From Tom's Desk
Canary in the Coal Mine
On June 25th, CMS was expected to release 2014 Medicare Advantage encounter data.
It cancelled at the last minute due to “data problems.”
Conspiracy theories are abounding—mostly about CMS using the extra time to massage the data to protect the interests of the big insurers.
I doubt that’s true. It’s a lot of data, challenging to process and present.
But no one is talking about the enormous red flag this represents.
This is exactly the type of data that’s going to be used to determine the huge payment swings under the MACRA/MIPS program beginning in 2019.
Only MACRA/MIPS involves more than twice as many patients, with ever-changing metrics and parameters.
You’re investing huge amounts of capital hoping to avoid a loss of revenue but the system you’re depending to analyze your efforts on can’t even manage to process a three year old data set with, in comparison, much more limited parameters.
CMS has already had to delay or change payments in other quality programs due to inability to collect and analyze the data. Not to mention delaying ICD-10 three times due to their IT infrastructure's inability to test end-to-end.
With billions on the line and a momentum that's impossible to stop, MACRA/MIPS is going to be train wreck of epic proportions. Absent any statutory relief, you're going to have to accept changes in your cashflow that have basically been decided at random--without respect to any "quality" changes you've made. No way CMS is going to be prepared to crunch the numbers to reflect reality of your efforts. No. Way.
Insurer, organization or individual clinician, if you’re “all in” on MACRA/MIPS, you better have a plan B to cover your expenses.
Come Q1 2019 there's a good chance your cashflow won't.