MIPS News from CMS
There is always new information about the Merit-based Incentive Payment System (MIPS) coming from the Centers for Medicare & Medicaid Services (CMS). Here is some of the latest and most relevant:
- If you participated in in 2017, your MIPS final score and performance feedback are available on the Quality Payment Program website. The payment adjustment you receive in 2019 is based on this final score. If you believe there is an error in your 2019 MIPS payment adjustment calculation, request a targeted review until October 15 at 8 pm ET.
- If you are interested in forming a virtual group for the 2019 MIPS performance year, the election period is now open. To form your group, you must follow an election process and submit your application to CMS via email (MIPS_VirtualGroups@cms.hhs.gov) by December 31.
- CMS published information recently on the 2018 MIPS quality measures impacted by updates to the ICD-10 codes. The agency has determined if a quality measure is significantly impacted by ICD-10 code updates by analyzing the 2018 measure specifications for codes that were deleted or added during the annual updates in October. If a quality measure is impacted by 10% or more ICD-10 code changes, the performance score for the quality measure will be based only on the first 9 months of the 12-month performance period for those identified measures. For more information, see “2018 MIPS Quality Measures Impacted by ICD-10 Updates Effective October 1, 2018”
Physician Group-Lead ACOs Save More Money
According to a recent study in the New England Journal of Medicine, physician group-led Accountable Care Organizations (ACOs) were associated with greater savings for Medicare; and these savings grew over the study period.
The authors said that Medicare Shared Savings Program (MSSP) participation was associated with differential spending reductions in physician-group ACOs. Spending reductions in physician-group ACOs ultimately constituted a net Medicare savings of $256.4 million in 2015, while spending reductions in hospital-integrated ACOs were offset by bonus payments.
Tips for Appropriate Billing When Patients Criss Cross Settings
In a recent report, the Office of the Inspector General (OIG) determined that Medicare inappropriately paid acute-care hospitals for outpatient services provided to beneficiaries who were inpatients of other facilities, including long-term care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities, and critical access hospitals. As a result, beneficiaries were unnecessarily charged outpatient deductibles and coinsurance payments.
All items and non-physician services provided during a Medicare Part A inpatient stay must be provided directly by the inpatient hospital or under arrangements with the inpatient hospital and another provider.
Some resources to help ensure correct, accurate billing include:
Quality Payment Program: Funding for Quality Measure Development
On September 21, CMS awarded seven organizations cooperative agreements to partner with the agency in developing, improving, updating, or expanding quality measures for Medicare’s Quality Payment Program (QPP). These cooperative agreements, authorized under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), represent the first funding initiative supporting public-private efforts to develop measures for QPP. Through these partnerships, CMS says, “We will work closely with external organizations to develop and implement measures that offer the most promise for improving patient care.”
Administrator Seema Verma says, “CMS looks forward to collaborating with these clinicians, patients, and other key stakeholders to identify quality measures that will meaningfully impact patient care. Through our Meaningful Measures initiative, CMS is committed to advancing measures that minimize burden on clinicians, improve outcomes for patients, and drive high-quality care. We need the expertise and firsthand experience of those on the front lines to develop measures that achieve these goals.”
This year, CMS removed or proposed to eliminate reporting requirements for 105 measures across programs, designed to save health care providers $178 million over the next three years. More than 400 measures remain.
QRURs and PQRS Feedback Reports: Access Ends December 31
The final performance period for the Value Modifier and Physician Quality Reporting System (PQRS) programs was 2016 and the final payment adjustment year is 2018. Quality and Resource Use Reports (QRURs) and PQRS Feedback Reports will no longer be available after the end of 2018. If you need these reports, download them through December 31, 2018. Click here for more information.
CMS Releases Revised Chronic Care Management Toolkit
CMS has recognized that providing chronic care management (CCM) services contributes to better outcomes and higher patient satisfaction but also takes provider time and effort. Therefore, the agency established separate payment under billing codes for the additional time and resources you spend to provide the between-appointment help of many of your Medicare and dual eligible (Medicare and Medicaid) patients need to stay on track with treatments and plans for better care.
CMS recently introduced a revised CCM toolkit based on partner feedback to provide better clarity and additional resources. Access the revised kit here.
Survey Says: Providers Not Confident About Prep for Malware, Ransomware
According to the 2018 Medical Device Security report, 27% of provider organizations said their security programs were substantial and fully functional; although almost half said these initiatives were implemented during this calendar year. At the same time, however, 18% of respondents said they have seen malware or ransomware infect or affect their medical devices in the past 18 months.
Few malware or ransomware incidents resulted in compromised health information or an Office for Civil Rights audit, respondents said. Nonetheless, they noted that they are were very concerned about this issue. Ultimately, less than half of respondents said that they are “very confident or confident” that their health systems’ current strategies were sufficient to safeguard their devices, protect patient safety, and prevent workflow interruptions.
While providers see data security as a top priority, survey respondents indicated that they face some hurdles. For instance, 96% said that manufacturer-related facts have contributed to their system vulnerabilities. Many respondents also said that managing outmoded operating systems and patching devices cause challenges.
Practitioner Burden, Patient Resistance Hinder EHRs’ Ability to Track SDHs
Some electronic health record- (EHR) based tools may help screen for and document social determinants of health. However, a new study suggests that they are more time-consuming for practitioners and of little interest to patients.
Practitioners and professional societies have endorsed the use of standardized social determinants of health (SDH), especially in settings where vulnerable patients are likely to have social and economic risk factors associated with poor health. However, the study in suggests that there are substantial barriers to implementing SDH in EHRs and may add a perceived burden for practitioners. At the same time, fewer than 25% of patients with a documented SDH need surveyed indicated wanting help.
Read the full study here. http://www.annfammed.org/content/16/5/399.full.pdf+html.
HIT Coalition Supports Amendment to Push for Information Blocking Update
Health IT Now, a coalition of patient groups, provider organizations, employers, and payers supporting the use of data and health information technology to improve healthcare, announced its support for a bipartisan amendment to the U.S. Senate’s Department of Defense and Labor, Health and Human Services, and Education Appropriations Act for Fiscal Year 2019.
The proposal (SA 3732), authored by Senators Sheldon Whitehouse (D-RI) and Bill Cassidy (R-LA), would require the Trump administration to provide Congress with an update on its progress establishing information blocking regulations required under the 21st Century Cures Act.
Health IT Now Senior Director of Government Affairs Catherine Pugh said, “Information blocking represents a senseless barrier to true interoperability and a continued threat to patient safety that must be addressed. Bipartisan majorities in Congress recognized this when they rightly added key information blocking provisions to the 21st Century Cures Act but, more than 600 days after its enactment, we are still waiting on these rules of the road to be released.” She added, “It is fitting that Congress would put oversight measures in place to ensure that the intent of 21st Century Cures is followed and that the administration upholds its end of the bargain.”
Social Media-Savvy Doc Shares Vision
Former hospitalist Zubin Damania, MD, whose alter ego, ZDoggMD, has a huge social media presence, is working to fix “today’s broken health care system.” In an interview with the Institute for Healthcare Improvement, he says that health care can and must be fixed; and he notes, “It’s happening now” and going in a direction he calls “Health 3.0.”
Dr. Damania says that Health 1.0 “was more art than science and deeply paternalistic.” Health 2.0, he suggests, was the era of managed care, quality measures, and electronic medical records that “turned all of us—doctors, patients, and the whole health care team—into commodities on the assembly-line of ‘Medicine-As-Machine.’” He explains that Health 3.0 “transcends and includes the best of 1.0 and 2.0 while restoring connections and the primacy of human relationships.” This new paradigm, he says, is long overdue.
Part of the change moving forward needs to include efforts to improve communication. Dr. Damania says, “Communicating is key, and we don’t do it well in health care. I think that’s the central reason we lost so much autonomy over the years, especially in this position as caregivers. We haven’t communicated with a good, clear voice. It’s time to connect in a way that will be visceral, but also intellectually honest.”
He suggests that the whole health care system requires a root cause analysis that will lead to “deep system change, deep culture change, and payment reform.” He stresses that “tweaking” the system isn’t enough; instead, he says, we need to “rethink it entirely.”