Medicare Compliance & Reimbursement

You can likely expect worsening administrative burdens, CMS admits.

The newly released draft Quality Measure Development Plan (MDP) is a promising first step in moving Medicare from a volume- to value-based payment system. But even the Centers for Medicare & Medicaid Services (CMS) warns that implementation won’t be a bed of roses.

CMS itself has identified specific challenges that may arise when implementing the MDP, the American Academy of Orthopaedic Surgeons (AAOS) noted in a recent summary. These challenges include:

1.  Engaging patients in the measure development process;

2.  Reducing provider burden;

3.  Shortening the measurement development period;

4.  Streamlining data acquisition for measure testing;

5.  Developing meaningful outcome measures;

6.  Developing patient-reported outcome measures (PROMs) and appropriate use measures; and

7.  Developing measures that promote shared accountability across settings and providers.

Reducing the added administrative burdens on providers is indeed a great concern, said Don McCanne, MD in a Dec. 29, 2015 blog posting for the Physicians for a National Health Program (PNHP). CMS is not simply coordinating the quality reporting programs, but instead is expanding and enhancing them with the development of the new de novo measures.

Also, the Physician Quality Reporting System (PQRS), Value-Based Payment Modifier (VM) and Meaningful Use programs “were highly flawed programs adding significantly to the excessive administrative burden that characterizes the U.S. healthcare system, while having a relatively negligible impact on improving healthcare quality,” McCanne charged. “The worst policy decision would be to expand these programs and force them on everyone, but that is precisely what [CMS] did.”

What’s more: Some physicians no doubt thought that they could escape the Merit-Based Incentive Payment System (MIPS) burdens since the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) would allow physicians to move into Alternative Payment Models (APMs) — accountable care organizations, patient centered medical homes, etc.

Not so fast: “MACRA requires that the quality measures used in APMs to be comparable to the quality measures used in MIPS,” McCanne said. “MIPS is now an obligation no matter where you turn.”