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Tina Colangelo

Tina Colangelo

Friday, 15 December 2017 17:51

Under The Value-based Umbrella

MACRA is an evoluntionary process that will take place over many years. There are many moving parts under the value-based umbrella that are vital to the business models of  healthcare organizations across the country. To excel, they must understand and implement all of the moving parts to stay ahead of the competition. Under the value-based umbrella, you will find MACRA requirements, patient engagement, clinician/organization public reputation, and chronic care management. It's not enough to just learn the first component of value-based care-MACRA's requirements to stay ahead of the game. Since the environment is soley based on winners and losers, public reputation becomes equally important. Patient engagement must also be a focus, as the overall goal of all value-based programs is to make our healthcare system patient-centric. All of the parts must move together-not just one. If your organziation is not focusing on the other components, your business model will be out of balance and so will your bottom lines. Chronic care management ties the moving parts together and helps finance restructuring investments that meet the needs of  value-based care business models. 

There are many resources available that can be used to help understand what seems like endless requirements of MACRA. To list them all would be time consuming. Healthcare organizations can start at the qpp.cms.gov website. It's free and easy to navigate. Healthcare organizations need to find creative ways to engage their patients. Don't be afraid to borrow marketing ideas from companies such as Southwest Airlines. The reality is that healthcare was always a business. Patients just didn't pay as much. Now that they are paying almost forty percent more in health insurance premiums, it is.  Healthcare was also never patient centered until the emergence of value-based care programs. Value-based care forces providers to rely on their patients participation in their own healthcare, just to get reimbursed by Medicare.  Essentially, the patient-provider relationship strengthens as they work as a team. Financial incentives are becoming popular among health plans and medical practices in an effort engage patients to make healthier choices. Financial incentives are not the only way to engage patients. A simple acknowledgement of a patient's birthday will do. Praise is also free and goes a long way. 

Just like consumer reviews and social media are vital to the success of any business, healthcare is no exception.  Medical practices, health plans, and hospitals will now need to market their practices to the public on social media. Patients are living longer and look on the internet to find new doctors, specialists and hospitals. More importantly, the Centers for Medicare and Medicaid (CMS) will now display all eligible clinician's MIPS composite performance scores on physiciancompare.gov. Patients  will be able to comparison shop, before choosing a provider.  With an estimated 10,000 patients joining Medicare a day, healthcare organizations are going to want new business. Large groups such as hospitals will negoiate big salaries and pay bonues to employed clinicians with the highest scores because after all, their reputation is on the line. 

So, as the first performance year comes to a close, we see that only focusing on MACRA's requirements can be detrimental as it's only one moving part. Going forward, all moving parts are needed in order to prosper in the value-based care landscape. 

Monday, 13 November 2017 15:52

MACRA's Final Rule 2018: 3 Things To Know

Clinicians participating in the Merit-based Incentive Payment System (MIPS) probably spent the month of October collecting performance data, in hopes to avoid the four percent penalty and earn an incentive. Many may have been too busy to notice that the Centers for Medicare and Medicaid Services (CMS) had actually released the 2018 Quality Payment Program (QPP) Final Rule a day late. While MIPS 2017 has been deemed the transitional year, it was expected that CMS would up the ante in 2018, which they did, in the quality and cost categories. Clinicians can expect the bar to rise even higher, in years to come as their performance improves and patients become healthier. Here is three things to know for 2018.

For those who may not know, MIPS was developed to become increasingly demanding. It has to if it's going to reach its primary goal of delivering quality care at lower costs. This is why is 2018, the performance threshold is set at 15. In order to avoid the five percent penalty, clinicians will need to earn a score of 15 points. This will take more effort than just submitting one measure on one patient to avoid the penalty. In fact, CMS is estimating that seventy-five percent of clinicians will earn a score of over 70 in 2018. This could become problematic for practices that just avoided the penalty in 2017 because if everyone is scoring that high, it will be almost impossible to be able to keep up with them in 2019. Strategy is key to success in 2018.

In addition, clinicians need to know that the MIPS eligibility threshold has been expanded to less than or equal to $90,000 in Medicare Part B charges or 200 or fewer Medicare patients. This means that clinicians may not be eligible to participate in the second year of the program even though they may have participated in the first year of MIPS. Clinicians are encouraged to use the lookup tool located on the qpp.cms.gov website to ensure their MIPS eligibility status in 2018. Clinicians do have the ability to volunteer to report which could be helpful with perfecting strategizies for future years of the program without the penalties. 

Finally, CMS has added new quality measures in 2018. Clinicians who may not be scoring high on measures they picked for 2017 (check with your EMR or data/QCDR registry) are encouraged to review this list prior to 2018. There may be new measures that better fit your practice. Keep in mind, that topped out measures can only earn a maximum of 7 points. Clinicians may opt to re-strategize which six measures to submit for quality in 2018. 

In 2018, we not only see higher penalities and performance thresholds, we also see major competition between the clinicians who have embraced MIPS in 2017 and are performing better and the ones who haven't. Unfortunately, the resistance will show up in their scores for the world to see. With about 7 weeks left in this year, there is still time to pool your resources together, develop a MIPS strategy and be successful in 2018! 

The last day to start collecting data is October 2, 2017. That is only thirty-one days away. It is crucial to take action now and schedule a MACRA practice assessment. At the very least, these four questions need to be answered:

1. Which payment track will I participate in 2017, the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (AAPM)? Noncompliance will result in a negative 4% penalty to all Medicare Part B charges in 2019.

2. Which pick your pace option are you most comfortable with? Your participation options are: Test pace (submit something), Partial Participation (submit data for at least 90 days), Full Participation (submit data from for a full year), or Advanced Alternative Payment Model? All eligible clinicians must choose one option in order to avoid a negative 4% penalty to Medicare Part B charges in 2019. 

3. Do I want to report my performance data as an individual or as a group? Both participation options have pros and cons. 

4. Which submission type is best for my practice? Electronic Health Record Direct (EHR Direct), Qualified Registry, Qualified Clinical Data Registry (QCDR), Claims (indivdual only), or Web Interface (groups of 25 or more)?

The answers to these four basic questions help to shape a successful MACRA strategy. Next steps in the process include:

  • Evaluating your past performance in Physician Quality Reporting System (PQRS), Meaningful Use (MU) and Value-based Modifier (VBM)
  • Assessing your practice resources to maximize your performance score
  • Developing MACRA systems within your organization to ensure optimal performance under MACRA

These are just some of the necessary steps to take to restructure your business model to meet the needs of the value-based reimbursement world we are all living in. The steps take time. I don't recommend doing them in haste or worse, skipping steps in order to save time. The deadline for collecting data will be here before you know it. It is best to take action now because your performance matters!

On June 20, 2017 The Centers for Medicare and Medicaid (CMS) released the highly-anticipated 2018 Quality Payment Program's (QPP) proposed rule. The 1,058-page document shows how well CMS had listened to clinician feedback requesting more flexibility, less administrative burdens and most importantly, additional opportunities to earn bonus points. 

Here is a sneak peek at what you will need to know:

  • The low volume threshold has been expanded to $90,000 Medicare Part B charges and 200 patients. This helps clinicians who may or may not be ready or do not have the resources yet to participate in MIPS. This would exclude 134,000 clinicians from MIPS in the 2018 performance year. I would encourage any clinician who does not meet the low volume threshold to take the opportunity to practice submitting all perfromance data to CMS anyway, as excluded clinicians can test their systems without getting penalized. It is a good position to be in. 
  • The 2014 EHR certification edition will suffice for those not ready to upgrade their electronic medical record systems (EMRs). Those who choose to upgrade will receive ten bonus points under Advancing Care Information (ACI) category.
  • Eligible clinicians who can demostrate rate of improvement in performance between 2017 and 2018 can receive up to 10 points in the Quality category.
  • Eligible clinicians who care for sicker patient populations will be granted a one-time special consideration, of up to 3 bonus points, becasue of patient noncompliance due to their illness.
  • Virtual groups reporting becomes an additional reporting option for smaller practices. This reporting option helps smaller practices compete with larger organizations in MIPS.
  • Hospital-based physcians can report on quality and cost categories within their facilities. This will help lessen administrative burdens.
  • Cost category takes a backseat for another year worth 0% in 2018 however will skyrocket to 30% in 2019. Cost should never be ignored despite being worth 0% in the first two years of MACRA.

It's not surprising that in 2017 MIPS has been the most popular reimbursement track of MACRA's QPP. One thing to keep in mind is that other Advanced Payment Models (APMs) will be available to participate in for 2018 performance year. They are Medicare ACO Track 1+, Next Generation ACO and Comprehensive Primary Care Plus (CPC+).

This doesn't mean complacency. It means that you are given time to restructure your business model and get up to speed. 

MACRA is the tidal wave that has hit the medical community. Yet many physicians and healthcare clinicians don't understand how beneficial or how devastating this can be for their business. Physicans need to find the balance between patient care and their bottom lines. The new MACRA system is shrouded in secrecy, mainly because providers don't know what to expect. It has proven to be both complicated and overwhelming to most people in the healthcare industry. But covering your eyes and ears in fear will not make MACRA disappear. It's understanding the reasons for the shift from fee for service to value-based care and the requirements for MACRA that will help the medical community adapt to this change and not be so fearful. 

The reason for this change is that the traditional fee for service model (volume) no longer works. It does not reduce costs or patients symptoms. The Centers for Medicare and Medicaid (CMS) are requiring providers to take on some percentage of risk for patient outcomes. Providers who deliver high quality care and lower costs will be rewarded. However, providers who deliver low quality care and increase costs will be penalized. 

Here is what expected from providers under MACRA. There are two different reimbursement tracks that physicians will fall under: Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (AAPMs). In MIPS, providers are required to pick their participation pace, identify measures that apply to their practices and decide how to report the measures to CMS. In 2017, providers can pick their participation pace. 

Option 1- Submit something, one quality measure on one patient and one imporvement activity to avoid the four percent penalty in payment year 2019

Option 2- Submit data for partial year, report measures for a minimum of 90 days for a small payment adjustment in 2019

Option 3- Submit data for a full year, starting January 1, 2017 through December 31, 2017 for a moderate payment adjustment in 2019

Option 4- Participate in an Advanced APM

Providers will need to report measures across four performance categories in MIPS. The categories are Quality, Advancing Care Information (ACI), Improvement Activities (IA) and Cost. Each provider will earn a composite perfromance score (CPS) based on their performance in each of the categories. Each of the four categories are weighed differently. With each performance year the weights of the categories shift. In 2017, the weights in MIPS are Quality (60%), ACI (25%), IA (15%) and Cost (0%). There are four ways that providers can report data to CMS in MIPS. Data can be reported by used a qualified data registry, qualified clinical data registry (QCDR), electronic health record or CMS Web Interface for groups 25 or more. Groups who would like to use CMS Web Interface need to register by June 30, 2017.

A second path affecting how providers are paid under MACRA is advanced APMs. Apms are innovative payment models that are geared towards reducing costs and imporving quality. They can be episode-based or condition-based. MACRA offers a 5% lump sum payment to providers who participate in APMs. The eligibility requirements are:

1. Use quality measures comparable to measures under MIPS

2. Use certified electronic health record (EHR) technology

3. Assume a financial risk or is a medical home expanded under the CMMI

The most important thing to remember is to be prepared. MACRA is something to hit the ground and run with instead of trying to wait out the changes. Waiting out the changes will make it difficult and your practice will be trying to play catch up while the other practices have been reporting to CMS. 

Friday, 03 March 2017 00:11

Ready or Not, MACRA is Here.

Clinicians have the same look on their faces every time I turn around. They look like they have lost their puppy. It usually comes after I inform them that they will now be penalized for non-compliance in MACRA. Despite being deep into the first quarter of the MACRA race, there are a high percentage of clincians who still have not heard of MACRA. Or if they have heard of it, do no know what it is. Hitting the pause button will only instill feelings of regret later on. The clinicians who comply will start to reap the benefits that MACRA provides. The others will be left behind and lose money. 

The Centers for Medicare and Medicaid (CMS) has deemed the performance year of 2017 a transitional year for many reasons. The primary reason is because the complexity of the final rule (2,378 pages) is very hard to understand. With that being said, making the transition from fee for service to value-based care is not something that can happen instantly. There is a ton of restructuring to be done in order to meet the needs of the program. Investments need to be made in order to do well financially. The return of investment will not be overnight either. It will come in the payment year in 2019. 

Realistically speaking, having a strategic plan on how to comply with MACRA is vital to success. Tracking your performance throughout this transitional year of 2017 is important to ensure the strategy is working. If no, change it. You can afford to be somewhat flexiable in 2017. Starting in 2018, all clinicians must report performance data for 365 day. This is why strategic planning is key in 2017. 

Sunday, 19 February 2017 16:09

Now Trending: Telehealth Visits

The new trend in primary care and chronic care is telehealth. A medical practice considered living in the dark is one who is digitally disconnected. If your medical practice is not offering telehealth medicine it's going to lose revenue.

Patients are looking for convenient ways to communicate with their medical office, especially since technology allow for it. Patients want the option to use technology to schedule  appointments, pay medical bills and have lab results sent by email. Telehealth is rapidly growing in popularity. A recent Jackson Healthcare survey found that 50 million Amercians are ready to switch their primary care providers for one that offers tele-visits. The survey also reported:

  • 79 percent of consumers caring for an elderly parent would prefer a multi-channel video telehealth service
  • Parents of children under 18 are willing to switch to a doctor with telehealth abilities
  • 67 percent of adult 45-64 would prefer to manage their chronic conditions online    
On the flipside, telehealth services are beneficial for the medical practice as well. Administrative responsibilites are reduced. The practice receives higher reimbursement rates by coding 2017 chronic condition management (CMM) codes and telemedicine codes. Lastly, it directs more business to the medical practice. Forward thinking medical practices understand the importance of being digitally connected. Why wouldn't anyone want to take advantage of more revenue and happier patients?
 

This is the most important performance cateogry in MIPS. The quality category is the old Physican Quality Reporting System (PQRS). 

 

Friday, 17 February 2017 06:06

MACRA Update: Virtual Groups

Small group practices have another option to participate in MACRA's MIPS. Find out what joining a virtual group can do for you!

Friday, 17 February 2017 05:46

It's a Value-based World! Here's Why!

Explains why fee for service has shifted into value-based care. Play video for your staff so they can understand why there is just a massive change to our healthcare system.

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Empire Radio Interview with Tina Colangelo

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