There’s no doubt that Medicare’s payment for physician services is moving toward a value-based system, and many other healthcare payers are following that lead.  CMS[i] is mandated under MACRA to implement value-based payments.  So far, most radiology practices are struggling to comply with the MIPS branch of the two-pronged MACRA system but the goal of CMS is to eventually move all physicians to the other branch, Alternative Payment Models (APM). 

Begin by Working Within MIPS

The transition to the APMs can begin while the practice is still working within MIPS.  For example, participation in specific MIPS Improvement Activities (IAs) will position the radiology group to become part of an APM at the appropriate time.  One IA solution that is readily available to radiologists is the ACR’s Radiology Support Communication and Alignment Network (R-SCAN™).

R-SCAN is a collaborative action plan that brings radiologists and referring clinicians together to improve imaging appropriateness based upon a growing list of imaging Choosing Wisely (CW) topics developed by the ACR.  It prepares radiology practices for a future of value-based payment models by allowing radiologists and referring physician practices to fulfill IA credit requirements.

Reducing inappropriate imaging seems like the best way for radiologists to get started in value payment programs.  According to an article in the ACR Bulletin, the chair of the ACR MACRA committee (and HAP client) Dr. Gregory N. Nicola agrees, "As ACOs mature, they will need to look deeper to find ways to save, and they're going to look at inappropriate imaging. Participating in R-SCAN now can show an ACO that your radiology group is proactive and already managing imaging patterns.  It's better to be early than late to this game, because ACOs may find ways to control imaging utilization without you — and then you're a commodity.“

Partner With Other Physicians

Radiologists can partner with primary care doctors who are motivated to avoid ordering inappropriate imaging.   This has the added benefit of preparing the practice for Medicare’s rule that will require ordering physicians to use a Clinical Decision Support (CDS) system to consult Appropriate Use Criteria (AUC) beginning in 2020.

There are also opportunities to enhance the radiology group’s relationship with other hospital-based physicians, such as those in the Emergency Department.  The ED physicians may be participating in their own Emergency Quality Network, which is a Support and Alignment Network (SAN) complementary to R-SCAN. 

Pros and Cons of APM Participation for Radiologists

Improving patient care is the real reason for participating in any quality improvement program, but the considerations that arise before embarking on a project like this include a financial component, whether it is enhanced reimbursement or penalty avoidance.  A statistic available from the Harvey L. Neiman Health Policy Institute in 2017 reported that only 20% of ACO’s existing at that time had any radiologist participation.  Until collaborative programs such as we have described above are implemented, inappropriate imaging will not be reduced and therefore participation in shared savings for radiologists will be minimal.   

Conclusion

Dr. Nicola reminds us in another ACR Bulletin article, “It’s important for radiology groups to know there will be a redistribution of Medicare payments from groups that don’t make value-based changes to groups that do.”  Currently most groups are participating in MIPS, at least to the extent that they will avoid a payment penalty.  Learning how to maximize reimbursement under MIPS while preparing for APM participation is the strategy forward-thinking radiology groups will adopt. 

Read and subscribe to our radiology RCM blog for more information and techniques for becoming fully engaged in the value-based payment system.

Richard Morris is the Director of Value-Based Strategy at Healthcare Administrative Partners. 

[i] GLOSSARY of acronyms used in this article:

CMS - The Centers for Medicare and Medicaid Services

MACRA – The Medicare Access and CHIP Reauthorization Act

APM – Advanced Payment Model

MIPS – Medicare Incentive-based Payment System

ACR – American College of Radiology

ACO – Accountable Care Organization (these will become APM’s as time goes on)

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Perspectives on Patient Care and Complexity for Radiology Practices

2018 Budget Bill Makes Changes to MIPS

How Removing IVC Filters Benefits Patients and Radiology Practices Alike