WHA continues to closely analyze the impact the new quality payment program for physicians created under the Medicare and CHIP Reauthorization Act (MACRA) of 2015 will have on WHA members. MACRA creates two paths for clinician reimbursement beginning in 2019—Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).
At the August 17, 2016 WHA Council on Finance meeting, chaired by Steve Little, president/CEO, Agnesian HealthCare, WHA Senior Vice President Joanne Alig and WHA Chief Quality Officer Kelly Court provided a MACRA overview. The Centers for Medicare & Medicaid Services (CMS) expects the majority of eligible clinicians to be on the MIPS path in 2019, but hopes that over time more will participate in alternative payment models. The challenge, however, is that the vast majority of the current payment models won’t qualify as “advanced” and thus be eligible for reimbursement under the APM path. WHA encouraged CMS to seek ways to expand the options for APMs and additionally for development of new APMs that can be focused on rural areas.
Alig noted a key takeaway is that the timeline for understanding the complexities of the law and proposed rules is short, let alone to begin to implement processes for improvement. The performance year for MIPS and APMs begins January 1, 2017, and the rule isn’t expected to be final until around November of this year.
Court provided details about MIPS, which has four components. MIPS replaces the existing Physician Quality Reporting System and calls for providers to report on six quality measures. Providers will also be required to report Clinical Practice Improvement Activities (CPIA), choosing from a list of 90 options. The program also includes cost measures, which will be calculated by CMS using Medicare claims. Finally, MIPs includes a component called “Advancing Care Information,” which will replace the existing Medicare meaningful use program for providers.
Jenny Boese, WHA vice president, federal affairs & advocacy, provided the Council with an update on an abruptly-enacted law, the Bipartisan Budget Act of 2015, which impacts some provider-based hospital outpatient departments (HOPDs). She provided an update on legislation, HR 5273, seeking to fix the law for a small sub-set of HOPDs caught up in this issue as well as an overview of the Centers for Medicare & Medicaid Services proposed implementation guidance. That guidance was released in the FY 2017 Outpatient Prospective Payment System proposed rule. WHA believes the guidance is an overreach by CMS and will be submitting comments to that effect by the September 6, 2016 deadline.
Redefining Hospital Community Benefit to Capture Broader Impacts
Attorney David Edquist, von Briesen & Roper presented an historical perspective on the evolution of nonprofit hospital exemptions and the changes in requirements that were included in the Affordable Care Act (ACA). Wisconsin was one of the first states in the nation to survey its member hospitals to collect data related to their health improvement activities. While WHA collects and reports the costs that hospitals incur related to community benefit, the survey does not account for the broader, downstream benefits these services have on the health of a community.
Mary Kay Grasmick, WHA vice president, communications, told the Council that WHA has worked closely with its members on issues related to community benefit reporting, Schedule H and public reporting. Hospitals have grown increasingly sophisticated in how they approach the community health needs assessment and in their implementation of programs and services that improve health status in their regions. However, these efforts are often seen in isolation and not in context to the benefit they bring in terms of reducing health care costs, causing measurable gains in overall community health, which increases worker productivity, and supporting public health.
“Hospitals and health systems provide essential services that, if we were not providing them, would fall to government or other organizations, or just not be available,” Grasmick said. “The bottom line is we want to identify and quantify the financial and societal impact our work is having in communities across Wisconsin.”
WHA is working with Edquist and other experts in the field to develop a new initiative that will give WHA members the tools they need to communicate and redefine community benefit to capture broader impacts.
WHAIC Launches New Data Analysis Tool: Kaavio
Jim Cahoy, senior database administrator for the WHA Information Center (WHAIC), demonstrated the features of a new tool, called “Kaavio,” which allows WHA hospital and health system users to analyze and visualize Wisconsin discharge data. Cahoy said users can easily interact with the Wisconsin discharge data—applying filters, refining parameters, and adding criteria. The changes are instantly reflected in the data. Kaavio presents the data in meaningful graphics that allow users to detect patterns, trends, outliers, and relationships that can help users make important decisions.
The new tool is designed to help WHA hospitals and health systems gain crucial insights into areas such as population health, utilization, patient access, geographic distribution and market share. For more information, contact Brian Competente, WHAIC operations manager, at firstname.lastname@example.org