Healthcare

The previous installment of this blog series described the CMS Innovation Center and its mission to test innovative payment and delivery models and to implement the MACRA Quality Payment Program (QPP).

The QPP is designed to help achieve HHS’ goal of tying half of Medicare fee-for-service payments to quality or value through Advanced Payment Models (APMs) by 2018. Advanced APMs, one of the two tracks of MACRA, allows physician practices to earn more by assuming some financial risk related to patients’ outcomes. Certain Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program (MSSP), including the new MSSP Track 1+ ACO, qualify as Advanced APMs.

Rural hospitals have some tough decisions to make about their level of participation in the new CMS Quality Payment Program created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). 

For a number of reasons, the MACRA cards are stacked against small and rural providers. Given the limited number of Advanced Alternative Payment Models (APMs) that are being approved, many providers will start out in the Merit-Based Incentive Payment System (MIPS), and that track offers limited upside potential compared with APMs.

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?