The Centers for Medicare & Medicaid Services (CMS) are at it again! They have revised their payment policies under the Physician Fee Schedule (PFS) and included proposed changes on how the government will pay anesthesiologists participating in the Quality Payment Program (QPP).

It can be hard to keep up, which is why we have summarized the latest changes to help you understand the QPP 2020 updates that impact anesthesiologists. Here’s what you need to know about the latest changes now and how it could impact your reimbursement over the next few years.

What is the CMS QPP?

In 2015, Congress voted on the Medicare Access and CHIP Reauthorization Act (MACRA), a statute that implemented a value-based reimbursement system called the Quality Payment Program (QPP).

Congress created the QPP to support and reward physicians who provide their patients with high-quality care. Medicare payments were distributed according to a two-tier, performance-based system:

Tier 1: Advanced Alternative Payment Models (APMs)

This payment system rewards anesthesiologists for delivering high-quality, coordinated, and cost-efficient care. Eligible practitioners can choose from eight care models to qualify for Advanced APM and can earn up to five percent in incentive payments.

CMS provided practices with retroactive incentive payments for 2017 and 2018 if:

• Advanced APMs accounted for paid twenty-five percent of their payments
• Twenty percent of their Medicare patients took part in advanced APMs

Anesthesiologists must participate in advanced APMs to avoid penalties.

Tier 2: Merit-Based Incentive Payment System (MIPS)

MIPS measures an anesthesiologist’s patient care performance in four weighted categories:

• Quality
• Promoting interoperability
• Improvement activities
• Cost

MIPS scores are generated for eligible physicians in each category based on performance measures at the end of each reporting year. CMS then calculates a MIPS Composite Performance Score (CPS) at the end of each Medicare reporting cycle which is assessed 2 years after each MIPS reporting year. CPSs ultimately affect how the government settles future anesthesia Medicare program payments. Anesthesiologists may receive positive, neutral, or negative reimbursement adjustments based on their CPS.   

What Are the Proposed QPP 2020 Changes?

CMS released its much-anticipated Changes to Part B Payment Policies in July 2019, which directly impacts the QPP for anesthesiologists over the next three years.

APM Changes

CMS is considering simplifying quality patient care measures for physicians who participate in APM-MIPS. This will be done by integrating their CPS quality score with APM quality assessments when APM quality scoring is unavailable. 

MIPS Changes

CMS will continue to update MIPS for anesthesia Medicare programs on an annual basis. Starting this year, the following MIPS performance and payment changes will be implemented:

1.     Negative reimbursement adjustments will increase from 7% to 9%: Eligible anesthesiologists must earn at least 45 CPS points (which has increased from the previous 30 points) to avoid a 9% negative adjustment during the 2020 reporting cycle.

2.     Category weight shifts: CMS will also alter the following MIPS category weights:

• Quality decreases to 40%
• Cost increases to 20%
• Promoting interoperability and improvement activities will stay at their current weights of 25% and 15% respectively   

3.     Multimodal Pain Management (MPM) inclusion: Physicians may now incorporate MPM values in their anesthesiology measure sets when reporting improvement activities.

4.     Simplified reporting via MIPS Value Pathway (MVP) assessment: CMS’ new MVP program, scheduled for 2021 implementation, will simplify performance assessment in MIPS categories by grouping the physician’s specialty and/or patient treatment measurements into one MVP class. This will allow CMS to use MVP assessments to evaluate anesthesia group efficiency as a whole as opposed to evaluating thousands of individual anesthesiologists.

The latest QPP changes to anesthesia Medicare programs will impact practices over the next three years.

Miscellaneous QPP 2020 Changes

CMS also proposed another QPP modification that directly impacts anesthesiologists and their practices:

Minimum total points threshold increase: Physicians must score at least forty-five threshold MIPS points in 2020 to avoid negative penalties in 2022. Practices must successfully complete all activity requirements included in the MIPS “improvement activities” category – either one high or two medium-weighted activities for non-patient facing physicians; or, two high or four medium-weighted activities for face-to-face practices.

Why Are QPP 2020 Updates Important?

Billing for anesthesia is complex; add in the additional Medicare reporting requirements and that complexity increases twofold. It’s critical that all anesthesia practices to stay up-to-date on QPP changes – especially since inaccurate or incomplete billing will invariably impact a physician’s bottom-line profits.

Don’t Stress About These Changes: We Can Handle It for You

All of the QPP changes can feel extremely intimidating to keep up with. Ensuring you meet all the requirements and avoid penalties is an additional job within itself. We recommend finding a partner, like Fusion Anesthesia, who can help manage these changes in billing and reporting requirements for you.