COVID-19Merit-Based Incentive Payment System (MIPS)RiskValue-Based Health Care
June 26, 2020

The Fallacy of “Relief”: The Dangers of MIPS Extreme and Uncontrollable Circumstances Applications

Under the banner of “relief,” CMS has announced that clinicians will have the opportunity to file an Extreme and Uncontrollable Circumstances  application to qualify for re-weighting in some or all components of the Merit-Based Incentive Payment System (MIPS). This possibility may sound intriguing, but don’t be fooled—those who take this route are overlooking the longer-term consequences of maintaining and expanding MIPS efforts. MIPS Is Not Going Away The day before releasing 2020 MIPS flexibility guidance, CMS announced the creation of the Office of Burden and Health Informatics, which has grown out of the Patients Over Paperwork initiative. In this notice…
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ACO ReportingCOVID-19RiskValue-Based Health Care
May 6, 2020

The Interim ACO Rule Explained: A Pause, Not a Reprieve

As the coronavirus pandemic continues to upend health care in the U.S., pressure has mounted on CMS to adjust its efforts to drive providers to adopt risk. In response, at the end of last week CMS announced a carve-out of COVID-19 patient expenses from certain reporting requirements. In this round, ACOs were on the receiving end, being largely excused from remaining 2019 reporting and 2020 enrollment obligations. True to our predictions, this will slow, but not reverse CMS’s ultimate agenda to push providers to manage under risk. Those who interpret the Interim Rule as a reprieve will do so at…
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Future of Health CareRiskValue-Based Health Care
March 11, 2020

Value-Based Care Defined: Know the Vocabulary of Health Care Reform

Today, as we confront a viral threat that is challenging our health system, its capacity, and how care is financed, it seems appropriate to review some fundamentals. Health care reform has been speeding down a particular track, changing how health care is covered, paid, delivered, and organized. These reforms may seem to be about health care financing, but will make a future difference in health care access and patient outcomes. Medicare is driving the train with its huge budget and rulemaking capabilities. But insurance companies, in lockstep, are rapidly implementing similar changes. Understanding all those changes is no easy task.…
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Artificial IntelligenceFuture of Health CareRiskValue-Based Health Care
January 29, 2020

Can Artificial Intelligence and Machine Learning Reduce Health Care Costs?

All the experts’ 2020 health care technology predictions have one trend in common—more Artificial Intelligence. AI and its subset Machine Learning are tagged as the winning ticket to advances not only in clinical medicine and research, but also in administration and management. The hype promotes so many potential applications for AI that it begs for an answer to one of its key claims: Can AI reduce health care costs? I'm referring particularly to Artificial Intelligence that is beyond clinical medicine and new medical technology. AI focused on clinical medicine, from genomics to the latest radiology and cardiology diagnostic capabilities, uses…
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Future of Health CareRiskValue-Based Health Care
January 22, 2020

Can Hospitals Still Lead Health Care Under Risk?

As the millennium's third decade begins, Risk has taken hold as THE strategy for tackling health care costs. Virtually overnight (in health care years) the industry has moved—albeit not uniformly—to accept Risk. This transition is already beginning to impact hospitals and hospital-based systems, and raises serious questions about the viability of their role as the primary financial engine bankrolling health care operations, reforms and modernization. Just one year ago, the concept of provider risk in Accountable Care Organizations (ACOs) was anathema to most participants. Despite initial misgivings, however, most ACOs remained in the system after CMS pushed forward with its…
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Future of Health CareRiskSpecialty Physicians
August 7, 2019

Risk Payment Models Will Fuel Growth of Equity-Backed Physician Practices

Risk payment models present a daunting challenge to the very cultural of medicine—for most physician practices. Physicians identify their practices as clinical enterprises more than businesses, although some have managed to achieve success solely by being excellent clinicians in their fields. Patients, however, are quick to see the flaws along with higher costs—hence complaints about customer service, poor billing practices, and difficulty communicating. But clinical practice success, up until now, has been measured by the yardstick of Fee-for-Service reimbursement: higher incomes through patient volume and services. Hospital purchasers of physician practices adopted the same benchmarks of success. Even as hospital…
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Alternative Payment Models (APM)Merit-Based Incentive Payment System (MIPS)Quality Payment ProgramRisk
July 31, 2019

A MIPS Rewrite is Certain: CMS Proposed Rule for the 2020 Quality Payment Program

The CMS Proposed Rule for the 2020 Physician Fee Schedule and changes to the Quality Payment Program picks up where the “Pathways to Success” ACO rule left off. This time, the “Pathways” shake-up is aimed squarely at MIPS, in the form of “MIPS Value Pathways.” We’ve described the growing frustration with MIPS, specifically MedPAC’s report to Congress on its concerns that MIPS is overly burdensome and complex, and doesn’t translate into better care. That theme repeatedly shines through the 1,704 page proposal. CMS is using this rule as an initial salvo indicating that MIPS as we know it is headed…
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ACOsBundled PaymentsFuture of Health CareRiskValue-Based Health Care
May 22, 2019

Can Provider Risk Cure High Medical Costs?

Fee-for-Service (FFS) has been on a slow march toward risk-based reimbursement for two decades. But FFS has proven to be remarkably resilient—until now. In the last six months, Medicare has doubled down on creating new provider risk models for ACOs, specialists and primary care physicians. All of them have methods to ensure that providers are held accountable for medical expenditure targets. Wait. Haven’t we been here before? What‘s different between now and the 1980s, when HMOs and provider risk first prevailed in the market—and then were purged as both ineffective and unpopular? Is provider risk a cure for high medical…
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ACOsPerformance ImprovementRisk
April 17, 2019

Bootstrapped ACOs Facing Risk? Adopt Cost Strategies With Long Term RoI

The experimental phase of Medicare ACOs has been officially declared dead, per CMS. Going forward, ACOs must agree to take on financial risk for expenditures beyond their targets. That’s sobering news for the majority of ACOs still struggling to succeed. The reality is that most ACOs are bootstrapped—light on extra funding and dependent on existing tools to do more. In fact, about two-thirds of ACOs report that funding is their most significant challenge. And that is probably understated, since patient engagement problems (also reported by two-thirds of ACOs) and lack of data (reported by 40 percent) are remedied by solutions…
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Population HealthRiskValue-Based Health CareWomen and Health Care
February 6, 2019

Higher Risks, Worse Disease, Fewer Choices: Health Care Fails African American Women the Most

No matter how we measure disparity in health care for women in the U.S, African American women stand out. Across the board, they have higher risk factors for disease and poorer outcomes, including much higher mortality for many conditions. African American women contract cardiac disease and cancer at a younger age and, often, in worse forms. Their risk of maternal death after giving birth is three or four times greater. Health care for African American women is complicated by racial and gender prejudices as well as by poverty and inadequate insurance coverage. But even among African American women who are…
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