¶ Changes to QPP, APMs, and ACOs
Welcome to Beyond the Stethoscope, Vital Conversations with SHP . I'm your co-host , Aaron C Higgins . On today's episode, Jason Crosby finishes his interview with me . As you may recall , in our last episode we talked about the final rule that was recently released by CMS the 2024 Quality Payment Program , or QPP .
Today , we'll finish up discussing all the changes that the program will see for APMs and ACOs in addition to the traditional MIPS . We'll also dive a little bit into the exclusion windows that are quickly closing . Are you ready for this Vital Conversation ? Let's get started .
We've got some backdrop , we've got some history , we know we've got to choose from 16 of them . Now we know what's , especially depending if I'm a GI doctor or whatever the case may be . Now let's get into the weeds a little bit , explain a little bit how it works exactly .
Yeah , so I've kind of hinted at it . At each MVP there will be pre-selected quality measures , improvement activities , cost measures that are applicable , and then what they call the foundational level , and that's the Promoting Interoperability , and then a new foundational level that they're calling population health . We'll cover that here in a second .
So let's go back to the Optimizing Chronic Disease Management MVP as our example , because it's a little easier to say so inside that , if you look inside that MVP , you'll find nine quality measures . You get to pick four of those nine . So right now , if you're doing ad hoc , you have to choose six this fewer to pick from .
Or if you're a small practice , so you have 15 or fewer clinicians , you only need to pick three . So that's great . Then you pick one high-weighted or two medium-weighted improvement activities from their approved list . Again , it's kind of a curated list of things that they think at practice in this specialty or this MVP would be doing .
Then , of course , the promoting interoperability assuming you don't exempt yourself from it and then you have to pick one population health measure . Which population health measures are a new thing in terms of definition , but they're not new in terms of what they are .
They're quality measures that have the population health category attached to them , because each measure has its own family that it lives in . So these population health measures , these will be done automatically through claims data , so they're going to be looking at it from a claims level and so you don't need to submit an extra quality measure . So that's nice .
Again , administrative burden lifted just a little bit .
That can be overwhelming , I guess , particularly if I'm not as acclimated , perhaps . So break that down a little bit . Why should I not feel overwhelmed ? Why does that not sound like a lot ?
Well , it sounds complex but it actually really is more simple than it is today . Like I said , this is a smorgasbord . We have this huge menu . It's kind of like going into Cheesecake Factory and you're just completely overwhelmed when they hand you a menu the size of the phone book . Imagine trying to pick that every year and go through that every year .
Well , that's kind of what you've had to do with QPP . You've had hundreds of measures , hundreds of recruitment activities , and then hope and pray to God that the right cost measures are associated to you , because you have no control over that , and so all of that worry kind of goes away .
You're instead offered a smaller menu in about nine or so , and it depends on the MVP . Some MVPs have an even smaller list of quality measures . So you have this nice little small list to pick from and you can be hyper-focused on those things . So it should be less overwhelming .
I like that . Little comfort there , little comfort . All right , I want to go back , because you mentioned a buzzword we hear way too much , but it's new to us . In terms of the MVP , you mentioned the new population health measure . Tell us a little bit about that .
Yeah . So to expand upon that , there's a handful of population health measures that exist today . So if you wanted to and you can you can go out to the QPP portal . You can pull up the list of all the quality measures and you can look in the category and you can look for population health .
It'll be those measures they will be pulling from for the MVPs and , again , these are going to be based off of claims data , because they're looking at more than just your care that you provide . They want to look at the care of the patient as a whole .
So it's almost more like a cost measure than it is a quality measure , and that's why they're giving it a new name population health measure . So you get a pick . So , unlike the cost , where you don't get to pick which ones , you do get to pick which one that they should look at for you .
But you yourself , you don't need to do anything and it'll all come from the claims data .
Oh , OK . Ok , that makes it a little bit more easy to digest . All right , Now let's switch gears a little bit . If someone does want to participate in MVP , either as a volunteer group practice or a clinician , how do they go about doing so ?
Well , the self-nominations . By the time this is heard again , it's closed . It closes at the end of November and that will be the case for next year as well . So my recommendation if you're hearing this for the first time and an MVP sounds interesting , you want to participate as an MVP ? Fantastic , cms would love to help you .
But the nomination window isn't going to open until the summer . So take a look at the MVPs , see if there's something that you want to participate in in 2025 , and start maybe modeling towards that , maybe for 2024, . Those are the measures that you submit in your traditional MIPS are the same ones that'll be in your MVP . Use 2024 as that transition year .
Again , you have a few years before it's mandatory , but I would suggest you get on board now . There's some benefit to that .
Yeah , good advice , good advice . Okay , let's switch to another three letter acronym here . What about those of our listeners who are in an APM and alternative payment model like an ACO ? Has CMS changed anything with those entities ?
Yes . So I suspect most of the listeners who are in an ACO or some kind of APM there's not a whole lot changing , but it's enough to cover but also those who are in traditional MIPS should continue to listen to , don't just turn us off or skip to the next podcast . We got a lot to cover .
¶ EHR Certification and APM Requirement Changes
So a particular interest certified EHR technology , or what we call CEHRT . That has changed . It was confusing . You have to have a 2015 CEHRT . Well , I mean , it's 2023 , 2015 . That was just a year that the certification was made and didn't necessarily exactly reference the fact that the last time the EHR was updated it got to be very confusing .
So CMS has said no more of that . Instead , if you want to participate in an APM , an ACO or traditional MIPS , you instead have to have a minimum version certification , which will be maintained by the Office of the National Coordinator for Health IT , called ONC . Onc has always done the certification , so that's not changing .
But going forward , they will now be the lone decider of what is a valid version of the EHR for QPP participation . So what that means ? They're doing away with their own versioning system anyway , because they're dropping the year from the certification number , which , again . It makes sense , because it was really confusing .
Instead they're going to a new numbering system and there's a whole release all about that . We won't get into that here Now . Cms will just point to ONC and say whatever version they're saying is the version you need to have , is the version you need to have for QPP . So that applies to everybody who participates in any form of quality .
They need to have whatever the latest required certified version is . I would recommend that you pay close attention and stay up to date on your updates . Furthermore , 75 percent of the participants in an ACO or an APM must be using CE HRT . The reason for that is you had a lot of APMs or ACOs that had providers not on EHRs at all .
They were on paper charts or they were on some really clucky home-built system that wasn't certified . It became a haven for those who were resisting converting to digital charts . CMS has sent no more . 75 percent was the whole number and now in order to participate in an APM , it must be 100 percent . That could be big .
If you're practice hiding out in an ACO still using paper charts , you will no longer be allowed to participate in the ACO , so bear that in mind .
That's a major decision point , that's for sure . Wow , yet another thing to keep track of . I've heard you say this over and over and I'm sure those who are listening have listened to you before have heard you comment . Is this just another thing that practices the admins and the docs have to keep track of with regards to the EHR version , or what ?
Well , yeah , certainly talk to your EHR vendor , make sure you have the latest and greatest of the CEH RT Before you submit and particularly before you enter certain reporting periods , particularly around promoting interoperability . So by June you need to make sure that you are using whatever the latest CEH RT certified version .
EHR what have you is running , because that's that promoting interoperability is tied to your CEHRT version .
Probably a good idea , as you're listening to this , getting in touch with someone in your office , or getting touch with your vendor as a suggestion . See where you're at , get a game plan together . So it's not last second . Any other ACO or APM updates that you want to tell our audience about ?
Yeah , this one doesn't apply to traditional MIPS because you already have to do promoting interoperability Now , going forward in 2025 , so you have one year to get used to it . Anybody participating in an APM must also report promoting interoperability . Some ACOs , some APMs have been exempt from that , for whatever reason . That goes away .
So just reach out to your APM coordinator or your ACO coordinator and ask them are you reporting promoting interoperability or do we have to do that ? That way , you can be prepared by 2025 .
Let's revisit . In past year , CMS has offered an incentive payment on the APM side , typically about 5 percent of the clinicians estimated payments for what I understand . How's that change at all ? Okay ?
Yes , it has changed , but I needed to find something first . It's that alphabet soup . So when a clinician participates in an APM , they receive a designation called Qualified Alternative Payment Model Participant or , as we abbreviate it , qp . That makes it easy . So this process is not going to change . It was in the proposed rule .
It was taken out , so they were going to actually make it harder to become a QP . They're changing it so those who are QPs now will stay QPs and those who meet the requirements can still follow the process that exists today . So clear as mud , I'm sure Now the incentive payment made to QPs is going to change .
So right now , reporting year 2023 means payment year 2025 , because we report our data in 2024 . It's evaluated and released in June , so you don't actually start receiving that 5% incentive until the following January 1 , 2025 . Got it ? So they're doing away with that . So 2023 is the last year that 5% .
You're still going to see it in 2024 if you qualified for it last year or if you're doing it this year , 2025 . So any new QPs starting January 1 , 2024 will not see the incentive . Instead , into performance year 2024 and beyond , existing QPs will still receive a higher Medicare or part of me fee schedule .
So the PFS called the qualifying APM conversion factor of 0.75% compared to non QPs . Non QPs will receive at 0.25 Medicare PFS update which will result in a differently higher PFS payment rate for eligible clinicians who are also QPs .
So you can be an eligible clinician , participate in an APM and still also receive some of the MIPS incentive payments is what it's saying here . So you can not double dip , but you can be double incentivized . Eligible clinicians who are QP for a year will continue to be excluded from certain MIPS reporting and payment adjustments for the year .
So this again clears mud . This is the change that's coming . If you don't know what the heck I'm talking about , it probably doesn't apply to you .
Well , it's too bad to see any incentive go away . You know that's something that's been influential for some folks , so it's too bad to see that going away .
Yeah , I hate seeing it , but it's been around since 2019 and we know Washington they take away all the toys .
Yeah , I try . All right , I know we've thrown a lot out there , but what else ? Any other updates or takeaways that folks need to know about as as they listen to this going on the 24 year ?
Yeah , so we didn't talk about exemptions or exclusions from the various categories , but you are quickly running out of time to file for those , if that is something that you qualify for . So if you've had a qualifying extreme or incontrollable circumstance , you have until January 2nd that's Tuesday , January 2nd 2024 to exclude yourself from MIPS 2023 .
There's a whole list on the website . It's qpp . cms . gov and you can go and you can click on the exclusions tab . There's a link on the bottom of the page and you can see if you qualify . So things like tornadoes , hurricanes , floods , fires , natural disasters , those sort of things can qualify . Other things don't .
So if you , let's say , you have a ransomware attack , that may not qualify , so be aware of that . So if you miss a significant chunk of 2023 and you can't hit your 75 points , look at that . That doesn't mean it means you're not going to get a payment , so your incentive is zero , but it's better than getting docked for it . Now .
The same goes for the promoting interoperability performance category hardship exemption .
There are certain criteria you must meet and so if , for whatever reason , you meet that , you want to get a zero on your promoting interoperability but you did fine on everything else , you can claim that and I'll put a link in the show notes specifically to that so you can go there and find out .
Now , that being said , small practices , which traditionally are 15 or fewer clinicians , according to CMS definitions , has traditionally , for the last few years , been exempted from promoting interoperability . So you could go and you could apply and you can say hey , I'm a small practice . Promoting interoperability is too difficult for me to achieve .
Cms started doing that a couple of years ago . They haven't said it's going away , but they also haven't released the exemption form for that yet . So be on the lookout for news if you're planning on that . Cms hasn't said anything , so I want it . Bet on it it may be going away , so just just bear that in mind .
Wow , that's a lot to keep track of . I know we probably have overwhelmed some folks , but that's again why we record this right . So , anyhow , great information , great conversation , aaron . We've done this for a couple of years in a row . I'm sure folks find it helpful . Really good information , as folks .
As Aaron suggested , feel free to look in the show notes for references . I want to thank you all for listening , and also to our guest and my esteemed partner , crime Aaron , who took a lot of time out to prepare for this and to present , and I wish you all a wonderful day . Thanks , aaron .
Yeah , you're welcome . You have a good one .
You've been listening to Beyond the Stethec ope, Vital Conversations with SHP . This has been a production of strategic health care partners .
Your hosts are Jason Crosby and me , Aaron C Higgins . This episode was produced and edited by Nyla Wiebe and social media content producers Jeremy Miller , the transcriber is Jason Crosby and our executive producers are Mike Scribner and John Crew .
For more information about SHP , the services we offer , including the back library of episodes , episode transcripts , links to resources that we discussed , and much more , please visit our website at shpllc . com . Thank you for listening .