Healthcare

Congress should repeal MIPS and replace it with a new Voluntary Value Program (VVP), according to a report released recently by the Medicare Payment Advisory Commission (MedPAC), the independent advisory agency tasked with making recommendations on Medicare policy.

By banding together into what CMS has termed “virtual groups,” solo practitioners and small medical groups can take advantage of significant flexibility currently available to help them succeed in the Merit-based Incentive Payment System (MIPS).

In Part 1 of this series, we answered some FAQs about these MIPS virtual groups. In Part 2, we share items to consider before joining a virtual group.

Small physician groups and solo practitioners take heart: CMS wants you to be successful in the Merit-based Incentive Payment System (MIPS) without having to merge or be acquired.

It is important to recognize that the road to long-term success does not end with the implementation of the Merit-based Incentive Payment System (MIPS). In CMS’ own words, MACRA’s final rule was established, in part, to incentivize and promote participation in Advanced Alternative Payment Models (APMs). These incentives include a 5% participation bonus from 2019 to 2024 and a 0.5% annual increase above the MIPS track beginning in 2026.

I've just returned from the National MACRA MIPS/APM Summit in Washington, D.C., where the overarching discussion centered on how to create and implement strategies that pay physicians fairly, while controlling spending in the Medicare program. It's a question we've wrestled with for almost 20 years and a challenge we must solve.

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?

Virtual healthcare is a godsend to struggling healthcare systems as they try to offer the right care in the right setting. Every day, these systems face enormous pressure to provide both high-quality and cost-effective healthcare to their communities. Their clinics are filled with scheduled patients, while others wait for a “work in.”

In our earlier blogs on the MACRA Final Rule with Comment Period (Final Rule), we have been discussing a series of topics from the Final Rule, especially those with changes since the Proposed Rule earlier this year.

MACRA created the new Quality Payment Program (QPP), comprised of two avenues to reward delivery of high quality care: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). After the May 9, 2016 release of the Proposed Rule, the feedback on the imminence of the MIPS implementation was less than fully supportive. On September 8, CMS’ Acting Administrator, Andy Slavitt blogged about the agency’s new flexibility with respect to the implementation of MIPS, and the “Pick Your Pace” moniker made it to the Final Rule, published earlier this month.