For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost. Several factors have combined over the past few years to change the goal for radiology practices – it is now ‘penalty avoidance’ rather than a reward for reporting quality metrics. As we outlined in our recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.
QPP Strategy for Radiology in 2023 on December 20, 2022
Today's Quality Payment Program (QPP) began in 2006 as the Physician Quality Reporting Initiative (PQRI). It was a voluntary program that would earn participants a bonus payment of 2% of their prior-year Medicare reimbursements. Beginning with performance year 2013 (for payments in 2015) a penalty was imposed on those physicians who did not successfully report quality data. The 2016 performance year saw the initiation of the Value-Based Payment Modifier (VM) that allowed for upward, downward, or neutral payment adjustments in 2018 based on both the quality and cost of care delivery. In the first year the VM was applied, physicians with low cost and high quality earned an additional 9.78% over the basic Medicare fee schedule while the potential negative adjustment for not reporting, or not successfully reporting, was 6%. There was a lot of incentive to participate in the program at as high a level as possible!
What Will the MIPS Value Pathways Option Mean for Radiology Practices? on September 21, 2022
Beginning in 2023, physicians will have the option to report under the Medicare Quality Payment Program (QPP) using MIPS Value Pathways (MVP) in lieu of the traditional reporting methods. MIPS, the Medicare Incentive-based Payment System, started gathering performance reports in 2017 and in 2019 the first Medicare payment adjustments were made based on that 2017 reporting. Eventually traditional MIPS reporting will be phased out, but the Centers for Medicare and Medicaid Services (CMS) has not proposed a timeline for doing so.
What’s In Store for Radiology In The 2023 Medicare Proposed Rule? on July 19, 2022
The Centers for Medicare and Medicaid Services (CMS) press release announcing the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2023 highlights expanded access to behavioral health services, Accountable Care Organizations (ACO), cancer screening, and dental care. Of these areas, cancer screening could be important to radiology practices, but the news was not good – CMS declined to include CT colonography coverage while it expanded coverage for traditional colonoscopy. The MPFS regulates the Medicare fee schedule payment provisions as well as the Quality Payment Program (QPP).
Quality Payment Program Modified Due to COVID-19 Outbreak on March 24, 2020
The Centers for Medicare and Medicaid Services (CMS) announced that they have adjusted certain aspects of the Quality Payment Program (QPP) in response the Public Health Emergency (PHE) caused by the COVID-19 coronavirus outbreak. CMS has extended the deadline for reporting 2019 Merit-based Incentive Payment System (MIPS) data and has relaxed the criteria for avoiding a penalty in 2021 based on submission of 2019 data.
Quality Payment Program Update for 2020 on March 2, 2020
Participation in the Quality Payment Program (QPP) means that you always have several years’ information in play at one time. The score you earned from submitting 2018 data will now be impacting your Medicare reimbursement in 2020; you have just completed your 2019 performance and it’s time to submit your data; and finally, you now have to begin your 2020 performance year.
Get Feedback on Your 2018 Quality Payment Program Performance on August 23, 2019
The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website. The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results. According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold.
CMS Releases a New Resource on the MIPS Cost Category on June 24, 2019
Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient. The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring. This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.
Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along. One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams. This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021. This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.
Update on MIPS Reporting and Payment Adjustments for Radiology on March 25, 2019
The year 2019 marks the third reporting period under the Medicare Incentive-based Payment System (MIPS). Radiology groups’ performance this year will determine their positive or negative Medicare fee schedule adjustment for payments in 2021, just as this year’s Medicare payment adjustment was determined by performance in 2017.