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Early Lessons from the Front Lines of Value-based Care: How One APM Has Impacted Community-Based Oncology Practices

Posted on June 11, 2018 I Written By

The following is a guest blog post by Dr. Charles Saunders, CEO, Integra Connect.

The Oncology Care Model (OCM) – an alternative payment model introduced in July 2016 by the Center for Medicare and Medicaid Innovation – launched with the ambitious goal to further delivery of higher quality, more coordinated cancer care at a lower cost. Participants include 184 practices representing approximately one-third of community oncologists in the US. They receive a so-called “MEOS” (monthly enhanced oncology services) payment of $160 per beneficiary per month for the duration of a qualifying 6-month chemotherapy period, plus the opportunity to earn a share of savings if they exceed a target threshold. In return, oncologists are expected to take on increasing accountability for patient outcomes and well-being, while also generating sustainable cost savings across all co-morbidities and care settings, into the patient home.

OCM Performance Period 1 Results Exposed an Unexpected Misalignment   

As part of the OCM program, CMS tracks practices during 6-month intervals – so-called “performance periods” – then shares results back about one year later. In February 2018, practices participating in the OCM program received visibility into Performance Period 1 (PP1) data, including savings achieved, aggregate quality score, and effectiveness of identifying eligible patients. While most practices were unsurprised by their performance scores, many did not anticipate the extent to which CMS would recoup MEOS payments that it deemed paid in error. The most common scenario involved patients with co-morbidities who, while receiving chemotherapy and related services, also visited other providers regularly. Therefore, the oncology practice did not represent the required plurality of E/M codes for that beneficiary. It was not uncommon for practices to be asked to return up to 30% of the sum they had been paid – a major financial hit.

Lack of Data Hinders Practices’ Ability to Accurately and Proactively Identify Beneficiaries

In May 2018, practices received their Performance Period 2 (PP2) Attribution Lists, which summarized which CMS beneficiaries met OCM eligibility criteria, which episodes were attributed to each respective practice, and episode start dates from January 1, 2017 through June 30, 2017. Unfortunately, because there is a significant lag between actual Performance Period and delivery of CMS findings – delayed up to nearly a year after each performance period has ended – OCM participants were unable to retroactively apply PP1 learnings to PP2.

Why is this especially problematic? Practices are faced not only with MEOS recoupments for erroneous payments but, with only a 1-year window to submit claims, are often unable to bill in full for patients who were missed. Indeed, there are many opportunities to miss appropriate patients, as practices needed to have an accurate view of: 1) all beneficiaries; 2) those with a qualifying diagnosis; 3) those with a new chemo episode; 4) those not only prescribed an oral agent, but those who subsequently filled it; 5) those not in a hospice; and more. Given all the dimensions to track and measure, practices without advanced tools face delivering enhanced services that they cannot correctly bill for.

Best Practices from Community-Based Oncology Practices Include Robust Data

What best practices arose to get attribution right? A vanguard of OCM practices realized that they would need to take proactive steps to enable near real-time visibility into their patient populations, embracing the tenets of population health management. Below is an example of the best practices adopted by several of these community-based oncology practices:

  • Increased transparency into oral chemotherapies: Existing practice protocols did not open an episode when oral agents were prescribed, since there was no in-office administration. To address this, the practice introduced a rule-based algorithm to identify all OCM eligible patients, including those who had been prescribed orals. In addition, they enlisted a combination of automated and personal follow-ups to validate qualification and ensure orals had been filled.
  • Avoidance of duplication: To identify missed billing opportunities while also reducing the risk of duplicated claims, practice leadership invested in a robust analytics tool that enabled personalized queries at the patient level. These reports compared eligibility against their practice management report to identify gaps, from unpaid and unbilled to denied.
  • Targeted patient intervention: To balance the practice’s financial and clinical objectives while optimizing OCM performance, the practice introduced complex care management services and employed a series of triage pathways. This approach ensured engagement with attributed beneficiaries and decreased avoidable high-cost events among at-risk patients, such as inappropriate ER visits and inpatient stays.
  • Optimized treatment choices. As part of its commitment to ensure each patient received the most effective treatment for his or her disease, the practice provided increased transparency around the availability of equally effective generic or biosimilar drugs. They also supported better end-of-life planning for patients facing second or third-line therapies not expected to provide any clinical benefits, but that could significantly degrade remaining quality of life.
  • Continuous performance improvement: To track the effectiveness of these quality improvement initiatives, the practice leveraged its analytics tool to monitor resource utilization and care management performance, then intervened to address outliers in real-time.

In short, to optimize performance under the OCM, practices are beginning to leverage the data to which they already have access – both clinical and financial – to risk-stratify their patient populations; identify OCM eligible patients; and gain near real-time visibility into quality and cost performance. Practices are also investing in better data integration and analytics that enable rules-based identification of eligible patients.

Population Health Analytics Help Practices Be Proactive and Succeed Under the OCM

Oncology is on the forefront of value-based care adoption and these early experiences from the OCM have provided a guide for other specialties. Based on their early results, what has come to the forefront is the need for a combination of comprehensive data management and robust analytics, coupled with the principles of population health management, which enable practices to step up and take control of the cost and quality for their attributed populations.

How Will CMS Handle Issues Surrounding MACRA Changes?

Posted on May 14, 2018 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.

As most readers will know, when CMS released details on MIPS and the Alternative Payment Model incentives it embarked on a new direction for quality programs generally. As most readers will know, MIPS consolidated PQRS, the Physician Value-based Modifier and the Medicare EHR Incentive Program for EPs (Meaningful Use). But CMS is still updating the Medicaid incentive program.

If I were a physician, I’d be even more interested in the CMS initiative dubbed Promoting Interoperability. In some of the biggest news to come out of the agency in ages, CMS is restructuring the EHR Incentive Programs to become the Promoting Interoperability Programs. Promoting Interoperability replaces the Advancing Care Information category of MIPS.

Whoa. That would be a big enough deal on its own, but the issues the rule raises are an even bigger one.

CMS’s has been working towards this goal for a few years. Per HIMSS, here are some changes suggested in the proposed rule that might have the biggest impact on the health IT world:

  • The rule would cut down measures from 16 to six
  • It would use a new performance-based scoring methodology which would include measures of performance on e-prescribing, health information exchange, provider to patient exchange and public health and clinical data exchange
  • The agency will define and work to prevent “information blocking”

On a related note, CMS has posted a request for information asking for stakeholder feedback on program participation conditions. This is pretty unusual for the agency.

Like many CMS proposals, this one leaves some important questions open. (Apparently, CMS itself wonders how this thing will work, as the request for information suggests.)

For example, the new performance-based scoring method will award providers anywhere from 0 to 100 points. Measuring health IT performance is always a tricky thing to do, and there’s little doubt that if this becomes a final rule, both providers and CMS will have to go through some struggles before they perfect this approach. In the meantime, providers face some big challenges. How will they adapt to them? Its too soon to say.

Addressing so-called “information blocking” should be an even bigger challenge. Everyone from members of Congress to providers to vendors acts as though there’s one way to describe this practice, but there’s still a lot of wiggle room. Honestly, I’ll be amazed if CMS manages to pin it down the first time around.

Still, the time is more than overdue for CMS to take on interoperability directly. Without real data interoperability, many promising digital health schemes will collapse under their own weight. If CMS can figure out how to make it happen, it will be pretty neat.

Meaningful Use Becomes Advancing Care Information Becomes Promoting Interoperability – MACRA Monday

Posted on May 7, 2018 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.

I’m quite sure you’ve all seen the news coming out from CMS about the name change for the various Medicare EHR Incentive and MACRA programs. I decided to not dive into it in depth here since so many organizations are already doing it. Plus, this is just the proposed rule. However, if you want some light reading, here’s all 1883 pages of the Promoting Interoperability proposed rule.

The name change of Meaningful Use/Advancing Care Information to Promoting Interoperability is an interesting way for CMS to signal what they want these programs to accomplish. It’s always been clear that ONC has wanted to find a way to promote interoperability. Now they literally have a program that will work to drive that goal.

I’ll admit that I’ve been a fan of this idea since May 15, 2014 when I suggested that ONC and CMS blow up meaningful use and just focus it on interoperability. It only took 4 years for them to figure this out.

While I still think this is directionally an interesting way to go, I’m afraid that the current programs aren’t a big enough incentive for CMS to really move the needle on interoperability. Plus, can CMS really create a rule that would push effect interoperability? I’m skeptical on both counts.

What’s interesting is that CMS could really push interoperability if it wanted. It could just say, if you want to get paid for Medicare, then you have to start sharing data. No doubt there are some complexities to this idea, but if CMS is really serious about promoting interoperability, that’s what they’d really do. That would move the needle much better than thousands of pages of rule making that won’t cause doctors and healthcare organizations to change.

What are your thoughts on the proposed rule? Were there big pieces of it that you saw and you think others should be watching? Are these changes going to relieve doctors of the massive reporting burden they should today? Please share your thoughts in the comments or on Twitter with @HealthcareScene

AAFP Opposes Direction Of Federal Patient Data Access Efforts

Posted on April 4, 2018 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 long ago, a group of federal agencies announced the kickoff of the MyHealthEData initiative, an effort designed to give patients control of their data and the ability to take it with them from provider to provider. Participants in the initiative include virtually every agency with skin in the game, including HHS, ONC, NIH and the VA. CMS has also announced that it will be launching Medicare’s Blue Button 2.0, which will allow Medicare beneficiaries to access and share their health information.

Generally speaking, these programs sound okay, but the devil is always in the details. And according to the American Academy of Family Physicians, some of the assumptions behind these initiatives put too much responsibility on medical practices, according to a letter the group sent recently to CMS administrator Seema Verma.

The AAFP’s primary objection to these efforts is that they place responsibility for the adoption of interoperable health IT systems on physicians. The letter argues that instead, CMS should pressure EHR vendors to meet interoperability standards.

Not only that, it’s critical to prevent the vendors from charging high prices for relevant software upgrades and maintenance, the AAFP argues. “To realize meaningful patient access to their data, we strongly urge CMS to require EHR vendors to provide any new government-required updates such systems without additional cost to the medical practice,” the group writes.

Other requests from the AAFP include that CMS:

  • Drop all HIT utilization measures now that MIPS has offered more effective measures of quality, cost and practice improvement
  • Implement the core measure sets developed by the Core Quality Measures Collaborative
  • Penalize healthcare organizations that don’t share health information appropriately
  • Focus on improving HIT usability first, and then shift its attention to interoperability
  • Work to make sure that admission, discharge and transfer data are interoperable

Though the letter calls CMS to task to some degree, my sense is that the AAFP shares many of the agency’s goals. The physician group and CMS certainly have reason to agree that if patients share data, everybody wins.  The AAFP also suggests measures which foster administrative simplification, such as reducing duplicative lab tests, which CMS must appreciate.

Still, if the group of federal organizations thinks that doctors can be forced to make interoperability work, they’ve got another thing coming. It’s hard to argue the matter how willing they are to do so, most practices have nowhere near the resources needed to take a leading role in fostering health data interoperability.

Yes, CMS, ONC and other agencies involved with HIT must be very frustrated with vendors. There don’t seem to be enough sanctions available to prevent them from slow-walking through every step of the interoperability process. But that doesn’t mean you can simply throw up your hands and say “Let’s have the doctors do it!”

Learn the Latest ACI (Advancing Care Information) Details as Required in MACRA-MIPS

Posted on March 16, 2018 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.

We’ve been partners with 4Med for a long time and offered a wide variety of courses over the years. Many of you reading this have probably taken their HIPAA security courses or possibly one of their previous PQRS and meaningful use courses.

Of course, the meaningful use and PQRS courses have now evolved into training around MIPS and MACRA. You know how complex these can be and that’s why I’m grateful that 4Med has put together these concise courses to teach you and your practice what you need to know. Plus, as part of these courses you also get a certification and possibly CEUs (depending on which CEUs you need).

With this in mind, 4Med recently announced their next ACI (Advancing Care Information, formerly known as Meaningful Use) course along with the CMAP (Certified MACRA-MIPS ACI Professional) Certification. This is a great course for those wanting to hear the latest info from the 2018 final rule.

Here’s a full summary of topics the ACI course will cover:
* Introduction to ACI for MIPS ECs
* ACI Reporting 2018
* ACI Reporting Options for 2017
* Required Objectives for the ACI Category
* Optional ACI Objectives for ECs Using a 2015 CEHRT
* Optional ACI Objectives for ECs Using a 2014 CEHRT
* Focus on Protecting Patient Health Info
* Patient Electronic Access
* Coordination of Care Through Patient Engagement
* Health Information Exchange
* ACI Scoring

This course is a live online workshop held on April 18, 19, 25, and 26 and are led by Trisha Conway, RN, BSN, CEO and Principal Consultant at eHealth Consulting. Of course, if you can’t attend the live sessions, then they’ll be recorded and available to you after the live event as well.

If this course interests you, you can register now and save $150 off your registration thanks to Healthcare Scene’s partnership with 4Med. The promo code to get the discount is HCSEARLYBIRD150, but if you click this link the discount will be applied automatically.

There’s a Disturbance in the Force We Know as MACRA

Posted on February 13, 2018 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.

Yesterday Anne Zieger wrote about AAFP’s proposals to reduce the EHR Administrative Burdens and then we got this tweet from CMS Administrator Seema Verma:

That’s some really strong language from the CMS Director.

If you care about this topic, you should go and read all of Seema Verma’s tweets, but here are two more for those who don’t want to read them all:

Change is in the air it seems. Many providers are rejoicing if you look through the replies to Seema Verma’s tweets.

Dr. Ronald Hirsch asked the question that I’m sure many doctors were asking:

The short answer is no MACRA and MIPS aren’t going away. If my understanding of policy is right, Seema Verma doesn’t have the authority to make MACRA go away. That would take actions from Congress and I don’t know anyone holding their breath on that one. However, Seema can streamline the way MACRA and MIPS are implemented to make it much easier for doctors. That seems to be what’s happening now.

What will this mean for the future of MACRA? I don’t think anyone knows the answers to that question. However, what does seem clear from these tweets is that change is in the air. We’ll have to wait and see what those changes are and who influences the changes they make.

What do you think this means for MACRA and MIPS? I’d love to hear your thoughts in the comments.

AAFP Proposes Tactics For Reducing EHR Administrative Burdens

Posted on February 12, 2018 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.

The American Academy of Family Physicians has proposed a series of approaches it says will reduce the administrative burdens EHRs impose on primary care doctors.

The recommendations, which come in the form of a letter to CMS, address health IT simplification, prior authorization and standardization of quality measurement. However, the letter leads off with EHR concerns and much of the content is focused on making physician IT use easier.

Few would argue that the average physician spends too much time struggling with EHR-related administrative work. The AAFP backs this assertion up with a couple of studies, including one finding that primary care physicians spend almost 6 hours per day interacting with EHRs. It also cites research concluding that four types of specialist spent almost 2 hours using the EHR for every hour of direct patient care.

To address these concerns, the AAFP recommends taking the following steps:

  • Eliminating HIT utilization measures in MIPS: The group argues that such measures are not needed anymore now that MIPS includes quality, cost and practice improvement measures.
  • Updating documentation requirements: With the agency’s Evaluation and Management recommendation guidelines having been developed 20 years ago, prior to the widespread use of EHRs, it’s time to rethink their use, the letter asserts. Today, the group says, they have a negative impact on EHR usability and hinder interoperability. The group recommends eliminating documentation requirements for codes 99211-99215 and 99201-99205 entirely and allowing any care team member to enter medical information.
  • Rethinking data exchange policies: The AAFP is asking CMS and ONC to focus on how and when data is exchanged rather than demanding that specific data types be included. The group also urges CMS and ONC to penalize healthcare organizations not appropriately sharing information, using its authority granted by the 21st Century Cures Act.
  • Creating standardized clinical data models: To share data effectively across the healthcare ecosystem, the AAFP argues, it’s necessary to develop nationally-recognized, consistent data models that can be used to share data efficiently. It recommends that such principles be developed by physicians and other clinicians rather than policymakers, vendors or engineers.

I don’t know about you, but I find much of this to be a no-brainer. Of course, the decades-old E/M guidelines need to be reformed, consistent data models must emerge if we hope to improve interoperability and physicians need to lead the charge.

Unfortunately, it’s hard to tell whether CMS and ONC are willing and prepared to listen to these recommendations. In theory, leaders at ONC should be only too glad to help providers achieve these goals and CMS should support their efforts. But given how obvious some of this is, it should have happened already. The fact that it hasn’t points up how hard all of this could be to pull off.

Is MACRA Ruining Healthcare?

Posted on January 22, 2018 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.

If you watch social media, physician forums or other places physicians gather, you’d be sure to hear complaining about MACRA and it’s partner in crime MIPS. Some are even still complaining about things like meaningful use and PQRS even though those have all been rolled into MACRA/MIPS now. At the end of the day, I don’t know a single doctor that likes MACRA and MIPS.

I take some of this with a grain of salt because I don’t know a single doctor who likes charting a patient visit either. This was true in the paper chart world and is just as true in the EHR world. Why would a doctor find joy in recording data from a patient visit? That’s like asking a lawyer if they like writing really long legal briefs or contracts full of legalese. We’d all rather just do the fun parts of our job. In medicine that’s seeing the patient, treating the patient, etc.

Charting will never be seen as fun, but doctors do it because it’s necessary to get paid. Although, this oversimplifies it. Doctors are amenable to charting the patient visit because having that information could help them at a future visit. Having a record of what happened at various visits is useful to the doctor the next time you come to see them. So, between reimbursement and continuity of care, there are clear benefits to why a doctor needs to record the visit.

This is the real problem with MACRA and MIPS. There’s no clear benefit to doctor for participating in MACRA and MIPS. At least with meaningful use there was a clear $44k payment that they’d receive. MIPS is much more nebulous and it’s revenue neutral so doctors really don’t know how much they’re going to be paid for participating.

Certainly, there are a whole lot of other nebulous reasons why a doctor should participate including physician reputation damage, lower provider compensation, diminished practice value, and even the ability to obtain and maintain loans. Some of these are going to hit doctors in the face and it’s going to hurt. However, most practices aren’t thinking in these terms. It takes a pretty wide vision to see all of these potential issues.

What about the clinical value associated with MACRA and MIPS? The studies haven’t really shown much clinical value. There’s a lot of hope around what could be done, but not any clear evidence of the benefits. Especially the benefits related to the specific MACRA requirements vs using an EHR generally.

All of this leaves doctors I know upset with MACRA and MIPS. They wish it would go away and that the government would stop being so involved in their practice.

The challenge I have with this idea is that many blame MACRA and MIPS for everything that’s wrong with EHR use and implementation in healthcare. Let’s imagine for a minute that Congress was functional enough to pass a law that would get rid of all of MACRA. Then what? Would doctor’s problems be solved?

We all know that healthcare would still have plenty of problems. In fact, doing away with MACRA would do very little to alleviate the burden doctors are experiencing in healthcare today. They’d all celebrate MACRA’s death, but then they’d realize the impact would be pretty small.

I’m not suggesting that just because it would only have a small impact it shouldn’t be done. Healthcare got to where we are because we were unwilling or unable to make the incremental changes that would improve the healthcare system. Now the problems are so big and complex that they’re much harder to solve. I’m am suggesting that there are bigger fish to fry than MACRA.

That said, I would suggest an overhaul and simplification of MACRA. I’d suggest we take all the requirements and pass them through this question “What does this requirement do to improve patient care?” If this were the test, I think MACRA would look significantly different. In fact, it might mean that MACRA should really just be interoperability, ePrescribing, and a HIPAA risk assessment (which we could argue is already required by HIPAA). Imagine the value patients would get if we blew MACRA up and just replaced it with interoperability requirements which have no natural incentive in our current system. That’s something I think doctors could get behind.

At the end of the day, MACRA could be improved. It should scare us that very few doctors are fans of it. However, we also should be careful to not overstate MACRA’s impact on healthcare. There are plenty of other issues we have to deal with as well.

MIPS Twitter Roundup – MACRA Monday

Posted on December 11, 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.

As we near the end of 2017, I found a number of tweets from CMS and other people that I thought would be useful to those that are interested in MACRA and MIPS.

First up is this tweet from CMS that it’s not too late to still participate in MIPS and collect some performance data before the end of 2017. This is them promoting the Test Option which would allow you to avoid the 4% penalty:

Next up is a fact sheet from CMS which outlines the different between 2017 and 2018 when it comes to MACRA/MIPS. I particularly like page 6 of the document. As you go through it, you’ll realize why 2018 is going to be much harder than 2017.

Next up is a stat from MGMA. I’d be interested in learning about the 14% of practices that think that their value-based reimbursement is going to decrease. Are these people going to direct primary care? I don’t see it going down for almost anyone. What do you think?

Finally, Matt Fisher asks a question about whether MIPS should be voluntary. I don’t think they can make it any more voluntary given the current legislation and do any of us think that congress is going to take up this topic? I don’t. So, it’s kind of a moot point. However, there is a lot of doctor angst about MIPS/MACRA. I just don’t see enough of it to really move the needle on things. I think we’re stuck with MACRA/MIPS for the forseeable future.

MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

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.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.