Healthcare

As we move into the third performance year of the Quality Payment Program (QPP), CMS is starting to take the training wheels off the Merit-based Incentive Payment System (MIPS). The threshold to avoid a penalty in 2019 doubled to 30 points, and the exceptional performance threshold increased to 75 points (up from 70 points in 2018).

January 20 is a significant date for healthcare providers—but not necessarily for the reason you think.

Yes, there is the inauguration of the 45^th President of the United States, who has vowed to “repeal and replace” the most significant healthcare legislation in recent history.

But that date has even greater significance for the many providers across the country who are struggling to cover the cost of care of an increasingly high-risk, low-income population.

We described in the previous installment in this series how recent case law and DOJ settlements provide clear evidence of the position of qui tam relators, prosecutors, and government experts that losses on hospital operation of physician practices are being targeted. Because evidence suggests that hospital losses on physician practices are common in many markets, the questions on everyone’s mind are whether health system losses on physician practices put the organization and key individuals at significant fraud and abuse compliance risk, to what degree can existing physician practice losses be justified through documentation, whether the health system has a functional Fair Market Value (FMV) and Commercial Reasonableness (CR) enterprise risk management process, and—the subject of this series--is a plan at the ready to begin mitigating practice losses?