monday

Posted on July 31, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program and related topics.

There’s always a lot of activity on Twitter that’s relevant and interesting and this is particularly true for MACRA. So, I thought it would be fun for this MACRA Monday to do a roundup of some of the recent tweets providing resources, information and perspective on MACRA.


This is an important list to know about if you’re participating in MACRA. Make sure you’re using an approved registry (QCDR for those following along at home). I wish it wasn’t a pdf, but it is CMS.


This is a great side by side comparison for those preparing for what’s coming in MACRA 2018. I also found it interesting to see that it outlines MACRA’s main goals as:

  • Improve Health Outcomes
  • Spend Wisely
  • Minimize Burden of Participation
  • Be Fair and Transparent

I think if those are the goals, they might have the wrong program.


This is many doctors views of MACRA. Although, Kris Held, MD is very vocal about it. Her Twitter profile even says she has a mission to get government out of medicine. I don’t think enough doctors are going to follow her lead and opt out, but we’ll see very soon.


This tweet just made me laugh. I guess there’s a Miss Macra. I’m not sure what the Miss Macra Festival is, but I find it hilarious when terms overlap like this. Not really the point of MACRA Monday, but I thought you might enjoy the laugh that I got from the odd overlap.

HHS Office of Inspector General Plans To Review $1.6 Billion In Incentive Payments – MACRA Monday

Posted on July 24, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program and related topics.

The HHS Office of Inspector General has announced plans to review the appropriateness of a walloping $14.6 billion of incentive payments made to providers over a five-year period.  The upcoming report, which follows on a GAO study naming improperly issued incentive checks as the biggest threat to the Medicare EHR incentive program, addresses payments made between by CMS between January 2011 and December 2016.

The OIG’s current audit plans follow on research it previously conducted which estimated that the incentive program had wrongfully paid out $729 million incentive payments between just May 2011 and June 2014.

To conduct that review, the OIG sampled incentive payment records for 100 eligible providers, then used the level of erroneous payments found among them to extrapolate the total amount paid out wrongly by CMS during those three years.

This time around, the watchdog organization plans to audit all payments made during the entire past life of the incentive program, an exercise which could generate some even more dramatic numbers. If the prior research is any indication, the OIG could conclude that roughly 10 % to 12% of the entire $14.6 billion in incentive payments it issued shouldn’t have been made in the first place.

Of course, looked at one way this effort could be seen as closing the incentive door after the horses have left. Meaningful Use, by all accounts, is giving way to incentives under MACRA, which will apply distinctive criteria to its incentive payment formulas. Also, while I’m no numbers whiz, seems to me that you can’t really model the entire meaningful use program effectively using just 100 sample cases.

That being said, it does seem likely that the audit will find more situations in which physicians hadn’t submitted he right self-attestation data or couldn’t prove what they asserted, and if the federal auditor has any role to play, this research is probably a good idea

Sure, nobody wants to be audited, particularly when your healthcare organization has jumped through many hoops to comply with meaningful use rules. Even if you can afford to pay back your incentive money, why would you want to do so? And particularly if you’ve already played by the rules, you certainly wouldn’t want to prove it again. But since the audit is going to happen anyway, perhaps it’s best to get any possible pain it may generate out of the way.

To date, I haven’t read anything suggesting that CMS has immediate plans to claw back incentive payments from providers. My assumption, though, is that they will eventually do so. Governments need money to get their job done, and audits theoretically offer the added benefit of tightening up important initiatives like this one.

As someone who has worked exclusively in the civilian world, I have often made fun of the plodding pace at which federal and state government agencies operate. In this case, though, a slow, deliberate process — such as a gradually-widening payment review — is likely get the job done most effectively. Let’s establish carefully which incentive payments may have been issued inappropriately and clear the decks for MACRA.

eClinicalWorks Settlement Raises Question Of Customer Liability

Posted on July 19, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Not much ago, my colleague John Lynn shared the news that EMR vendor eClinicalWorks had settled a whistleblower lawsuit for $155 million. The U.S. Department of Justice found that the vendor had skirted many EMR certification requirements, which in turn had caused providers using its software to file false claims for Meaningful Use incentives.

Today, I read an interesting follow-up by Becker’s Hospital Review addressing the issue of whether eCW users faced any liability for the vendor’s failure to meet certification standards.  The Becker’s writer, who reached out to CMS to find out its policy on the matter, found that while eCW’s customers technically submitted false claims for MU reimbursement, the agency won’t be asking any them to return any of the money.

If anyone has calculated how much CMS paid them, I haven’t seen the figures, but I’m sure it’s a pretty substantial sum of money. It’s good to see that the feds aren’t putting the squeeze on these customers, who presumably weren’t aware of eCW’s apparent skullduggery.

The thing is, I find it hard to believe that eCW is the only vendor who fudged things to get certified for the MU program. In fact, I’d guess that virtually every vendor in the industry has skirted if not crossed the line when it comes to EMR certification. That’s the way it goes, realistically, when you’re dealing with federal oversight.

After all, doesn’t every company work to save as much on taxes as they can? Yes, some are very conservative and only take whatever deductions they see as clearly legal, but others push harder. A goodly number of firms are willing to adopt strategies a tax lawyer might call “aggressive” – which don’t clearly violate the law but may raise a few eyebrows – in an effort to maximize their profits.

The big question here is whether an EMR customers could be on the hook for incentives paid wrongly due to an invalid vendor certification. If vendors are coloring outside the lines, it’s likely some will be caught, and if so, I’m betting that CMS will eventually get tough with their customers.

In the absence of clear evidence of customer wrongdoing, CMS might let customers keep their incentive payments. But I imagine that under some circumstances, the agency might wonder if they knew they what was going on and decided to take, say, a price cut in exchange for keeping its mouth shut.

Also, particularly if other vendors are hit with whistleblower suits, CMS might decide that customers should have validated that the EMR they were using actually had a legitimate certification. I don’t know how (or if) EMR customers would do this, but I can imagine a scenario under which CMS might take this tack.

Bottom line, we’d all better hope that CMS doesn’t decide to audit every vendor’s EMR certification filings. As I see it, their customers could easily be caught in the backlash.

The Health Plans’ Role in Meeting MACRA Requirements – MACRA Monday

Posted on July 17, 2017 I Written By

The following is a guest blog post by Karen Way, Health Plan Analytics and Consulting Practice Lead at NTT DATA Services. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

When the Medicare Access and CHIP Reauthorization Act (MACRA) became an official federal ruling for the healthcare industry in 2015, the act replaced the previous Medicare reimbursement schedule with a new pay-for-performance program focused on quality, value and accountability. In short, the legislation rewards healthcare providers for quality of care, not quantity.

While many discuss the impact on providers, what is the health plans’ role in aiding health systems and physicians to meet MACRA requirements?

MACRA provides multiple opportunities for health plans to increase and improve collaboration with provider networks. Recommendations on how health plans can accomplish this include sharing information and services, creating new partnerships and bringing about financial awareness as the legislation continues to take effect.

Sharing Data

One of the requirements under MACRA is for providers to enhance clinical measures and data analytics to strengthen members’ experiences. Health plans can assist by recognizing where providers lack expertise in data-related facts to offer input and support where it’s most beneficial.

For example, a provider may not have as much knowledge on advanced data science, but health plans can share their predictive models and tools to strengthen analytics. Sharing advanced technical infrastructure to facilitate data exchange will enable providers to access a more complete picture of members’ profiles. In return, the picture will provide a higher quality service to individual members, as well as opportunities for health plans to continue offering tailored consulting and data support.

At its best, sharing data to improve clinical measures is a win-win scenario. The Healthcare Effectiveness Data and Information Set (HEDIS) is a tool used by more than 90 percent of America’s health plans to measure performance on important dimensions of care and service. Just as HEDIS calls for measurement, MACRA also encourages health plans to aid providers with reporting standards. Under these rules, health plans are required to record a wealth of information on members, and when shared with providers, the tide lifts all boats.

Partnering to Manage Risk

Some of the changes under MACRA are reminders for providers to be highly aware of risk management. Providers will seek strong partners with the necessary skills, experience and knowledge to ensure they do not take on risk greater than they can support. To assist, health plans should enter into risk-sharing relationships, such as value-based contracts, with high-performing providers.

Health plans should actively strive to be strong partners by enabling robust data analytics that support quantitative action plans in the areas of quality and clinical care gaps, medical cost and trend analysis, population health, as well as member-risk management. As health plans partner with providers, they should also stay flexible on potential changes to provider payments as the pay-for-performance model(s) mature over time.

Financial Awareness

Health plans also need to be aware of the financial considerations that result from increased value-based contracting for small and large providers.

Under MACRA, smaller providers and individual physicians are more likely to be exposed to potential increase in costs, which may result in additional provider considerations. As Medicare payments shrink, these providers will look to shift costs to other payers, making contract negotiations more difficult and potentially increasing unit costs for some services. Large physician groups, or those located in markets with progressive healthcare systems, will look to negotiate even higher reimbursement rates due to the potential for increased competition.

Health plans should also be aware of potential impacts beyond Medicare fee-for-service (FFS), which is the initial focus of the MACRA legislation. Pay-for-performance is likely to extend beyond Medicare FFS into other health plan lines of business, such as Medicaid or commercial plans. For example, under MACRA, Centers for Medicare and Medicaid Services stated it would consider permitting Medicaid Medical Homes to count as an alternative payment model if participating practices would risk at least four percent of their revenue in 2019 and five percent in 2020.

Why This Matters

Overall, MACRA creates a tall order as it aims to increase pay-for-performance and decrease care based on quantity. This notion is an altruistic adjustment for the health system and each party has a specific role to play to achieve the dream. But the backbone of this goal is collaboration between health plans and providers. Collaboration will result in shared clinical measures, awareness and management of risk, lower healthcare costs and, most importantly, improved patient outcomes.

The Top Three Hidden Impacts of MIPS – MACRA Monday

Posted on July 10, 2017 I Written By

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust