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MIPS 2020, MIPS consultants, MIPS reporting, MIPS data submission, QPP MIPS, MIPS 2021, MIPS Value Pathways, MIPS consulting services, MIPS Quality measures, QPP MIPS 2020

P3Care Investigates: QPP MIPS 2021 Proposed Rule

CMS (The Centers for Medicare and Medicaid Services) released the proposed rule for QPP MIPS 2021 via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM).

In this article, we will be dissecting changes that are expected in MIPS 2021. However, keep in mind that the changes are just proposed until now and are not final yet.

Each year, CMS proposes various guidelines to facilitate physicians with their payments.

How MIPS consultants take care of the administrative data to report to the authorities affects revenue management.

As a physician, your first responsibility is towards patients. We are sure that you certainly would not have time to manage the MIPS reporting requirements.  However, with the help of MIPS consulting services, the process of MIPS data submission becomes easier and less hectic.

Besides the accurate data reporting, we also have to understand the QPP MIPS requirements every performance year.

What can we expect in the MIPS 2021, and how it will impact the data submission process.  Let’s follow-through.

But, first, we must analyze the COVID-19 Impact!

2021 QPP MIPS might come with challenges. We can expect time delays (which we also experienced during MIPS 2020 performance period).

The implications of the pandemic are going to go a long way with us. For Instance, CMS asks physicians to focus on quality care rather than volume care. However, with the pandemic, there was no choice left other than catering to the volume of patients while being careful and value-driven to every extent possible.

We are expecting a delay in MIPS Value Pathways (MVPs) for 2021.

Additional reporting flexibilities are also in consideration in response to the COVID-19.

MIPS Value Pathways (MVPs)

The proposed rule stated that MIPS Value Pathways (MVPs) will be delayed until 2022.

However, they will be available as options, and eligible clinicians can choose to report through them alongside the other MIPS data submission options.

APM Performance Pathways

Participants of MIPS APMs are allowed to report via APPs, which function the same as MVPs.

CMS is also considering sunset the current APM score standards in 2021.

Keep in mind that only the following audience can use APPS.

  • Individual eligible clinician
  • Group (TIN) or APM Entity
  • MIPS APM participants

The above-mentioned specialists have the option to use APP, but it is compulsory for ACOs participating in the Medicare Shared Savings Program to report quality performance via the APP.

The performance category for the APP will be scored as follows upon the fixed set of quality measures.

Quality Category: Weighs 50%. It contains six measures that focus on population health.

Improvement Activities (IA) Category: Weighs 20%. CMS will automatically assign its score based on the requirements of the MIPS APM.

All APM participants reporting through the APP will earn a 100% score for 2021.

Promoting Interoperability (PI) Category: Weighs 30%. Compulsory for all QPP MIPS data submissions.  It is reported and scored at the individual or group level.

Cost Category: Weighs at 0%

Moreover, it is also automatically used for the Medicare Shared Savings Program (MSSP) quality scoring.

QPP MIPS Program Updates

For MIPS 2021, various data submission options will be given to MIPS consulting services to help eligible clinicians get through the program.

Physicians have the option to report QPP MIPS as:

  • Virtual Group
  • Solo eligible Clinicians
  • Group
  • APM Entity

Note that the virtual group has the highest hierarchical priority when CMS receives multiple scores for it.

APM Participation

Participation through APM participation is available for eligible clinicians. They can report QPP MIPS data for both Quality and Improvement Activities (IA) performance categories.

Moreover, you can select and report MIPS Quality measures in the same manner as eligible clinicians choose and report for QPP MIPS.

However, generally, the APM Entity group calculates the performance for the Improvement Activities (IA).

The Cost category has a slight change in the data reporting mechanism. If you do not report this category via APP, the APM Entity Group will automatically score it.

The above-mentioned are the little details that QPP MIPS participants must know beforehand they enter the MIPS 2021.

MIPS Quality Measures 2020, MIPS incentives, MIPS Quality measures, MIPS data submission, MIPS quality reporting, submit mips data, MIPS registry, healthcare Solutions, MIPS 2020, MIPS consulting firm, MIPS consultant, MIPS data via clinical quality measures, MIPS solutions, MIPS CQM

MIPS Quality Measures 2020 and Specifications for MDs and DOs

Am I eligible for MIPS incentives in 2022?

The question that we hear a lot. And, I have to say it is your right to know.

Whether you are a general physician or a surgeon, submission of MIPS Quality measures leads the way to incentives.

Why?

The government started MIPS back in 2017 to incentivize eligible clinicians, and in return, improve the quality of healthcare. In short, it ensures ECs submit measures for the good of their patients – they will have permanent access to quality care.

The purpose here is to write down a MIPS Quality measures list that includes at least some measures and leave the rest to update in the future. Therefore, you’ll see some of them if not all; we’ll keep updating it, hopefully.

I also hope to provide info not only for family and general physicians but for specialists too. In an ideal system, the MDs, and DOs work in rhythmic harmony for better care coordination and patient experience.

Difference between an MD and a DO

For those of us who don’t know what an MD is, it is short for Medical Doctor, while DO stands for Doctor of Osteopathic Medicine.

Although both of them may use all the available methods to treat their patients, including drugs and surgery, DOs believe in a more holistic approach. DOs emphasize preventive medicine, musculoskeletal health, and holistic care. It doesn’t mean MDs are any less skilled or something like that. Both are equally capable.

The Expertise of Both Specialists

Both specialists, MDs and DOs, can choose to practice in any specialty. Both lend their expertise to promote the quality of healthcare to patients translating CMS MIPS quality measures.

AMA (American Medical Association) studied that in 2018, up to 57% of more DOs preferred to practice in primary care compared to 32% of the MDs.

The total statistics for DOs participation in primary care were:

  • 9% went for family physicians
  • 8% went for internists
  • 8% went for pediatricians

However, both programs offer a license, thus, it does not matter what program a student pursues.

Define the Quality Performance Category

One of the categories of the Merit-based Incentive Payment System (MIPS) is the Quality performance category! It holds a 45% weight in the total score.

What does it account for?

It measures your performance in clinical activities and patient outcomes. MIPS data submission through Quality measures helps assess health care processes, manage results, and patient experiences. As a result, we can expect the highest quality of care while keeping expenses to a minimum. Hence, the achievement of the value-based care purpose.

Understanding CMS MIPS Quality Measures

  1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) 

Diabetes, a menace, to say the least, shadows quite a part of the US population. How can we put a lid on it? Well, the answer lies in value-based care. More importantly, it is MIPS quality reporting that will eventually decrease the number of diabetics across the country.

This particular measure says to submit data on your patients from the age of 18-75 with diabetes who had hemoglobin A1c > 9.0% during the measurement period.

A CMS eCQM is available for this outcome measure. The collection types for this measure include:

  • Medicare Part B Claims
  • eCQM (electronic-clinical quality measure)
  • CMS Web Interface
  • MIPS CQM (clinical quality measure)

Since one of the collection types of this measure is MIPS CQM, you can submit it through a registry. It is one of the most effective of all the MIPS data submission methods thus far.

You can submit it if you are part of the following areas, provided you fulfill the low-volume threshold for MIPS:

  • Family medicine
  • Internal medicine
  • Preventive medicine
  • Nephrology
  • Endocrinology
  • Nutrition/dietician
  1. Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD)

Measure number 2 is related to the heart. American Academy of Cardiologists

It includes people aged 18 and above who were diagnosed with heart failure (HF) with a present or past left ventricular ejection fraction (LVEF) < 40% and were prescribed beta-blocker therapy either within a year of procedure in an outpatient setting or at each hospital discharge.

Reporting MIPS through this measure sets the tone for the management of chronic conditions. Gladly, it is available in both eCQM and CQM type, thus acceptable through various sources.

Specialties for which this measure is suitable to include:

  • Cardiology
  • Family medicine
  • Internal medicine
  • Hospitalists
  • Skilled nursing facility
  1. Anti-Depressant Medication Management

Psychiatrists act as pillars of healthcare when it comes to mental health treatment. Especially, their role is critical through the COVID-19 pandemic. Could there be a worse time for mental health issues to rise? Well, it could be worse!

Being grateful and using empathy as a tool to interact with people around us is needed for sure. The description of this measure that we have with us is mostly for eligible psychiatrists. MIPS 2020 presents numerous measures to report with accuracy and data integrity as the two requirements.

It is quality measure #9, according to the official fact sheet released by CMS.

How do we describe it?

It aims to find a percentage of people aged 18 years and above who were treated for mental illness and prescribed antidepressants. As per their depression symptoms, they have prescribed medication for months. You should report the following two types:

  1. First, the percentage of patients who were on antidepressants for at least 84 days (12 weeks)
  2. Second, the percentage of patients who were on antidepressants for at least 180 days (6 months)

Why is this measure meaningful?

It is in line with the prevention and treatment of opioid and substance use disorders. A MIPS consulting firm helps you select the right measures to report. More importantly, it is the accuracy and data completeness that matters to maximize MIPS incentives.

The collection type available for this measure is eCQM. Moreover, the specialties that this measure services include:

  • Family medicine
  • Internal medicine
  • Mental/behavioral health
  1. Age-Related Macular Degeneration (AMD): Dilated Macular Examination

Eyes let us see the beauty around us, thankfully. They show us the world as it is. In this quality measure, people aged 50 years and above are to participate. As an EC, you are to report it once they are diagnosed with age-related macular degeneration (AMD), followed by a dilated macular examination.

Further, it led to the recording of the presence or absence of macular thickening or geographic atrophy or hemorrhage and the intensity of the damage caused during one or more office visits within the 12-month assessment period.

Henceforth, this measure assesses the chronic conditions management area. Ophthalmologists are to report it through their MIPS consultant. MIPS solutions and to send MIPS data via clinical quality measures type is doable with plenty of support from qualified registries.

The collection type for this measure includes:

  • Medicare Part B Claims
  • MIPS CQM

In fact, it is only available for ophthalmology specialty.

Conclusion

Thus, paying special attention to the MIPS quality measures can maximize the chance to earn positive adjustments and even incentives.

It all depends on the CMS MIPS quality measures that you submit to CMS. Therefore, MDs and DOs, take time to strategize MIPS solutions properly and improve your financial situation.

MIPS 2020, MIPS Qualified Registries, MIPS consulting service, MIPS eligible clinicians, MIPS performance, final MIPS score, Electronic Healthcare records, Professional MIPS Reporting, MIPS Consultants, MIPS data submission, how to submit mips data, healthcare services

Why Your Medical Practice Needs a MIPS Qualified Registry?

The stressful time of the year for MIPS eligible clinicians has arrived.  We are going towards the end of the performance year MIPS 2020.

It is the time when MIPS Qualified Registries help you check all boxes of reporting requirements.

They not only simplify the MIPS 2020 data submission but also optimize your performance and help you stay ahead in the game with useful tools and strategies. Of course, the merits of submitting data via a MIPS Qualified Registry knows no bound.

Given below are some of the reasons why should your medical practice choose to consult a MIPS consulting service.

Merits of Consulting a Professional MIPS Consulting Firm

All-in-One MIPS Services

MIPS Qualified Registry submits data for all MIPS performance categories via an efficient and optimized system.

  • Quality
  • Promoting Interoperability (PI)
  • Improvement Activities (IA)
  • Cost

For the Cost category, physicians do not have to submit data but CMS estimates its score based on the submitted claims.

With a state-of-the-art infrastructure to manage data in one place, it is easier to estimate the final MIPS score. The process goes smoothly, and reporting objectives are easily achieved. Moreover, professional companies also estimate the cost incurred in quality healthcare services. So, you can make better strategies to counter issues.

Specialty-Specific Quality Measures are Easy to Choose

Do you know that eligible clinicians were allowed to report only fifty measures via EHR (Electronic Healthcare records) in 2019? Whereas, with a MIPS Qualified Registry, there were 232 quality measures to choose from.

With professional help, clinicians can choose from a wide list of measures and report data for MIPS 2020 as per the specialty expertise. For Instance, at P3Care, we ensure each client reports data for higher points and not just for the sake of it.

  • The list of quality measures are fully researched and analyzed
  • The team segments measures that strictly relate to the practice
  • MIPS Consultants discuss the prospect of each measure and prepare data as per the CMS’s standards

Professional MIPS Reporting

MIPS Qualified Registries have the experience and clientele to report QPP MIPS appropriately. Their clientele ranges from clinics, hospitals, and medical billing companies, small and large groups. They know how to present data that translate efforts to CMS for maximum score and help stay away from penalty as per the requirement.

An Electronic Management System

Smart electronic management systems at MIPS Qualified Registries help eligible clinicians to plan, analyze, and discuss plans with the consultants. You can easily keep a check on the MIPS 2020 performance and suggest changes that you want.

Estimate Financial Estimations

If you are working on your own, you cannot estimate the financial implications of your MIPS data appropriately. However, with professional help, you can easily do the entire Math to avoid any surprise element in the end.

For penalty estimation, incentive calculation, and other estimations, P3Care is there for you.

MIPS Reporting Support 24/7

A professional MIPS Qualified Registry guides you at each step from the beginning to the end. Whether you have any questions or need assistance in solving any matter, the team is there at your service.

You can also seek our help for any MIPS related question, contact P3Care at https://www.p3care.com/ | 1-844-557-3227.

Timely MIPS Data Reporting

When MIPS Qualified Registries compile all data, they allow medical practices to review data to the fullest. Once you are satisfied, the process goes further. They ensure that data for every MIPS performance category is in order and then submit it on time.

We know submitting data to CMS is complex. Therefore, a MIPS Qualified Registry is the perfect option to ease this process. If you have any concerns related to a smart reporting strategy, effective tools, and an efficient team, we are here to answer your queries.

CMS updates, QPP MIPS, MIPS Data Submission, MIPS 2020, Eligible physicians, professional healthcare services, QPP MIPS 2020, medical practice

How CMS Determines MIPS Eligibility?

The QPP MIPS participation starts from knowing the eligibility status. For MIPS 2020, clinicians can check eligibility via QPP Lookup Tool. Later on, CMS updates if physicians are eligible for MIPS data submission or not.

However, the reporting requirements change each year due to changed policies. So, if we want to succeed in this program, we have to comply with the changes.

 MIPS 2020 Eligibility Check

According to the official website, interested clinicians must have:

  • National Provider Identifier (NPI)
  • Associated Taxpayer Identification Numbers (TINs)

A TIN is required when you own a practice; belong to a hospital as a medical facility or a medical practice.

In the case of physicians’ reassignment of Medicare Billing Rights to TIN, their NPI gets associated with that TIN, referred to as TIN/NPI combination.

For Instance, if any physician has assigned billing rights to multiple TINs, he/she will have multiple TIN/NPI combinations.

CMS assesses TIN/NPI combination for MIPS eligibility and use TINs for practices’ eligibility.

Eligibility Determination Period of MIPS

CMS looks into past and current Medicare Part B Claims and Provider Enrollment, Chain, and Ownership System (PECOS) data for clinicians and practices, each year twice.

Data analysis from the first segment is referred to as preliminary eligibility. Data from the second review are then attached to the first segment of data and presented for final eligibility determination. The requirement is to pass the Low-Volume Threshold (LVT) during both reviews.

What is Low-Volume Threshold (LVT)?

LVT includes three aspects of professional healthcare services as follows.

  • Allowed charges
  • Number of services provided
  • Number of Medicare patients who receive services

Other than exempt cases, physicians are required to participate in QPP MIPS 2020, if they:

  • Bill above than $90,000 for Part B covered professional healthcare services
  • Check more than 200 Part B patients
  • Offer above than 200 covered professional healthcare services to Part B patients

It is to consider if physicians report Medicare Part B claims in the second review with a medical practice’s TIN, the eligibility status at that practice will only reflect data from 2nd review.

Who Can Participate in MIPS 2020?

CMS has an eligible clinician type. Clinicians falling into the list and satisfying all the requirements can participate in MIPS.

  • Physicians (including doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry)
  • Chiropractors
  • Physical therapists
  • Occupational therapists
  • Clinical psychologists
  • Osteopathic practitioners
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Qualified speech-language pathologists
  • Qualified audiologists
  • Registered dietitians or nutrition professionals

MIPS Data Submission Methods

Eligible physicians can report data to CMS as individuals, a group, or a virtual group.

Eligibility Check for MIPS 2020 Participation as Individuals

For MIPS participation as individuals, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Surpass the Low-Volume Threshold requirements
  • Not qualify for Alternative Payment Model Participant

Eligibility Check for MIPS 2020 Participation as Group

For MIPS participation as a group, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Belong to a medical practice that surpasses the Low-Volume Threshold requirements
  • Not qualify for Alternative Payment Model Participant

The MIPS score and payment adjustment will be awarded as a group in this case.

 

Eligibility Check for MIPS 2020 Participation as Virtual Group

For MIPS participation as a virtual group, physicians must:

  • Belong to eligible clinician type on Medicare Part B claims
  • Have enrollment in Medicare before the performance year 2020
  • Not qualify for Alternative Payment Model Participant
  • Be associated with a medical practice that surpasses the Low-Volume Threshold requirements & is part of virtual practice

 

The above-mentioned are all the requirements that a MIPS participant should know beforehand the MIPS data submission. We are halfway through QPP MIPS 2020, and many professionals already had planned and implemented a strategy for optimized performance in the end.

 

How to Report MIPS Data?

Physicians have a lot on their plate already, and the pandemic has increased their burden. In such a situation, MIPS quality reporting seems like a challenging task.

If you’re an eligible MIPS clinician, the best advice to you is to concentrate on quality care outcomes. A professional MIPS Qualified Registry will take your efforts into account, and you can target more measures if you have a proper plan of action on board.

Best of luck.

MIPS data submission, MIPS quality measures, MIPS submission method, MIPS qualified registry, quality measures

Right MIPS Submission Methods Lead To Successful MIPS Reporting!

MIPS – a quality payment program for physicians is one of a kind and progressive step that benefits both, physicians and even the patients. The prior tangled and twisted reimbursement method failed to contribute to the healthcare industry via any advancement. Thus, MIPS came as light at the end of the tunnel for physicians to direct their financial matters in the right direction.

Reporting accurate data, according to the medical practice and with the appropriate submission method is inevitable to score high in the MIPS scorecard. The period for submitting MIPS qualified measures is already short so there is no time to waste.

This article discusses all the queries regarding MIPS submission methods so that physicians successfully report clinical data to CMS.

First, Do Your Research Well!

The first step in MIPS reporting is to recognize what submission method will suit your practice, the best. The right decision will have a huge impact on your submission. Otherwise, you’ll end up scratching your head for unnecessary delays caused by poor research, as many factors are important for a professional MIPS submission.
In addition, MIPS data submission seems easy. However, it is not as simple as one may estimate. Let us briefly explain the MIPS reporting process.

How to Report MIPS?

Physicians work day and night treating patients to deliver quality-based medical services. MIPS eligible clinicians report their performance data on a yearly basis to CMS. There are four performance categories for MIPS:
• Quality holds 50% of the total MIPS score
• Promoting Interoperability (PI) holds 25% of the total MIPS score
• Improvement Activities (IA) holds 15% of the MIPS score
• Cost holds 10% of the total MIPS score

As per the CMS submission requirements, physicians report against three categories. However, the CMS authorities themselves measure the cost category. They calculate performance for this category by administrative claims data.

Now, Choose Between MIPS Submission Methods!

Clinicians can choose from a number of submission methods as per their requirement,
• CMS Web Interface
• Administrative Claims
• Electronic Healthcare Records (EHRs)
• Qualified Clinical Data Registries (QCDR)
• Qualified Registry
• CAHPS for MIPS Reporting Survey Vendor
• Attestation

Another factor that plays an important role in the successful MIPS data submission is finding the right and specialty-specific MIPS quality measures to report.

Physicians can consult MIPS qualified registries, which help them choose the measures relevant to their practice. Reporting data against the relevant measures gives the chance to score high.

How to Report MIPS Data?

Physicians have the freedom to report either as an individual or in a group.

As an individual identified by individual National Provider Identifier (NPI) with a single Taxpayer Identification Number (TIN)

In a group of two or clinicians with a single TIN, identified by NPI

There is also another option to report via a virtual group.

Consider the Following Points When Choose a Submission Method!

  • While considering what submission methods will result in your favor cost-effectively, you also need to ponder upon their limitations.
  • Clinicians are only allowed to report data via a single submission method for a single performance category.

Look out for all possible scenarios that can occur with the submission method. As each MIPS submission method has its benefits and limits as per the medical practice. Therefore, carefully check all the logistics and your organizational structure before submitting data. It may leverage your performance score for positive or negative payment adjustment.

Not only deciding the right submission method is time-consuming, but it also requires thoughtful planning, resourceful implementation, and the ability to incorporate progressive steps of your organization.

All this Process is Hectic but you can Stay Stress-Free with P3Care!

Physicians may be worried about how they’ll manage to choose the right MIPS submission method along with their responsibilities. Don’t worry and let us share your MIPS reporting burden. P3Care has been MIPS qualified registry for two years. Our specialized methods, resources, and experience in this field speak for itself. Moreover, we as an H I.T consultants help to choose you the right quality measures and the submission method.

For further information, visit https://www.linkedin.com/company/p3-healthcare-solutions

News

CMS Update, healthcare system, MIPS 2020, MIPS Qualified Registry, MIPS data submission, MIPS incentives

CMS Announces A Decline of $15 Billion in Medicare Fee-For-Service Improper Payments

Both patients and physicians are in for a treat. A few days ago, CMS happily announced the continued decline in the Medicare Fee-For-Service improper payment rate.

It is a clear statement in the name of transparency. More importantly, it is the proper accreditation of taxpayer money and an effort to strengthen the Medicare program in general. Undeniably, such are the efforts that pave the way for a rewarding healthcare system.

If you see it in another manner, once you hold fraudulent activities to account, there is more to give to those who deserve it. It automatically translates into value for quality programs like the MIPS 2020 and for other value-based care programs. Through such strategic actions, we will cement the positive reflection of value-based programs, both materially and conceptually.

In fact, once CMS saves taxpayer money by stopping improper payments made on account of frauds, overpayments, and underpayments, it converts into quality care and fewer expenses for the common man.

Four Years of Remaining on Point Saves the Day

It was not an overnight thing, but it took four constant years to come to this point. CMS corrective measures led to an estimated $15 billion reduction in Medicare FFS improper payments in FY 2020. It was part of the agency’s action plans that helped reduce and prevent illegitimate payments over the years.

During this journey of consistency and hard work, the agency’s capacity to address risks improved substantially through group activities and interagency collaborations.

For a fact, it was the Trump administration that made a clear commitment to protect Medicare for our seniors. To achieve this purpose, we must ensure that frauds, abuse, and waste do not happen as they will rob the program of its efficacy, Ms. Seema Verma expressed in her brief talk.

The Trump administration doubled the efforts to protect taxpayer money, and this year’s continued reduction in Medicare FFS improper payments is a direct effect of those actions.

Historic Win for Taxpayers

The reduction in improper payment rate means a win for taxpayers. Their hard-earned money is safer this year by quite a margin from the previous year. Due to the constant efforts in this sector, in 2020, CMS managed to decrease the improper payment rate further down – to 6.27%. Back in FY 2019, this rate was 7.25%. It is the start of an era of taxpayer savings to ignite the flames of a flawless healthcare system.

The improper payment rate threshold has to be under 10%, and, rightly so, we live to see it become a reality. In the past four years, we made this progress under the Payment Integrity Information Act of 2019 for our present and future generations.

Progressive Areas

  • Home Health department saw improvements, including clarifying documentation requirements and raising awareness among providers through the Targeted Probe and Education program. The resulting situation was no less than incredible. It led to a $5.9 billion decrease in improper payments from 2016 to 2020.
  • Skilled Nursing Facility Claims was the other area that saw improvement. There was an approximate reduction of $1 billion in improper payments in the last year due to a policy shift. It happened due to an adjustment made to the supporting information for physician certification and recertification of the skilled nursing facility services. Moreover, CMS’ Targeted Probe and Educate programs reaped its fruits.

Healthcare costs are soaring as we speak, and they are going to increase going forward. According to an estimate, by 2026, one out of every five tax dollars will go into healthcare.

To have sustainable cost growth, CMS must continue to strive for a system that accepts only proper payments. Improper payments only destabilize the cost balance. Stating the obvious, they are illegal payments – intentional or otherwise – going against the sustainability of affordable healthcare. They also represent false spending of American taxpayer dollars; however, not all of them represent fraud. The definition of improper payments includes overpayments, underpayments, or payments made under insufficient information.

Action Plan

CMS has developed a five-tier program integrity plan to mark the agency’s approach to reducing improper payments while safeguarding its programs for future generations:

  1. Bring Bad Actors to Justice: CMS works alongside law enforcement agencies to bring people who have defrauded the system under law.
  2. Prevent Fraud Before It Happens: Rather than the costly and ineffective “pay & chase” model, CMS eliminates fraud proactively by reducing the opportunities to exploit vulnerabilities in healthcare.
  3. Mitigate Risks to Value-Based Programs: CMS continues to explore ways to identify and reduce integrity risks to value-based care programs. MIPS 2020 and Advanced Alternative Payment Models (APMs) are the two programs currently underway. With the help of experts in the healthcare community, their lessons learned, CMS pledges to run these programs smoothly.
  4. Reduce Provider Burden: It is in line with reducing providers’ burdens who make claim errors in good faith; CMS wants to assist them by giving them easier access to coverage and payment rules. In addition to that, CMS is educating them on compliance programs. P3 Healthcare Solutions becomes a part of this effort via MIPS data submission to CMS as a MIPS Qualified Registry.
  5. Leverage Artificial Intelligence and Machine Learning: CMS looks to leverage technology like AI and machine learning to allow the Medicare program to oversee compliance on claim submissions. It eventually calms the providers down, and taxpayers get to pay less.