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Richard Kane Discusses Challenges With MIPS


The Merit-based Incentive Payment System (MIPS) is a big program designed to be applied to all clinicians, which makes it complex to figure out how to do right, explained Richard Kane, senior director at Avalere.

The Merit-based Incentive Payment System (MIPS) is a big program designed to be applied to all clinicians, which makes it complex to figure out how to do right, explained Richard Kane, senior director at Avalere.

The American Journal of Manage Care® (AJMC®): What are the biggest challenges practices are facing when implementing MIPS?

Richard Kane (RK): I think the fact that it’s a mandatory program for most clinicians and it has a lot of different measures for them to look as the program is design for all clinicians. So, you have a set of quality measures, and some of them apply to you and, in some cases, you have the opportunity to pick which ones can apply to you. There are the cost measures, at least in the initial vision, and there are just multiple episode measures that may be implemented—some of them will be attributed to them, some of them won’t. So, there’s a lot of uncertainty, I think, as the clinicians just try to figure out all the different pieces and what of all the different pieces they have to focus on.

AJMC®: What requirements of MIPS do you think community practices might have the easiest time meeting? What aligns with what they are already doing?

RK: I think CMS has been very helpful to some clinicians who are a little concerned with transitioning to this type of payment system. And they have made it much easier to avoid negative payment adjustments. So, there is, in many cases, the ability to simply avoid negative payment adjustment by reporting on quality measures. So, there is not a big leap in performance required to suddenly avoid the threat of negative payments.

AJMC®: With MedPAC recently recommending that Congress repeals MIPS, what do you think the future holds?

RK: The present is a good guide to the future. Congress recently has made some changes to MIPS. Congress recently took out a statute which allowed CMS to not increase the weight of the cost component of the MIPS composite score. So, by statute, the MIPS [cost] component was going to have to be worth 30% of the MIPS composite score, Congress, in the balanced budget agreement, gave CMS the flexibility to go at a slower pace. CMS has also made changes to, again, go at a slower pace. So, I think we’ve already seen that going at a slower pace is something that CMS has been willing to do, and something Congress is also willing to do.

AJMC®: What changes do you think need to be made to MIPS?

RK: I think there’s a lot of uncertainty about the cost component. There was a lot of concern about it—at one point in the initial rule it had 60 potential episode cost measures, then there were 10, then there were none. And there has been an indication that there are some coming, so I think there’s just a lot of uncertainty about the cost component.

AJMC®: With first results of the Oncology Care Model (OCM) now available, what has been the reaction from OCM-participating physicians in the community on the first performance period?

RK: I think reactions vary depending on who you talk with. I don’t think they all had the same reaction. We have heard things such as concern over the way attribution works. So, that’s always a concern with a lot of episode payment models—that was a concern with ACOs [accountable care organizations]. If you’re a physician, you know the patients that you treat, and then understanding how some of them are aligned to you in this patient model and some of them aren’t is always a big challenge and something that they want to figure out.

AJMC®: If they have concerns about who is being attributed to them are there ways to address those concerns with CMS moving forward?

RK: Yes, potentially there is. CMS has attempted to provide more data to OCM participants. I know that has been one thing that we’ve also heard from participants is that they are pleased that the amount of data that they’re getting from CMS has improved. So, that’s one way of addressing it. The other way with discussion with participants and understanding their concerns. And then, also, with other payment models, there has been adjustments to methodologies of whether it’s better to know prospectively who your patients are or whether it’s better to just have them attributed retrospectively or some combination. So, the ACO programs when they first started with Medicare struggled with that same question and created different payment tracks that lended to different purposes.

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