Specialists Can Do Better by Pursuing APMs over MIPS

Archway Health recently attended a conference focused on educating specialty practices about key industry trends; one of the conference breakout sessions was dedicated to helping specialists understand and succeed in MACRA’s Merit-Based Incentive Program (MIPS). MIPS, intended to incentivize and reward physicians for providing efficient, high quality care, adjusts physicians’ Medicare FFS rates upward or downward according to their relative scores in four performance domains: Quality, Clinical Practice Improvement Activities, Advancing Care Information through EHR technology, and efficiency.

Every specialty practice participating in the MedAxiom breakout session had already invested significant resources preparing to meet MIPS reporting requirements; however, when surveyed, only one practice had the goal of earning additional money under MIPS; the rest simply aimed to avoid a penalty.  

It is highly disconcerting to watch our nation’s leading specialists spend limited time and resources with an end-goal of not being penalized under a reimbursement system that already underpays its doctors. Because MACRA eliminates annual rate inflation under the Medicare Physician Fee Schedule, even with the avoidance of a MIPS penalty, doctors will still fail to break-even due to higher input costs. Acknowledging MIPS’ poorly designed structure, the Medicare Payment Advisory Commission (MedPAC), which advises the Centers for Medicare and Medicaid Services (CMS) on Medicare payment policy, recently recommended revising the Merit-Based Incentive Program (MIPS), citing the burden the policy places on providers, with little return in care improvement.  

Instead of wasting resources “just trying to survive under MIPS,” as one practice manager put it, practices should be investing to thrive in the Bundled Payment for Care Improvement (BPCI) ‘Advanced’ program, the only option for most specialists to qualify for the Advanced Alternative Payment Models (APMs) track under MACRA. Under Advanced APMs, physicians have the opportunity to earn significantly greater revenue, avoid the risk of penalty under MIPS, receive an additional 5% bonus annually if a minimum percent of their Medicare patients are attributed to the APM, and receive substantially more robust and timely patient level performance data; further, physicians can establish a foundation for success under commercial Value Based Purchasing.  

At Archway Health, we’re encouraged to see the new priorities for the Center for Medicare & Medicaid Innovation (CMMI) focus on creating more specialist Advanced APMs, including the BPCI-Advanced program which is expected to be announced this fall.  CMS is currently testing eight outpatient bundles, including Knee Arthroplasty, signaling their intent to adopt outpatient bundles in the next generation BPCI program and engage a broader range of specialists.  

Our specialists deserve better than a failed return on investment under MIPS. We believe that qualifying for the Advanced APMs track through BPCI Advanced is not only the better option under MACRA’s Quality Payment Program—it’s a better business solution.  Bundled payments can help grow your practice, and the Archway team would love to share more of our ideas and solutions for how you can do this.