The comment period for Medicare’s proposed rule on the Quality Payment Program closed last night, so as usual we’ll take this opportunity to share our full comments on the proposed updates to how Medicare shapes the path to a value-based future.

August 21, 2017

Seema Verma, Administrator

Centers for Medicare & Medicaid Services

7500 Security Blvd

Baltimore, MD 21244

 

Re:       CMS-5522-P: Medicare Program, CY 2018 Updates to the Quality Payment Program

 

Dear Administrator Verma:

Aledade partners with 205 primary care physician practices, FQHCs and RHCs in value-based health care. Organized into 16 accountable care organizations across 15 states, these primary care physicians are accountable for more than 190,000 Medicare beneficiaries. More than half of our primary care providers are in practices with fewer than 10 clinicians. We are committed to outcome based approaches to determine the value of health care. We are committed to using technology, data, practice transformation expertise and most importantly the relationship between a person and their primary care physician to improve the value of health care.

Creating a path for independent practices to thrive in the transition to value-driven health care

  • Whole hearted endorsement of the inclusion of “the preservation of independent practices as a guiding principle for the Quality Payment Program (QPP)”
  • Virtual groups provide a needed step on the path to transition to value-driven health care by allowing independent practices to come together for QPP even if they are not ready to take on the total cost of care
  • Virtual groups are part of the path to value-driven health care that must be carefully crafted to be attractive to independent physicians
  • The low volume threshold proposal leaves too much of the Medicare spend and therefore too many Medicare beneficiaries out of the program. We recommend that no more than 10 percent of the Medicare Part B spend should ever be excluded from QPP.

Measuring QPP performance and reducing administrative burden

  • We recommend that the cost category for total cost of care be included for 2018.
  • We recommend that the AAPM bonus move forward a year with bonuses earned in 2018 paid in early 2019 or even in 2018 itself
  • We recommend that CMS value simplicity and minimizing administrative burden above other characteristics of the all-payer determination for APMs

Below is a full explanation of those positions. Thank you for your consideration as we move together through this exciting time in health care. Please feel free to contact Travis Broome (travis@aledade.com) if you or your staff have questions or would like to explore these positions further.

Sincerely,

/s/

Farzad Mostashari, MD

CEO and Co-Founder, Aledade, Inc

Independent Physicians Thriving in Transition to Value

Principle of Independent Practice

It would be difficult to overstate the importance of CMS’s inclusion of the preservation of independent practices as a principle of the QPP. Independent physician practices have proven to be the most successful in accountable care[1] and key to maintaining competitive health care markets.[2] The same characteristics that make the independent physician practices successful also make this principle particularly challenging for CMS to deliver on. Physicians must feel the change in their practice. There is no board room in small practices where a government affairs team will explain slight tweaks in policy that increase revenue by a half a percentage point. The preservation of independent practice in QPP will be felt by CMS’s continuous effort to reduce the administrative burden of participation in QPP through technology, policy and measure design and a continuous effort to link performance with incentives as tightly as possible.

Virtual Groups

We support CMS’s proposal for virtual groups. CMS specifically asked for comment on several additional requirements for virtual groups. We do not believe that at the onset it is advisable to set additional standards on virtual groups. We recommend the following principles to guide CMS’s finalization of the virtual groups.

  • Voluntary election by physicians to be in a virtual group prior to the start of the performance year
  • Agree to work together to improve their performance in QPP
  • Must agree to be scored on quality
  • Can elect to be scored on
    • Clinical Practice Improvement Activities
    • Advancing Care Information
    • Resource Use
  • Can utilize any reporting method including Group Practice Reporting Option (GPRO)
  • Identify to CMS the officer responsible for the virtual group’s reporting
  • The virtual group is responsible for ensuring group reporting (i.e. CMS should not be responsible for aggregating the data across practices except in the area of resource use and other claims based measures)

CMS has proposed that all virtual groups would be scored on all categories as a group. We believe that this could be a limiting approach. For example, it would dissuade any virtual group from admitting members who do have 2014 Certified EHR Technology due to the effects on the advancing care information score.

Finally, we recommend that CMS allow third-party entities to organize and report for QPP on behalf of smaller practices. The practices making up the virtual group should not be required to manage this process internally.

Successful Transition to Value Based Care

We continue to work together with CMS to define a path that both transitions to value based health care and preserves independence.

It is helpful to remember what the path looked like just 5 years ago:

These are all huge leaps. First, physicians must take responsibility for total cost of care in a way they never had before. Second, they must take on a level of risk that could ruin an independent practice. Third, they must develop health insurance operations. The size of those leaps simply prevents many physicians from taking the next step.

Today, with the proposal in this rule for virtual groups the path looks more achievable:

With this proposed rule CMS has smoothed out the move from FFS to total cost of care. In prior regulations, CMS made incremental progress on the move from one-sided risk to two-sided risk. While not specifically for this regulation, we recommend a path to CMS that bases risk on the financial wherewithal of the participants in the total cost of care model and lets physicians move to Medicare Advantage to assume full risk without the burden of claims processing and network development. Our recommendations for the former can be found in the blog for the American Journal of Managed Care[3] and for the latter in the blog for Health Affairs[4].

Our recommended path is:

We believe this path is ideal for encouraging independent practices to continue to make the transition to value based care where they have proven they can succeed at all levels in various pockets of the county. We know they can succeed not just here and there, but in nearly every health care market in the country.

Low Volume Threshold

CMS has proposed to raise the low-volume threshold to exclude individual MIPS-eligible clinicians or groups who bill less than $90,000 Part B billing OR provide care for less than 200 Part B enrolled beneficiaries. We do not support raising the low-volume threshold, and recommend maintaining the current policy of excluding clinicians or groups who bill less than $30,000 to Part B or care for less than 100 Part B enrolled beneficiaries.

In the transition year final rule, CMS estimated that about 32.5 percent of providers would be exempt from MIPS because they do not meet the low-volume threshold, but the number of providers actually exempted for 2017 was higher than anticipated. The increased low-volume threshold creates an arbitrary cut-off for performance in the MIPS program without first assessing the impact of the current low-volume threshold on Part B providers. CMS should continue to transition a greater percentage of total Medicare spend away from fee-for-service to payment arrangements that account for quality, cost, and patient outcomes, rather than further reducing the number of providers eligible to participate.

Further, the modified threshold would mean that some clinicians who were eligible to participate in 2017 will be excluded from MIPS in 2018. We recommend that CMS extend the option for clinicians to voluntary participate in MIPS reporting in 2018 for a performance score and performance-based payment adjustment.  Clinicians who made investments and preparations to participate in MIPS during the transition year should not lose out on the opportunity to earn a positive payment adjustment in 2018.

QPP Measurement AAPM Determination

Resource Use Category

Aledade supports a transition to value-based payments that hold providers accountable for patient experience, quality of care, and total cost. By statute, in the QPP’s third performance year, the cost performance category must be weighted at 30 percent and the MIPS performance benchmark must be set at either the mean or the median score of all MIPS participants. Introducing cost performance into the MIPS score should be done incrementally, rather than creating a steep cliff from 0 percent weight in PY2 to 30 percent in PY3. Therefore, Aledade does not support reweighting the cost performance category to 0 percent of the final score, and recommends this category be weighted to at least 10 percent of the final score.

Measuring cost is an integral part of measuring value because clinicians play an important role in managing care so as to avoid unnecessary services. We appreciate the ongoing CMS efforts to better align the episode cost measures across programs and to better attribute beneficiaries to specialists for purposes of QPP. However, the lack of finality in these efforts should not slow the inclusion of total cost of care in QPP for 2018.

 

Aligning the AAPM 5 Percent Incentive with Action

Currently, a physician chooses to join an AAPM in the summer of 2017 (CMS’s 2018 deadline for the Medicare Shared Savings Program was July 31st), they participate during 2018, they receive their performance in the AAPM in August of 2019 and then they receive their lump sum bonus for participation in the AAPM in May of 2020. Almost three years have passed between a physician’s decision to join an AAPM and the reward for that decision.

When we talk to physicians about AAPM participation they naturally assume that since the 5 percent is contingent only on participation that they will receive the bonus in not May of 2020, but May of 2018 or even sooner. More than one physician has naturally assumed that the bonus would come January 1, 2018. Every minute explaining why this isn’t the case is a minute spent decreasing the likelihood of AAPM participation, the very thing Congress funded the 5 percent bonus to incentivize. While we understand that not all AAPM models require full year participation and therefore within-year bonuses may not be possible, CMS should explore every proxy to bring action and incentive as close together as possible. At a minimum, CMS should use the same year for the QP determination period and the claims period to pay out the bonus the year following participation. So in 2018 participation in AAPM would pay the 5 percent bonus in May 2019 based on the 2018 claims instead of May 2020 based on 2019 claims. To have the bonus for mere participation come seven months after the savings for actual performance in the AAPM strikes physicians as so backwards that it calls into question the credibility of the AAPM itself and negates the positive effects of the 5 percent bonus.

 

All-Payer AAPM Determinations

As members of the Healthcare Transformation Taskforce (www.hcttf.org), we worked closely with other health care providers, health plans, patient groups and health care payers to make recommendations on this area and we would refer you to those comments for the details.

In our comment letter, we want to emphasize the importance the health care providers place on the simplicity of this process. We do not desire to impose a high administrative burden on either health plans or on CMS in order to make the all-payer AAPM determinations. In this case, we would recommend that CMS value simplicity over every other characteristic of this program.

 

 

 

 

 

[1] http://www.nejm.org/doi/full/10.1056/NEJMsa1600142#t=article

[2] https://www.brookings.edu/research/making-health-care-markets-work-competition-policy-for-health-care/

[3] http://www.ajmc.com/contributor/travis-broome/2016/03/changing-stop-loss-formula-can-drive-interest-in-risk-based-models

[4] http://healthaffairs.org/blog/2017/07/06/spurring-provider-entry-into-medicare-advantage/

There has been no shortage of health policy news out of Washington in the past few weeks. Which means that one major announcement nearly slipped under the radar, but since this was the most relevant to Medicare, here’s our analysis.

Last week, CMS released a 1,058 page proposed rule to update the Quality Payment Program for 2018. The Quality Payment Program is the implementation of the Medicare and CHIP Reauthorization Act, passed in 2015 – one of the key pieces of legislation in the movement to a value-based health care system. We’ve talked about MACRA and CMS’s proposals to implement it before, so feel free to revisit our feedback on the Aledade blog.

Our key takeaway is that the rule is a win for small and independent primary care practices. That starts right near the beginning (page 9 to be exact), when CMS lays out the aims of the Quality Payment Program.

As the rule says:

“The Quality Payment Program aims to:

  1. Support care improvement by focusing on better outcomes for patients, decreased clinician burden, and preservation of independent clinical practice;
  2. Promote adoption of APMs that align incentives for high-quality, low-cost care across healthcare stakeholders; and
  3. Advance existing delivery system reform efforts, including ensuring a smooth transition to a healthcare system that promotes high-value, efficient care through unification of CMS legacy programs.”
    (emphasis ours)

“Preservation of independent clinical practice.” That new phrase guides not only this proposed rule, but should guide future program decisions as well. When CMS is looking at the best way to transition to value, they are committing to a key consideration of independent clinical practice.

Here’s how CMS puts that commitment into action in this rule: The rule sets up guidelines for virtual groups, allowing small practices to band together while keeping their independence. It preserves the excellent work CMS already did on the interaction between ACOs and MIPS, and adds some relief for small practices who are not yet ready for virtual groups or ACOs.

Let’s walk through some of the changes that are proposed:

  • The creation of a virtual group option for practices
  • Another year-long delay before cost performance becomes part of the MIPS score
  • Bonus points in the MIPS score for small practices (small defined as 15 clinicians or less)
  • Another year-long delay in the requirement to use 2015-edition certified EHRs
  • A significant increase in the low volume threshold to exclude clinicians from MIPS

The Stepping Stone of Virtual Groups

Virtual groups are a completely new option for physicians in 2018. The move to value-based care isn’t immediate. Not every practice can immediately leap into an ACO that puts them on the hook for any higher costs, especially if they want to stay independent. Some need a longer runway, and virtual groups create that option.

Here’s the proposed criteria for virtual groups:

  • A virtual group will be a combination of a solo practitioners or practices (defined as a single TIN) with 10 or fewer eligible clinicians who band together for at least one-year performance period. As of now, there are no geographic, size or specialty limitations on the groups (though CMS is open to comments on this).
  • The group’s participants need to send a written agreement to CMS by December 1, before their performance period starts.
  • At least one member of each participating practice needs to be eligible for MIPS, and the entire group will be assessed as a group on every MIPS category.
  • As the formation requirements are relatively light, these groups will be much easier to form and operate than a typical ACO with fewer responsibilities.

The purpose of creating virtual groups is to create a better path to valued based care. We believe it is worth taking a moment to review the current pathway, compared to the proposed pathway.

Here’s how the runway currently looks as providers move from the old fee-for-service system to two-sided risk:

MACRA Blog 1 pt2

 

In there are at least two major hurdles, especially for small, independent practices. First, the initial step out of fee-for-service and into one-sided risk. Practices want to band together in high-value networks, especially if there’s a chance to share in savings. But many practices don’t want to sacrifice their independence for a hierarchical ownership structure. That’s why we called for CMS to create “virtual groups” last year.

Second, the jump from one-sided risk to two-sided risk can be devastating to practice revenue. If a small, independent practice faces headwinds in one year, losses based on the total cost of care could be devastating. This is why the rule contains practice-revenue based risk. CMS created Track 1+ ACOs to take advantage of this revenue-based risk and they should roll that principle out to all two-sided risk ACOs.

Here’s what the proposed path looks like:

MACRA Blog 2

We’ll dive into this pathway more in a future post. Virtual groups are a key component to making the hardest transition between fee for service and accountability for total cost of care.

Delaying the Cost Factor in MIPS

CMS is proposing to delay the cost category in MIPS for another year. In the vacuum of a single year, this is no big deal. However, MACRA requires a certain transition to the cost category. So every year the transition is delayed, the cliff gets steeper. Right now, CMS is proposing to go from 0 percent cost in 2018 to 30 percent cost in 2019, trying to catch up to the law. There are consequences to kicking the can down the road.

Bonus Points for Small Practices

CMS is proposing 5 bonus points to the total MIPS score for small practices. Small practices are individual practices (defined by Tax Payer ID or TIN) with 15 or fewer physicians, nurse practitioners, physician assistants and other MIPS-eligible clinicians in the practice. The minimum threshold is 15 points, to ensure a practice is not penalized for 2020 based on 2018 performance. So these 5 points immediately get a small practices a third of the way there. This means that a small practice can avoid a negative adjustment in 2020 simply by reporting on at least two quality measures.

Delaying the Required Use of 2015 Edition Certified EHR Technology

Practices will be able to report on the advancing care information category with either 2014 or 2015 edition EHRs. While there are very important improvements to EHRs in the 2015 edition, we have seen firsthand the delays in rolling out 2015 edition EHRs to practices. CMS is proposing that rather than penalizing practices who don’t use the 2015 Edition, they would award 10 bonus points if practices do. As only 100 points are needed for full credit in the ACI category, this is a significant bonus. 

Increasing the Low-Volume Threshold – How Much is Too Much?

In this new proposed rule, CMS suggests they might raise that threshold even higher – from an initially proposed combination of $10,000 in Medicare revenue and less than 100 patients to this year’s proposal of either $90,000 of Medicare revenue or 200 patients. That means nearly half of all physicians could be exempt from this requirement. In other words, more than one out of every ten dollars spent by Medicare Part B. By significantly increasing the low-volume threshold, CMS risks slowing the transition to value-based care and, worse, create a two-tiered system of physicians moving forward opposed to those who are exempt and doing what they can to stay that way.

We believe that American health care needs to avoid a bifurcated or two-tiered system – one in which some providers are paid for improving quality and outcomes, and other providers stay in the old fee-for-service model with different incentives.

This proposed rule estimates that 70 percent of Medicare Part B dollars will flow either through MIPS or Advanced Alternative Payment Models.

That number can never go down.

Every patient deserves to be in a system of better care and lower costs, and every provider deserves to be rewarded for high value care. Instead of kicking the can down the road on cost and exempting more physicians, CMS should concentrate on making the program itself better. They make good strides in that endeavor with this proposed rule.

We will be working closely with our physicians and with other stakeholders to submit complete comments on the regulation in the weeks to come. We look forward to working with CMS on its commitment to move to value, and its clear commitment to preserve independent clinical practice.

In a Health Affairs blog post yesterday morning, Donald Fisher and Chet Speed from AMGA took a hard look at some of the obstacles on the path to value-based care. Building off a survey of their membership and a close look at the Billings Clinic in Montana, Wyoming, and the Dakotas, they found that it’s often tough for practices to get the right data at the right time. They worry that commercial payers aren’t moving as aggressively toward value-based payments – especially in local markets. And they say that reporting requirements are too burdensome.

They’re taking a clear-eyed look at many of the challenges that primary care doctors are facing every day as we move to a health care system that rewards high-quality care. But if we look too hard at the obstacles, we can miss some opportunities.

Here’s what we’re seeing at Aledade:

Commercial Payers are Gearing Up for Value-Based Payment

https://aledade.com/moving-ahead-with-payment-reform-in-commercial-markets/

Commercial contracts around value-based payments aren’t everywhere just yet, but they’re on the move. Take this recent analysis from Leavitt Partners –  Medicare may get the most attention, but a larger proportion of lives covered by an ACO come from commercial contracts, and they’re growing at a rapid pace.

Take two examples:

  •  Cigna established CareAllies, a service company that works with provider organizations of all types to improve patient outcomes and raise the quality and affordability of health care.
  • Humana has a well-established value path called the Accountable Care Continuum that moves its Medicare Advantage providers away from fee for service towards global capitation.

Right here in Aledade, we’ve been working with commercial partners – like Highmark and Blue Cross Blue Shield, covering more than 70,000 lives, to connect them with high-quality care through the physicians in our ACOs.

This kind of movement across the market empowers purchasers as well. Now they’re empowered to push their payers towards value-based contracting.

Reporting Requirements Absolutely Need Standardization

https://aledade.com/the-importance-of-quality-measures-for-accountable-care/

Just as important as standardization is a shift in focus. We and our partner physicians must focus on getting value out of measurement. Asking ourselves the question “How can we use this measure in our practice to ensure better outcomes for our patients?” No doctor wants to be filling out multiple, confusing and often duplicative quality reporting requirements and there is a lot of work to do in standardization. However, we need to do our part and shift our mindset from compliance to outcomes.

Data Access is a Solvable Problem

https://aledade.com/aledade-gets-the-data-flowing-to-pcps/

Fisher and Speed focus on accessing data, but that’s only the first step. We agree that practices need to get the data. That’s why, at Aledade, we focus on connecting to HIEs to deliver data to practices. But practices then need to derive insights from that data. At Aledade, we developed an app that integrates all of a practices’ clinical and claims data, giving doctors a full picture of their patients’ care. And finally, practices need to act on the data, as it guides them to deliver high-quality, coordinated care.

As we grow, Aledade continues to develop relationships with stakeholders throughout the national and local health care markets to equip our ACOs with the data they need. A big part of this is working with Health Information Exchange networks (HIEs) in the communities our ACOs serve.

They can even partner with other practices. One idea that’s started to take shape here is the idea of a virtual group – a group of physicians who can band together online to improve the quality of their care, and be scored as a group for the purposes of the Merit-based Incentive Payment System under MACRA. Our experience has been that these efforts do benefit from the economies of scale and a data “utility” that serves virtual groups and physician practices is an idea whose time has come.

Aledade is here to navigate these obstacles

https://aledade.com/growing-together-and-learning-from-our-partner-physicians/

We agree that these obstacles are real. We hear about them from our own partner physicians every day. But they don’t necessarily need to slow our journey toward a value-based payment system. Everybody needs a partner in this era – and a key part of the transition to value is that partnership doesn’t have to be driven by ownership, but can be driven by shared values and centered around the patient.

Whether it is a partner like Aledade who is transitioning practices from volume to value right now or partners like the recently announced support for the Quality Payment Program who help practices get ready for the transition to value, practices are not in this alone.

Last Friday, the Centers for Medicare & Medicaid Services (CMS) released the highly anticipated final regulations implementing the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA creates two value driven ways of interacting with CMS: Advanced Alternative Payment Models (AAPMs) and the Merit-Based Incentive Payment System (MIPS). Here is what you need to know about each. CMS listened to and responded to a vast array of comments from health care stakeholders. I believe the rule will move the country to where doctors are reimbursed for quality and value not volume. In creating a clear path for small, independent physicians to embrace the transition to value, CMS makes it possible for leading independent practices to reduce costs, boost outcomes, and thrive.

Advanced Alternative Payment Models: What You Need to Know

Most commonly taking the form of accountable care organizations and bundled payment initiatives, the defining characteristic that make an alternate payment model “advanced” is risk. Risk is usually simply defined as poor performance means I will have to write CMS a check. The critical question was how big does the check have to be to qualify. CMS originally proposed that the check had to be a percentage of the denominator in the model so in an ACO a percentage of total cost of care or in bundles a percentage of the total bundle price. Yet as we detailed in blog posts (here, here and here) as well as in our formal comments to the proposed rule this would have disadvantages smaller, physician-led groups that represent only a small percentage of the total cost of care.

Therefore, we are very pleased to see CMS simplify how they measure the amount of risk and relate it to the financial resources of those participating in the APM entity. CMS recognizes that not all APM entities have the same financial resources so it is impossible to use the same standard for all and claim that the risk is merely more than nominal for all of them.

CMS finalized for 2017 and 2018 that risk representing 8 percent of the Medicare Part A and Part B revenue received by participants of the ACO or other APM would qualify the APM as advanced. CMS also indicated that this could ramp up over time to as much as 15 percent in later years. This would ensure that participation in an AAPM always entails more risk than participation in MIPS, a goal we support.

Advanced Alternative Payment Models: What to Watch For

This is just the first step. Today no two-sided risk APM takes advantage of this motivational level of risk. CMS indicates in it regulation that updates to existing APMs are coming very quickly. In particular CMS talks about a MSSP Track 1+ that would take advantage of this lower risk track in time for physicians to be in it for 2018 which would affect their payments in 2020. We look forward to seeing CMS move quickly to catch their various models up to this final rule.

While not an issue for most ACO participants, physicians should be aware that they must have at least 25% of their Medicare Part B services or at least 20% of their Medicare Part B patients attributed to the APM to individually qualify for the 5% bonus payment. Nearly every primary care physician in an ACO model will easily push past these thresholds, but specialists and physicians in other models should be wary of this provision especially as it ramps up to 50% and 35% respectively in 2021 (reporting year 2019) and all the way to 75 and 50% in 2023 (reporting year 2021).

Medicare Incentive Payment System: Need to Know

CMS recognized that with 2017 starting in just two and a half months and calls 2017 what it was always going to be: a transition year. To successfully navigate the transition year there are two number to know: 3 and 70. 3 is how many points you need in 2017 to avoid any penalty in 2019. 70 is how many points you need to gain access to the $500 million exceptional performance bonus pool that Congress created.

MIPS is divided into four categories that total up to 100 possible points.

2017 Breakdown of Points by Category

Category

MIPS only Points

MIPS with ACO Points

Quality

60

50

Improvement Activities

15

20

Advancing Care Information

25

30

Cost

0

0

 

2018 Breakdown of Points by Category

Category

MIPS only Points

MIPS with ACO Points

Quality

50

50

Improvement Activities

15

20

Advancing Care Information

25

30

Cost

10

0

 

To get the 3 points you need only successfully report one measure for one category. This prevents any 2019 negative payment adjustments. A low bar to be sure, but you must interact with CMS in 2017 at least this much or you will receive a negative 4% adjustment in 2019.

Because CMS expects most physicians to at least report one measure, there will not be a lot of positive payment adjustments available under budget neutrality rule. This means most of the positive potential in MIPS is tied to the exceptional performance bonus pool. To access this pool, you must report at least 90 days preferably the whole year and earn at least 70 points. While it appears possible to get there while ignoring one of the categories other than quality this is not advisable. Each category has some built in low hanging fruit (for example you get 50% of the points in Advancing Care Information just for having 5 specific EHR capabilities) that should not be missed. Every organization should look into the three scored categories and plot their best way to get to at least seventy points.

To start you on that path, improvement activities is the easiest category and as mentioned you get 50% of the points in ACI just for fully implementation of your EHR. That is 22.5 points right there in MIPS only and 35 points in MIPS with ACO, certainly a solid base to start from. If you have done PQRS before, if you have done meaningful use before and certainly if you are in an ACO or other “non-advanced” APM then look into how you can be in that exceptional performance pool right away. If those things are new to you then take full advantage of 2017 as a transition year.

Medicare Incentive Payment System: What to Watch For

There are a lot of reporting submission options. Claims, registry, EHR, CMS web interface, CMS wants your data and they will take it however they can get it. If you are in an ACO your ACO quality reporting does double duty. If you aren’t in an ACO or ACO won’t be in its performance year in 2017 then you have to choose which option to use. The first consideration is what options are available to you. Is there a registry for your specialty, are you on an EHR those type of capability question. If you are capable of more than one, the second thing to keep in mind that each has its own benchmarks. So the benchmarks for CMS web interface are the same as the benchmarks used for the Medicare Shared Savings Program whether you are in an ACO or not. The benchmarks for EHR submission are based on past performance of those who submitted through EHR, etc. Benchmarks for most measures are published in advance and could influence your choice of submission method.

Bottom Line:

AAPM – Excellent news on right sized risk, but models that use it will come out in 2017

MIPS –   Must minimally interact with MIPS in 2017 to avoid penalty and if you are ready the bonus pool is within reach.