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MIPS or APMs … That Is The Question – MACRA Monday

Posted on August 1, 2016 I Written By

John Lynn is the Founder of the 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 and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

As we outlined in the first entry of MACRA Monday, MACRA is broken down into two programs: APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System). The question your practice should be asking yourself is whether your practice will be participating in the MIPS or APM program. Practices will participate in one or the other, but not both.

Steve Sisko recently tweeted that CMS estimates only 4% of doctors will participate in MACRA as an APM. Regardless of the exact percentage, it’s clear that the majority of providers will need to worry about MIPS and won’t spend much time looking into the details of the APM program. As such, we’ll spend most of our MACRA Monday time diving into the details of MIPS and not APMs. However, in this post we will highlight what would make you qualify as an APM in case that applies to you.

Here’s CMS’ technical definition of who’s included in an APM:

  • CMS Innovation Center model
  • MSSP (Medicare Shared Savings Program)
  • Demonstration under the Health Care Quality Demonstration Program
  • Demonstration Required By Federal Law

In the CMS webinars, they offered this easier to understand list of who’s considered an advanced APM in 2017:

  • Shared Savings Program (Tracks 2 and 3)
  • Next Generation ACO Model
  • Comprehensive ESRD Care (CEC) (large dialysis organization agreement)
  • Comprehensive Primary Care Plus (CPC+)
  • Oncology Care Model (OCM) (two-sided risk track available in 2018)

Those are the details of who should be watching the APM program because they could be a participant. If you’re not participating in any of these programs, then you’ll not be taking part in the APM program. Next week we’ll dive into more details of other requirements to be what is considered an “Advanced APM”. Plus, we’ll dive into the benefits of participating as an advanced APM.

As I mentioned, we’ll be focusing most of our MACRA Monday series on the MIPS program, but it’s important that all practices spend time understanding the APM program even if you’re not going to be impacted by it in 2017. Why? CMS expects that while most practices will start their MACRA journey in the MIPS program, practices will transition to the APM program over time. How quickly that will happen and the process for switching programs will be interesting to watch. However, that’s why even MIPS participants should be keeping an eye on what’s happening with the APM program. It’s important to see the trends and shifts so your practice is ready.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.

New Payment Model Pushes HIT Vendors To Collaborate

Posted on April 20, 2016 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 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.

CMS has launched a new program designed to shift more risk to and offer more rewards to primary care practices which explicitly requires HIT vendors to be involved at advanced stages. While the federal government has obvious done a great deal to promote the use of HIT in medical practices, this is the first I’ve seen where HHS has demanded vendors get involved directly, and I find it intriguing. But let me explain.

The new Comprehensive Primary Care Plus payment scheme – which builds upon an existing model – is designed to keep pushing risk onto primary care practices. CMS expects to get up to 5,000 practices on board over the next five years, spanning more than 20,000 clinicians serving 25 million Medicare beneficiaries.

Like Medicare payment reforms focused on hospitals, CPC+ is designed to shift risk to PCPs in stages. Track 1 of the program is designed to help the practices shift into care management mode, offering an average care management fee of $15 per beneficiary per month on top of fee-for-service payments. Track 2, meanwhile, requires practices to bear some risk, offering them a special hybrid payment which mixes fee-for-service and a percentage of expected Evaluation & Management reimbursement up front. Both tracks offer a performance-based incentive, but risk-bearing practices get more.

So why I am I bothering telling you this? I mention this payment model because of an interesting requirement CMS has laid upon Track 2, the risk-bearing track. On this track, practices have to get their HIT vendor(s) to write a letter outlining the vendors’ willingness to support them with advanced health IT capabilities.

This is a new tack for CMS, as far as I know. True, writing a letter on behalf of customers is certainly less challenging for vendors than getting a certification for their technology, so it’s not going to create shockwaves. Still, it does suggest that CMS is thinking in new ways, and that’s always worth noticing.

True, it doesn’t appear that vendors will be required to swear mighty oaths promising that they’ll support any specific features or objectives. As with the recently-announced Interoperability Pledge, it seems like more form than substance.

Nonetheless, my take is that HIT vendors should take this requirement seriously. First of all, it shines a spotlight on the extent to which the vendors are offering real, practical support for clinicians, and while CMS may not be measuring this just yet, they may do so in the future.

What’s more, when vendors put such a letter together in collaboration with practices, it brings both sides to the table. It gives vendors and PCPs at least a marginally stronger incentive to discuss what they need to accomplish. Ideally – as CMS doubtless hopes – it could lay a foundation for better alignment between clinicians and HIT leaders.

Again, I’m not suggesting this is a massive news item, but it’s certainly food for thought. Asking HIT vendors to stick their necks out in this way (at least symbolically) could ultimately be a catalyst for change.