Keep Reporting MIPS Anesthesia Quality Data in 2019: Here’s Why

As noted in our December 17, 2018 eAlert, the budget neutrality required by MACRA for the Merit-Based Incentive Payment System (MIPS)—coupled with the high performance by the vast majority of participating anesthesia and chronic pain management groups in the Quality Payment Program (QPP)—means that providers within the specialty are unlikely to earn significant bonuses through MIPS participation for performance year 2019 (payment year 2021).

The outlook was more optimistic when the Centers for Medicare and Medicaid Services (CMS) launched the QPP, ABC Chief Quality Officer Bryan Sullivan observes in his lead article for this issue of Communiqué, “MACRA Financials for Anesthesia Practices: What We’ve Learned So Far.” By allowing practices more flexibility in MIPS performance year 1 (the year of the “pick your pace” option), “far more practices were able to avoid a penalty, and thus, not fund the bonus side of the program,” he writes. “The lack of funding on the penalty side deeply depressed the bonus for exceptional performers.”

Despite these financial realities, continued participation “provides the most flexibility in negotiations with payers and facilities and serves as a continual performance metric,” Mr. Sullivan says. In short, for those of you who have been MIPS participants: carry on. (Also see our eAlert for the 2019 anesthesia quality measures awaiting CMS approval so you can begin planning for the new year.)

Also in this issue:

• Lorraine A. Morandi, MA, director of human resources for Plexus Management Group, LLC, explores a topic we’re covering in the newsletter for the first time: the vital and integral role of human resources in effective anesthesia practice management. Ms. Morandi touches on 10 top HR-related issues facing anesthesia groups in 2019, observing that practices too often neglect HR as financial planning and other practice management priorities demand their attention. She urges anesthesia groups not to lose sight of HR’s value in solidifying a group’s culture and reinforcing its ability to draw qualified professionals to the practice and build a productive and satisfied team.
• Will Latham, MBA, of Latham Consulting Group, probes the ways in which anesthesia groups can incentivize members to deliver value. “Given the fact that, in many cases, anesthesia group shareholders have limited expectations to do anything (other than provide clinical care), anesthesia group leaders need to look at various ways to motivate group members to focus on and provide the value that stakeholders demand,” writes Mr. Latham, a frequent Communiqué contributor, who will be speaking at this year’s ASA practice management conference in Las Vegas. He points out the problem practices often run into by assuming that money offers the most powerful motivator: “If money is the only incentive you use, people will only do the things that generate money.” Engage members, support group leaders, recognize those who provide important service and establish normative behaviors via a Code of Conduct to avoid disincentivizing members, he recommends.
• Jody Locke, MA, vice president of anesthesia and pain practice management services for ABC, asks us to imagine “Uberism” in anesthesia. Can the same business principles behind the wildly successful appdriven transportation service be applied to our specialty? “Hospital administrators have started to adopt an Uber mentality regarding their requirements for anesthesia services” in their desire for 24/7 coverage without having to pay providers when they are not caring for patients, Mr. Locke writes. “Like Uber, they only want to pay for actual service.” What would it take for the specialty to achieve a win/win situation similar to the model that has brought new convenience and cost-effectiveness to transportation?
• Mark F. Weiss, JD, of the Mark F. Weiss Law Firm, provides an update on an area some providers have been asking about recently: the “company model,” under which referring physicians, who own a facility where surgical procedures are performed, form a separate anesthesia company in order to share in anesthesia revenue. The ASA has long opposed the model as “fraudulent and abusive” to anesthesia practitioners and patients. Mr. Weiss explores the intricacies of this topic, noting that, while “it’s not the case that any specific law or regulation makes, in blanket fashion, company model deals illegal . . . the bottom line is that each arrangement within the rubric of the company model must be scrutinized extremely carefully.”

We look forward to seeing many of you at PRACTICE MANAGEMENT® 2019 in Las Vegas and extend our wishes for a fulfilling and productive new year.

With best wishes,

Tony Mira
President and CEO