Monday Musings

Last week I talked about the passage of legislation that finally got rid of the annual “Doc Fix” crisis, averting a 21% decrease in Medicare payments to eligible professionals by creating an incentive payment program referred to as the Merit-Based Incentive Payment System (MIPS). MIPS consolidates all the current incentive programs so, not surprisingly, it will assess the performance of eligible professionals in four categories: quality; resource use; EHR Meaningful Use; and clinical practice improvement activities.

  1. Meaningful Use. Current EHR Meaningful Use requirements, demonstrated by use of a certified system, will continue to apply in order to receive credit in this category.
  2. Clinical Practice Improvement Activities. This new component gives credit to professionals working to improve their practices and facilitates future participation in Alternative Payment Models (APMs).
  3. Resource Use. The resource use category will include measures used in the current Value Based Modifier (VBM) program. CMS is developing a methodology to identify resources associated with specific care episodes including a method that would allow professionals to report their specific role in treating the beneficiary (e.g., primary care or specialist) and the type of treatment (e.g., chronic condition, acute episode). This process addresses concerns that algorithms and patient attribution rules fail to accurately link the cost of services to a professional. This methodology could be very important to wound care providers. Resource use measurement would also reflect recommendations on how to improve risk adjustment to ensure that professionals are not penalized for serving sicker or more costly patients. I hope the wound care community is beginning to get the message that post hoc vetting of outcomes to make healing rates appear better than they are – simply by not reporting the patients who do badly—does NOT actually help anyone’s performance look better. To prevent sleight of hand maneuvers like post hoc vetting, CMS requires that outcomes be risk stratified. We have got to properly risk stratify patients in order to report “healing rates” in relation to how sick patients are. That’s the only way to fairly evaluate a physician’s performance—what % of the hardest to heal patients do they heal?
  4. Quality. Measures used for this performance category will be published annually in the final measures list. In addition to measures used in the existing quality performance programs, the Secretary of Health and Human Services will solicit recommended measures and fund professional organizations and others to develop additional measures. Measures used by Qualified Clinical Data Registries (QCDRs) may also be used to assess performance under this category.

How will this work? Every year, the Secretary, through notice and comment rulemaking, will publish a list of quality measures to be used in the forthcoming MIPS performance period. Eligible professionals will select which measures on the final list to report and be assessed on. Eligible professional organizations and stakeholders will also submit quality measures to be considered for selection (and identify and submit updates to the measures already on the list). The law directs CMS to include input from all stakeholders when selecting quality measures, not just providers. The quality measures selected for inclusion on the final list will address all five of the following quality domains: clinical care, safety, care coordination, patient and caregiver experience, and population health and prevention.  Qualified clinical data registry measures will be automatically included in the first program year’s final list of quality measures. These measures will remain in the MIPS program unless they are removed under the rulemaking process. This is incredibly important news for wound care EPs since the only quality measures we have are to report are available through a QCDR.

Next week I will tell you how this translates to payment.