October 24, 2017

Medicare Quality Payment Program Under Fire

By
The American Hospital Association steps in; the American Medical Association steps up.

On Sept. 27, 2017, the Centers for Medicare & Medicaid Services (CMS) announced that it would not update its overall hospital quality star ratings in October 2017, as planned. This was primarily based on the public's feedback, but the star ratings released last December will remain on the Hospital Compare website until the next update. The American Hospital Association (AHA) has been very vocal in suggesting that the current proposed Medicare Quality Payment Program (QPP) that began Jan. 1, 2017 is misleading. That program required that physicians who are eligible participate in either the Merit-Based Incentive Program (MIPS) or the Alternative Payment Model (APM). Those eligible that did not elect to join either program will receive a 4 percent penalty in their 2019 Medicare reimbursement.

As of Oct. 4, 2017, for those using the MIPS program, there are two requirements: a) clinicians are required to document care for patients and record data; and b) the performance reporting period that opened Jan. 1 closes Dec. 31. The final deadline for submitting complete data is March 31, 2018.

The good news is that the American Medical Association (AMA) outlined a “10 Key Steps Action Plan” for 2017 for MIPS. The steps include:

  • Step One: Determine whether MIPS Applies to You
  • Step Two: Review Available Performance Categories
  • Step Three: "Pick Your Pace" for MIPS Participation
  • Step Four: Review Your Data
  • Step Five: Decide Whether to Report as Individual or a Group
  • Step Six: Identify Your Reporting Mechanism
  • Step Seven: Perform a Security Risk Analysis
  • Step Eight: Report for at Least 90 Days (CMS Deadline was Oct. 2, 2017)
  • Step Nine: Complete MIPS Performance CMS (Deadline was Dec. 31, 2017)
  • Step Ten: Submit 2017 MIPS Data

What are the three major challenges facing the industry at this time?

  • Most recognize that fee-for-service reimbursement payments will not survive, but are sensitive that "bundled payments" and electronic health record (EHR) punitive models have not survived.
  • Providers do not understand the new QPP program and are sensitive as to when to embrace the new model seriously. The change in U.S. Department of Health and Human Services (HHS) leadership, with the departure of Tom Price, has also raised questions as to whether the new payment method will change.
  • EHR systems (as sophisticated as they are today) are not prepared to report data.

Regardless, for now, the AMA recommendations allow providers to track their progress based on their guidelines, CMS deadlines, and successful adoption of MIPS.
Lyman Sornberger, MBA

President and CEO for LGS Health Care and Chief Health Care Strategy Officer for Capio Partners. Prior to his roles at LGS Healthcare and Capio Partners, Sornberger was the Executive Director of Revenue Cycle Management for Cleveland Clinic Health Systems (CCHS) from 2006 – 2012. This role comprised of the Revenue Cycle Management for all 11 Cleveland Clinic Health Systems Ohio and Florida Hospitals and 1,800 Foundation Physicians. His responsibilities included all CCHS Patient Access Services, Health Information Management and Billing. Prior to his affiliation with CCHS Mr. Sornberger was with the University of Pittsburgh Medical Center for 22 years as a leader in revenue cycle management. Sornberger is a graduate from the University of Pittsburgh with a BS and Masters Degree in Business.

Related Stories

  • CMS Issues RADV Blueprint for Handling Flawed Documentation
    New CMS document features gems that fill risk adjustment voids for coding rules. Coders love rules. In risk adjustment coding, we live by the Official Guidelines for Coding and Reporting, the ICD-10-CM conventions for code lookup, and the AHA Coding…
  • Sexually Transmitted Disease Awareness
    CMS encourages providers to talk, test, and treat STDs. When it comes to sexually transmitted disease (STD) awareness, the Centers for Medicare & Medicaid Services (CMS) is encouraging providers to take three simple steps in protecting their patients through talk,…
  • News Alert: MS-DRG Changes Prevalent in IPPS FY19 Proposed Rule
    Expansion of new ICD-10 codes has slowed. The 2019 Inpatient Prospective Payment System proposed rule covers many Medicare Severity Diagnosis-Related Groups (MS-DRGs) changes, in addition to changes to the Value-Based Purchasing (VBP), Hospital-Acquired Conditions (HACs), and Hospital Readmission Reduction program,…