The Quality Payment Program 2023 & Beyond | With Aaron Higgins

Jason Crosby

Hi. I’m joined today by familiar voice, my podcast partner in crime Aaron Higgins of SHP.

Today’s topic. We’re gonna cover the basics, the ends and outs and all things related to the quality payment program final ruling that recently came out. Aaron, how are you? And thank you for joining.

Aaron Higgins

I’m doing pretty good, Jason. How about you?

Jason Crosby

Fantastic. Thank you. Thank you. So Aaron has been with us SHP for quite a few years now between our analytics department and as our IT strategist, but a lot of his background and current function is knowing anything and everything related to MIPS and now QPP.

But Aaron, as we get started, tell us a little bit how you got started in healthcare and specifically how you became involved with quality in the first place.

Aaron Higgins

Sure. So my background starts relatively benign. I was the IT guy brought on to a cardiology group in in the waning years of the Bush administration in the early days of meaningful use, PQRS at that same time, the practice, like many practices, was moving from paper church to digital church. And so I was brought in to help them move to their new EHR and it just kind of got coupled with the whole EHR.

Deployment of well, we have to do PQRS. We have to do this meaningful use thing. Using your EHR. You’re the expert on the EHR. So why don’t you run it? And so it had the snowball effect from there where a larger and larger chunk of time went from, hey, my mouse isn’t working to hey, how come my erx scores low and it just the the growth of it was sort of this natural onset and.

Coming to Savannah several years ago, I did primarily that sort of thing, PQRS and then at the time QPP or MIPS was new. So I helped the practice get on board with that and and do their scoring and then coming to SHP, it grew from just being a solo practice focus to helping a lot of our clients do their.

Their QPP work. So in that time I’ve worked with IPA’s and large practices, small practices, helping them solve their quality payment program questions.

Jason Crosby

Kind of a natural evolution from the IT background, EMR support and the QPP, which is pretty common. It seems like these days, if not clinical kind of coming from that EMR side gives you some unique insight I can imagine.

Aaron Higgins

Yeah, absolutely. Yeah. The the biggest part of that being successful with QPP really comes down to workflows, making sure you’re documenting the care and the right way according to your EMR’s needs. So that was really the biggest barrier that we had with adoption within easy sort of quality payment fill in the blank, whether it was meaningful use or PQRS, it came down to workflows.

Jason Crosby

Fantastic. Well, well on that front, let’s, let’s back up a little bit, explain a bit around the origins of the quality payment program.

Aaron Higgins

Sure. Uh, I’ve already mentioned PQRS and meaningful use, so those were the forbearers. But we actually have to go back even further to the late 90s. A lot of the private payers we’re trying to figure out ways that they could reduce costs and improve patient outcomes. And at the same time too the federal government was doing the same thing. And so the two kind of came together the private payers, a lot of the private organizations such as the American Medical Association and the federal government sat down in the mid aughts.

And said we need something, we don’t know what we need, but we need something that improves patient care. That’s measurable, that everyone can do. And in again the late Bush years, so circa 2008.

We started seeing a lot of rumblings from CMS about this new meaningful use program to get people to use EHRs and use them in a meaningful, useful way. EHRs were thing they just they weren’t widespread. And so that program took on a life of its own. And then under the Obama administration, it grew even further than by the time the Obama terms were nearly done. We ended up with MACRA, which was the Medicare and Chip Reauthorization Act of 2015.

From that MACRA program we got the quality payment programs which is the umbrella term that we use to cover MIPS. So the merit based incentive payment system MIPS, we got a lot of the ACOs and the advanced payment models that we have today APMs all of that came out of macro. So it’s been 20 years or so of just gestation and constant evolution of the programs.

Jason Crosby

Yes, sounds like it, whether it’s the alphabet soup that’s evolved over the umbrella of reimbursement underneath it, measures, et cetera, definitely a big evolution. So let’s let’s touch on that a little bit. Over the last seven years in particular, since it was passed in 2015, lots of changes even within that small window. Why would you say that it is and how has that program changed so much?

Aaron Higgins

One of the big complaints about meaningful use was how rigid it was. It it changed a little bit every year, but it was extremely rigid. There wasn’t a good feedback in mechanism for it. So at its heart macro was written by Congress to require a lot of feedback and CMS has taken that feedback every year, so they they release a proposed rule. And that being said, laws have always required a feedback period. It’s just with MACRA that was baked right in they were very strict on CMS soliciting feedback and very clear on the release schedule for and so every summer we get a proposed rule for QPP and then come Porter three or quarter four sometime we’ll see the final. Now this year it was great. Final rule dropped in late October is on Halloween. So it was a little bit of a treat and I say that because in prior years they’ve waited as long as the first week of December. So there’s not a whole lot of time to read through the final rule.

But, but going back to that feedback that that’s been an important element and a big driver of how the programs evolved when the program was first introduced, it was very all a cart kind of.

Take your own adventure sort of thing, and now it’s kind of going back to that rigidity that we had with meaningful use, but with a lot more care and a lot more feedback put into it with the introduction of MVP, which is the way that MIPS is going to evolve for non-APM practices in the future.

Jason Crosby

Let’s keep going on that path. So lots of changes obviously as you just mentioned.

And my folks are listening now to 2023 final rule, which just came out as you just mentioned.

Hit on specifically some of the measures and points that you feel are most influential for folks coming in with 23 bowl.

Aaron Higgins

Yeah, some of the changes that we’re seeing with 23 aren’t as huge as we’ve had in prior years. Some of the years the programs drastically changed. And again, going back to that feedback element, the final rules always have this question or an answer, I guess, feedback and answer response sort of mechanism in there. And it’s, it’s fascinating to read through that if you’re a normal like me because you get an idea of what CMS is thinking when they’re writing these rules.

And in many cases we’ve seen it where someone’s left comments and it’s made a change in the final outcome and we saw that this year too there were several measures that were proposed for removal and the quality and ended up staying and getting changed instead. So the feedback matters. But this year some of our bigger changes were actually a little bit of a surprise for some of us because they weren’t in the proposed rule. And CMS has allowed to do that. Things come up between the time that the proposed rule is released and the time that the final rule is released.

So they make changes, so one of the big changes is in regards to the certified EHR technology or see hurt. It’s right now 2015 C hurt is required to participate in any form of QPP.

But they have updated the CEHRT certification to the Cures update, so you need to make sure your EHR vendor is updating your EHR to the 2015.

Certified EHR Technology cures update it it’s a bit of a mouthful. Reach out to your EHR vendor, talk to them. It’s really important that you do that. Depending on how you’re reporting your quality measures, it could be as soon as January 1st. So this is really timely. That would be January 1st, 2023 or at the very latest October 1st, 2023. You need to talk to your EHR vendor. It has to do with the way that you’re reporting your quality measures really important.

Some of the other changes that we’re seeing is the automatic exemptions for small practices, so small practices. According to CMS QPP rules or practices with 15 or fewer eligible clinicians. If you are an eligible practice, you may be able to take some automatic exemptions on promoting interoperability. CMS has seen small practices struggle with that, so they’re taking the burden off while they either retool it.

Or they allow small practices to figure out what they need to do to actually do well on it.

And another exemption, but you have to apply for it is the cost category. The cost category is really hard for small practices to know what their score is going to be until after they get their scores. So there’s no chance for them to change it and that’s going to be available for small practices.

But there’s been a significant number of individual quality measures that were changed over 75 of them. Were we actually just did a webinar on this a couple weeks ago. I invited our listeners to go check that out. We go into greater detail about what those measures are, the new and changed improvement activities. There’s a whole laundry list of individual small changes that were made in the program this year.

Jason Crosby

Great info there. And to reiterate Aaron’s point, I think you’ll find the webinar very informative. Lots of info. There were about good 45 minutes worth of stuff where you guys to go out and check out.

Alright, given that know. we’ve obviously got various folks listening practices, hospitals, etcetera. What would you tell a practice who has not participated in MIPS before, or maybe who just hasn’t scored as well? Where should they start and seeking out? Should I go down this path or how to improve? What would you suggest first?

Aaron Higgins

Yeah, it is very daunting like any federal program, it’s confusing. There’s a lot of rules. The rules change every year. Where to begin and…great question…I would say start by seeing if you’re providers are eligible or not. If you know for certain that they are eligible or you’re maybe you’re practice as a whole is eligible.

Uh, so that’s important, because if you’re not eligible and you haven’t started this year?

For 2023, use 2023 instead as a preparation year to participate in 2024. Now, if you are eligible and you’re panicking right now, well, don’t panic. There’s a lot of great resources out there for small practices. Again, that’s 15 or fewer clinicians. There’s a lot of free resources available to you where CMS has vendors that will come alongside and hold your hand through the process. Of course, there’s CHP. We’re more than happy to sit down with you, spend 20-30 minutes on a call with you to talk you through what all you need to do because you’re going to need an identifying measures, measures that are relevant to your organization and your type of practice. Gonna need a fine improvement activities. You’ll need to check with your EHR vendor to see what measures and activities they’re supporting and promoting interoperability. Getting patients enrolled in patient portal, that’s where thing. There are a lot of moving parts and if you are eligible for MIPS in 2023 and you haven’t begun preparation.

Well, I hate to say it’s it’s too late. It’s never really, truly, too late. But you need to start working on it now instead of waiting until after the first of the year. But we are more than happy to help you out as HHP our website ashpllc.com webinars is where you’ll find recordings of all of our webinars regarding QPP. So that may be another place you want to begin.

A few years ago, Jason, we did some webinars about the origins, the individual origins and really deep diving into each of the categories. That would also be a great resource for someone who wants to learn the whole history and and how we got to where we are.

Jason Crosby

Yeah. Now that they’re, they’re reimbursement penalty.

Is climbing the ranks there and as hurtful as it is, another incentive to kind of get on the train there.

Aaron Higgins

Yeah, and and that that raises a good point, Jason, if you don’t participate and you are eligible, that’s a 9% reduction on your Medicare Part B payments. And for a practice that has a large Medicare population that could be huge.

Jason Crosby

Yeah. Yeah, early on that when it was less that was kind of the rationale for folks not participating right OHG it’s only you know one percent, 2% and now it’s nine. It’s kind of moves the dial a little bit. So we we’ve talked about how you got in the QPP, we’ve talked about the origins of it, we’ve talked about the changes for next year. And then just now a lot of what to do action called action type items, anything else you wanna highlight for the group?

Aaron Higgins

Yeah, I hinted at it earlier. We have the MIPS evolution, the MVP program so MVP is the way that traditional MIPS is going to evolve. If you’ve ever participated in an ACO or know someone who has think as an MVP, as a micro ACO. So that’s the way that the program will evolve in the future. We’ll make the administrative burden a little bit lighter and this final rule went into some more information about the types of MVPS that you’ll be able to choose from starting next year. It’ll be a voluntary process.

And then three years from now, in 2026, it’s going to be mandatory that you participate in MVP. So if you’re just getting started or you been in the program for a really long time, understanding what the MVP’s are and how they’re going to work for you is really important. Again, going back to, if you have questions about that, you can call us or you can call the QPP help desk there available at qpp.cms.gov and more than happy to help their great resource.

Jason Crosby

And I I’ll reiterate again that the webinar that Aaron’s referencing, if you go to shpllc.comwebinars, you’ll see it there dated November 15th.

Jason Crosby

Very informative PowerPoint presentation there for your reference. Uh, please take a look at it.

Aaron’s information’s on the website. Otherwise how can they find you here?

Aaron Higgins

You can find me on LinkedIn Aaron C Higgins or you can click the link in the show notes. We’ll have everything linked below, or you can shoot me an e-mail. That’s ahiggins@shpllc.com.

Jason Crosby

Fantastic. Great information. I appreciate your time, Aaron. And then slight appreciate everybody listening. I’m sure we’ll talk QPP at some point next year as well. Obviously what that thanks again for joining us and have a great rest of your day.

Aaron Higgins

And you too, Jason.