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When Regulators Cry “Wolf!”

As a CMS qualified registry that supports managing and reporting for many Value Based Care (VBC) programs, we understand that it takes more than just technology to meet and stay up to date with all the programmatic requirements and changes. For that reason, we package our population health analytics application with a service offering that helps to guide clients on how each VBC program is changing, how the changes will impact their organization(s), and how different tactics can result in financial rewards for success under the programs. The problem is that the rules and the game seem to constantly change.

As I type this, CMS has just released yet another huge change to the 2020 MIPS program. Yesterday I turned on my laptop to see a message waiting sent by CMS – “oh joy, what now?” I thought.  It stated that they updated and adjusted some of the scoring and final feedbacks from 2020. In some cases, this led to practices receiving a neutral adjustment – even for those who scored well above the 45-point threshold. Organizations that dedicated extensive staff, resources, and time to managing their MIPS reporting requirements in the hopes that their efforts might be financially rewarded, especially during the darker pandemic days, are yet again let down by the minimal incentives they see under a program that requires such considerable effort. We have heard, “we want out of MIPS” more as a result of the 2020 reporting year than ever under any program like MIPS, PQRS, Meaningful Use… the list goes on.

Another wolf cry was the almost certainty that CMS had for retiring the CMS Web Interface as a collection type. This would effectively require that Medicare Shared Savings Program (MSSP) ACOs would need to move to reporting the MIPS CQMs/eCQMs for 3 active reporting measures as part of the new APM Performance Pathway (APP). The slightly under-reported but major impact of this change was that MSSP ACOs would thus be forced to move from reporting on just Medicare beneficiaries to reporting on all payer events for the quality measure reporting requirement. The message was clear that CMS was forcing the web interface out and didn’t plan to go back on this change. The web interface method was as good as done… or so we thought.

ReportingMD knew the change for MSSP ACOs to report on just Medicare beneficiaries to having to report on all payer patients would be massive. Suddenly, MSSP ACOs would need to have the ability to aggregate data from various disparate data systems (EHRs, PMs etc) across their various practice participants and report a single set of aggregated measures for the entire ACO. CMS ultimately finalized that the Web Interface collection type would be retired completely in 2022 but could still be used in 2021. ReportingMD made certain that the ACOs were going to be ready for this change but then in the 2022 proposed rule, CMS once again changed their tune. The 2022 rule proposed that CMS would extend the use of the web interface for the 2022 and 2023 years. The only caveat is that if an ACO chooses to report via the web interface in 2023, they must also report on at least one of the active reporting MIPS CQMs/eCQMs to show that they are preparing to able to report on all payer events for those measures.

How do we navigate this? How do practices work through these changes? How do we as a registry strategize for future reporting years when CMS and other third-party payor programs change the rules of the game?  I am reminded of Calvinball from Calvin and Hobbes. The rules are simple – in fact, there is only one rule in Calvinball – rules cannot be used twice, so every game is different, and any plays made in one game cannot be made again in future games. That is how reporting has seemed as of late, with the rules, policies, and implementation constantly shifting – even after the submission of data.

Each year practices are warned that the hammer falls this year, and more and more practices will be penalized – ooooo. Once again, practices roll their eyes and say, “yeah, uh-huh, sure. Fool me once, shame on you, fool me 3 times in a row, shame on me”.

ReportingMD will stay the course and continue to guide clients on how to work within the guidelines of the various VBC programs and how to manage through times of change and uncertainty. We have no other choice than to go with the flow. Unfortunately, that means that sometimes we will cry “wolf” on behalf of the regulators. Maybe someday this will prepare organizations when regulators deliver on their advertised plans.