As I read the new proposed rule above, I am focusing on the three highlighted areas and wanted to share some key points from my reading thus far:
In the Physician Fee Scale, an expansion of Care Management is proposed, for example
Increasing the RVUs for Transitional Care Visits
Adding new CPT codes to more specifically document the time spent on care management activities for patients that meet the criteria for care management.
We actually have a pretty cool, inexpensive way of tracking and calculating time spent in Care Management which makes it very easy to identify patients eligible for billing this activity. (Only available for clients that have access to their database server).
Adding a new code for Primary Care Management or PCM. This code would allow for care management of those patients with one chronic health problem that need care management for at least an3 month period. This is a great code for specialists that are caring for a specific chronic condition – later stages of congestive heart failure, organ transplants, diabetes managed by the endocrinologist, to name a few examples.
Quality Payment Program Proposals and 2019 Changes
Payment Adjustment is +/- 9% in 2020
The final score increases to 45 in 2020 and 60 in 2021
Exceptional Performer scores are proposed at 80 in 2020 and 85 in 2021
Category scoring
Quality – 40 in 2020, 35 in 2021, and 30 in 2022, data completeness increases to 70%
Cost – 20 in 2020, 25 in 2021, and 30 in 2022. 10 new cost measures in 2020
Improvement Activities – at least 50% of providers must participate in the activity
Promoting Interoperability – no change in scoring
In the Promoting Interoperability Category
The 2 bonus measures have been changed to a Yes / No Attestation for 2019.
In 2020, the Opioid Treatment Agreement measure is proposed to be removed.
If a provider or group, depending on your Submission method, is excluded from a Supporting Electronic Referral Loop by Sending Health Information, the points are redistributed to the Patient Access Measure. Begins in 2019.
There is a new concept of MIPS Value Pathways (MVP)s that I will discuss as I learn more.
As the QPP program scores increase, the accuracy of your reporting in quality and promoting Interoperability is paramount. This accuracy directly impacts your payments and bottom line. If your reports are not accurate, call us. You cannot afford to be underscored any longer.
Another quick note – I have been reading all the horror stories online about bad hosting frameworks and the impact on productivity of your practice. I just want to remind you that you do have options if you chose to go with hosting or with having a third party build out your servers onsite.
One of the companies that we partner with is Strategic Solutions of Virginia. I have given them permission to send information your way on the importance of PM/EHR performance measurement and optimization. They have turned many poorly performing slow systems into ones that work for doctors and staff and not against them. Be on the lookout for this information if you are in NC or VA. If you are not in NC or VA, there are still reputable companies that can help you with a solution for optimizing your environment. We are happy to recommend solutions!