Oncology & Hematology Coding Alert

The Oncology Care Model APM offers 2 participation options. Smart practices should weigh them carefully.

While most eligible clinicians (ECs) will participate in the standard MIPS track, some may also participate in a MIPS-based Alternative Payment Model (APM). Others could be eligible for the advanced APM track, which allows ECs to avoid MIPS reporting altogether.

Seems like a good thing, right? Maybe, maybe not, according to Mike Schmidt, director of client certification and success at Medflow.

"For oncology, there is a far more natural path to select the APM tract of the QPP than there is for some other specialties," says Schmidt. The Oncology Care Model (OCM) ACO offers two tracks:

• An advanced APM option with dual-sided financial risk (upside and downside). This model would place you out of the MIPS track entirely.
• A nonadvanced APM option with upside financial risk only. This lower-risk model still requires participation in the MIPS track, but you'd receive bonus points for participating in the APM.

The benefits to participating in the nonadvanced APM are clear. "You're still subject to MIPS payment adjustments but with special scoring rules. You get preferential MIPS performance scoring and your cost is not scored at all," says Schmidt.

For the advanced APM track, you should carefully weigh whether that is the best option for your practice. Many ECs don't want to deal with the hassle of MIPS, so they figure that participation in an advanced APM is obviously the way to go. Not so, says Schmidt. "In determining the track that you want to be on for the QPP, the key decision point is to not just consider the financial impact from the MIPS program alone, but to also be aware of the financial impacts of the other [APM] program," advises Schmidt.

With the advanced APM track, you won't have to deal with the mechanics of MIPS reporting. However, the financial incentive is less-a maximum of 5 percent, whereas in MIPS you could get up to 9, plus a possible exceptional performance bonus.

And remember, with an advanced APM, it's not just the bonus you need to worry about-there's dual-sided financial risk. "You could have a negative adjustment," warns Schmidt. "Congress wants to contain Medicare costs by moving you onto that [APM] track. They have a sort of darker reason to get you onto that track, so be aware of that."

If the payment adjustment is all you're worried about...

Keep in mind there are other ramifications. "If you're on the standard MIPS tracks, your own specialty outcomes are going to be published on the Physician Compare website, which is presumably a good thing," notes Schmidt. But in an APM, there are no specialist outcomes that are scored or published. "That could be a negative impact for patients that are comparison shopping," warns Schmidt.

If you think the APM track will be less of a hassle ...

Think again. You won't necessarily spend fewer resources by going the APM route. "Even if you're in an APM entity you still need practice resources to deal with the QPP, your ACO, and performance and improvement activities," notes Schmidt. "It's not like you're getting out of MIPS entirely."

If you're attracted to an ACO for the referrals ...

Consider an affiliate status in the ACO "in order to get their referrals without actually being a participant," recommends Schmidt. That way "you could control your own destiny under standard MIPS scoring if that's what you want to do."

Resource: For an in-depth coverage of Quality Payment Program updates for CY 2108, see the story on page 1.