Inside CMS’ 2020 Proposed Changes to QPP
What’s at Stake for Medical Practices in 2020 and Beyond?
CMS’ 2020 Proposed Rule for the Medicare Physician Fee Schedule calls for a number of changes. Most noticeably, the proposal includes increases in the performance thresholds and financial impact of the Merit-based Incentive Payment System (MIPS). It also includes changes that would enable clinicians to report on a smaller set of measures that are specialty-specific, outcomes-based, and more closely aligned to Alternative Payment Models (APMs) – the 2021 rollout of MIPS Value Pathways (MVP), an initiative intended to decrease reporting burdens and improve performance data quality.
And the financial stakes are higher than ever in 2020.
Case in point: A 100-physician organization with $10 million in annual Part B revenue that earns a high score could see as much as $600,000 in incentives — enough to support three fulltime nurses, a full suite of population health software and services, and 30 to 60 percent of the cost to run an MSSP Accountable Care Organization (ACO).
Understanding what’s at stake is the best way for a medical practice to get ahead and increase its chances of success.
What’s Next for QPP: MIPS & APMs
Tucked into the proposed rule were multiple QPP changes:
- The creation of the aforementioned MVPs, beginning with the 2021 performance year;
- An incremental increase in the MIPS performance threshold, starting with a raise from 30 to 45 points for 2020;
- The reduction in MIPS’ quality performance category to 40 percent in 2020, 35 percent in 2021 and 30 percent in 2022.
- The removal of 55 quality measures, along with the addition of seven new specialty sets that address the eligible clinician groups that were added in the CY 2019 final rule;
- An increase in the weight of MIPS’ cost performance category to 20 percent in 2020, 25 percent in 2021 and 30 percent in 2022; the inclusion of 10 new episode-based cost measures for implementation in 2020.
- Revised calculation of the “marginal risk rate” of APMs, making it easier for certain APMs to qualify as Advanced APMs eligible for the 5% Part B bonus and MIPS exclusion
- When quality reporting is not technically feasible for an APM subject to MIPS, grant an automatic credit of 50% of the MIPS quality category.
For medical practices, many of these proposed changes reflect the general trend of healthcare regulations. As demonstrated through initiatives such as the EHR Incentive Program, CMS frequently steps up its requirements as program participation deepens.
As expected, higher MIPS performance thresholds will lead to more competition among medical groups that want to achieve “exceptional performer” status — and avoid a negative financial adjustment.
But the MVPs are of special concern for providers — especially those who are already struggling to achieve CMS’ Triple Aim Goals — improving health, reducing costs and improving the experience of care. Many are already asking, ‘what would the standard mean to clinical workflows?’ ‘How would reporting among specialists change?’ and ‘how will this impact my organization’s bottom line?’
On the plus side, provider groups don’t have to worry about the MVP rollout until at least 2021, if it happens (proposals have been known to undergo extensive revisions before the Final Rule phase).
Still, the proposal of MVPs is worthy to monitor, because it reflects the agency’s shift toward a more holistic, high-quality patient experience, within the broader vision of value-based care. The goal of MVPs, according to CMS, is to reduce physician reporting burdens, like redundant data entry, while providing more performance data to patients (potentially including patient-reported outcomes or data obtained through a CAHPS survey). Under MVPs, clinicians would be scored based on the care activities they’re engaging in: In the case of diabetes, for instance, clinicians would be scored on their performance for a mandatory bundle of quality and cost measures across MIPS performance categories, so it would be easier for patients to compare two providers being graded on the same measures.
Getting to Work
While we have about two months until the proposals become law, practices can take a proactive approach in shaping their futures. Here are some of our recommendations for the next 30 days:
- Review Data. The 2018 MIPS feedback reports are available in the CMS web portal, so providers can download them. Make sure you understand what the report says and, more important, make sure agree with the data and score you received. If you ultimately decide that something isn’t right, request a targeted review by September 30.
- Reassess goals. Communicate with clinicians about results and where you want to go in 2019 and focus on setting those expectations and leveraging best practices.
- Analyze MIPS performance. Identify areas of potential score erosion, or lower trending scores, particularly in the Promoting Interoperability (PI) category.
- Download and comment. Review the 2020 Proposed Rule and consider what the changes to QPP would mean to your organization. Submit comments by September 27.
- Talk to vendor partners. Make sure your vendors are up to speed with the changes and what they mean to your organization: Do they offer webinars to keep clients up to date? Are they committed to making timely updates to their software to ensure timely reporting and compliance? These things matter.
Understanding what’s at stake for 2020 and 2021 is critical to planning for the future. The more prepared you are now for CMS’ potential changes in the pipeline, the better equipped you’ll be to adapt to regulations when they take effect.
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Tune in to hear value-based programs expert Matt Fusan and his guests discuss the challenges, opportunities, and best practices for thriving in the new era of value-based care (VBC). Topics include reporting under MACRA’s Quality Payment Program, either in MIPS or as an APM, as well as insights into value-based payer contracts, and best practices for improving care at lower costs. Matt and his guests will give keen insights and share real world experiences and use cases to help you drive success in VBC for years to come.
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