Avalere Health LLC | The intersection of business strategy and public policy
Will Reform of the SGR
Catalyze P4P in
Medica...
© Avalere Health LLC
Page 2
Agenda
Understanding the Sustainable Growth Rate (SGR) and Its Impact on
Physician Payment
E...
© Avalere Health LLC
Page 3
The Sustainable Growth Rate Was Meant to Control Physician
Spending
“By linking fee updates to...
© Avalere Health LLC
Page 4
SGR Mechanism Determines Spending Target for Physicians
The spending target is updated annual...
© Avalere Health LLC
Page 5
Despite Annual Updates and Revisions, Physician
Expenditures Have Exceeded the Annual Targets ...
© Avalere Health LLC
Page 6
Congress Tends to Override Cuts “Required” Under SGR
1998-2001
<
Actual Physician
Spending
Spe...
© Avalere Health LLC
Page 7
Linking Payment and Performance Requires Activity and
Agreement At Multiple Levels, Across Mul...
© Avalere Health LLC
Page 8
Six Critical Trends Influencing the Adoption of P4P
Payment for outcome, process and/or volume...
© Avalere Health LLC
Page 9
Challenges Affecting the Adoption of P4P Among Physicians
Inertia among physicians, policymake...
© Avalere Health LLC
Page 10
Today, Physician Reimbursement Based On Quality Varies By
Specialty and Practice Size
 Propo...
© Avalere Health LLC
Page 11
NURSING HOMENURSING HOMEHOSPITALHOSPITAL PHYSICIANPHYSICIAN
Examples of Existing Medicare P4P...
© Avalere Health LLC
Page 12
Medicare P4P / P4R Initiatives Tend To Have
Long Gestation Periods
2000 2001 2002 2003 2004 2...
© Avalere Health LLC
Page 13
New Law Links Physician Reimbursement in Medicare to
Quality Reporting
1.5% Bonus Payment for...
© Avalere Health LLC
Page 14
The 2007 Physician Voluntary Reporting Program
Facilitate gathering and analyzing data on the...
© Avalere Health LLC
Page 15
The Legislation Establishes Timeline for Participation and
Expansion
Jan 1:
2007 PVRP
measure...
© Avalere Health LLC
Page 16
The New Law May Encourage Physician Participation in
Pay-for-Reporting
Accelerants
Power of t...
© Avalere Health LLC
Page 17
But, There Remain Several Unresolved Issues That
May Limit Widespread Participation
Retardant...
© Avalere Health LLC
Page 18
MedPAC Believes Payment Incentives For Quality Are Key To
Transforming Physician Payment in M...
© Avalere Health LLC
Page 19
Adoption of P4P in Medicare Is Likely To Rest on Our
Capacity to Answer and Agree These Key Q...
© Avalere Health LLC
Page 20
Assessing the Probability of Adoption of P4P in Medicare:
Keep a Lookout for…
 Results from ...
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  • It is also worth noting that currently, the target system is applied solely to the physician setting. Payment for other provider settings (under Medicare) is determined through a different formula.
  • In 2002, the first year that the SGR target was exceeded, Congress acted to cut physician fees.
    Between 2003 and 2005, the negative updates were replaced with positive updates.
    In 2006 and through TRA 2006, in 2007, payment levels were held at 2005 level.
    It is important to note that the successive cuts under the SGR was not supported by Congressional Support Agencies. MedPAC, for example, has articulated that “consecutive annual cuts would threaten beneficiary access to physician services over time, particularly those provided by primary care physicians.” (MedPAC, March 2006)
  • The study, which based its findings on the group’s Community Tracking Study Physician Survey, examined data from 1996 to 2005.
    According to the findings, compensation based on quality measures increased from 17.6 percent of physicians in 2000-2001 to 20.2 percent in 2004-2005. In a statement, HSC called the increase “small but statistically significant.” However, the survey found that reimbursement tied to physician productivity has consistently ranked as a common incentive for 70 percent of physicians in a non-solo practice since 1996-1997.
  • The PVRP
  • Transcript of "Presentation Material (Powerpoint)"

    1. 1. Avalere Health LLC | The intersection of business strategy and public policy Will Reform of the SGR Catalyze P4P in Medicare? Pay for Performance Summit February 15, 2007
    2. 2. © Avalere Health LLC Page 2 Agenda Understanding the Sustainable Growth Rate (SGR) and Its Impact on Physician Payment Examining Physician Pay-for-Performance (P4P) in the Context of Other Providers Framing Recent Legislation on Physician Payment and the Role for P4P Looking to ’08 and Beyond: Identifying the Critical Issues and Their Impact on Potential P4P Adoption / Expansion
    3. 3. © Avalere Health LLC Page 3 The Sustainable Growth Rate Was Meant to Control Physician Spending “By linking fee updates to spending, the Sustainable Growth Rate (SGR) is intended to provide physicians a collective incentive to control the volume and intensity of physician services.”1 Physician Updates are based on the difference between actual and target spending = = + - < > Actual Physician Spending Spending Target Increase in Fees Decrease in Fees Change in Physician Payment 1 National Health Policy Forum, “Updating Medicare’s Physician Fees: The Sustainable Growth Rate Methodology.” November 10, 2006
    4. 4. © Avalere Health LLC Page 4 SGR Mechanism Determines Spending Target for Physicians The spending target is updated annually, and based on several key components Year 1 Target Spending Year 1 Target Spending X Year 2 SGR Factor (1.007 in ’07) Inflation adjustment (1.026 in 2007) Changes in # of FFS Beneficiaries (0.971) GDP (1.022) Changes in coverage mandated by laws and regulations (0.990) Year 2 SGR Factor (1.007 in ’07) Inflation adjustment (1.026 in 2007) Changes in # of FFS Beneficiaries (0.971) GDP (1.022) Changes in coverage mandated by laws and regulations (0.990) Year 2 Target Spending Year 2 Target Spending= Adapted from National Health Policy Forum, “Updating Medicare’s Physician Fees: The Sustainable Growth Rate Methodology.” November 10, 2006 Initial SGR target based on spending over the 4/1/96-3/31/97 period. SGR targets are both annual and cumulative, and annual payment changes are designed to reduce cumulative overage/underage to zero, over time, with limits to min/max updates (>-7% and <+3%). $81.7 billion in 2006 $82.3 billion in 2007
    5. 5. © Avalere Health LLC Page 5 Despite Annual Updates and Revisions, Physician Expenditures Have Exceeded the Annual Targets Since 2002 Target (allowed) expenditures for respective year, with each target updated annually without rebasing the “starting point,” per current law Actual as reported by CMS 40 45 50 55 60 65 70 75 80 85 90 95 100 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 1.1 2.1 4.7 -4.3 -3.8 -6.1 -10.3 -12 -13.2 $inBillions Source: CMS Final Rule: Medicare Program; Revisions to Payment Policies, Five-Year Review of Work Relative Value Units, Changes to the Practice Expense Methodology Under the Physician Fee Schedule, and Other Changes to Payment Under Part B; Revisions to the Payment Policies of Ambulance Services Under the Fee Schedule for Ambulance Services; and Ambulance Inflation Factor Update for CY 2007. Targets exceeded actual ($ in billions) Actual exceeded targets ($ in billions)
    6. 6. © Avalere Health LLC Page 6 Congress Tends to Override Cuts “Required” Under SGR 1998-2001 < Actual Physician Spending Spending Target 2002 > Actual Physician Spending Spending Target 2003-2007 > Actual Physician Spending Spending Target In Fees* Congressional Action + Complied: Fee Increased - Complied: Fee Decreased - Overridden: Negative update prevented *As mandated by SGR Physician Payment
    7. 7. © Avalere Health LLC Page 7 Linking Payment and Performance Requires Activity and Agreement At Multiple Levels, Across Multiple Stakeholders Structural Readiness System-Level Reforms Measuring Quality Building an environment to encourage 1, 2, and 3 Adjustments at the provider/payer level needed to incorporate P4P Payment Methods 44 33 22 11 FEEDBACK FEEDBACK Defining quality along the healthcare continuum Development of new approaches to link quality to payment
    8. 8. © Avalere Health LLC Page 8 Six Critical Trends Influencing the Adoption of P4P Payment for outcome, process and/or volume Variation in readiness to adopt measures by provider setting Role of HIT in defining, collecting, and disseminating quality measures Choice of transitional strategy to P4P* Degree of focus on development of specialty measures Ability to span silos created by provider setting or patient disease 11 22 33 Payment Methods Structural Readiness 55 66 Measuring Quality System-Level Reform 44 *Efforts to introduce P4P begin with incentives for providers to report data on quality measures; also known as pay-for-reporting
    9. 9. © Avalere Health LLC Page 9 Challenges Affecting the Adoption of P4P Among Physicians Inertia among physicians, policymakers and payersSystem-Level Reform Structural Readiness Measuring Quality Limited patient sample size (particularly at the small physician practice level) Limited measures (particularly at the subspecialty level) Limited data for benchmarking Boundary issues Upfront investment needed to establish infrastructure for quality reporting (HIE) 11 22 55 66 77 88 Payment Methods Policy questions surrounding the expansion of gainsharing33 44 Limited consensus around the magnitude of incentives need to motivate adoption
    10. 10. © Avalere Health LLC Page 10 Today, Physician Reimbursement Based On Quality Varies By Specialty and Practice Size  Proportion of physician compensation based on quality increased from 17.6% in 2000-01 to 20.2% in 2004-05 » Reverses a significant decline in proportion found between 1998-99 and 2000-01 Source: Center for Studying Health System Change, “Physician Financial Incentives: Use of Quality Inches Up But Productivity Still Dominates.” January 2007 Physicians Reporting Performance on Quality Measures is a Factor Used in Compensation, 2004-05 Quality is a Compensation Factor Primary Care Physicians Medical Specialists Surgical Specialists 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% Small Group (<10 physicians) Medium Group (10-29 physicians) Large Group (30+ physicians) Hospital and other settings By Specialty Type By Provider Size
    11. 11. © Avalere Health LLC Page 11 NURSING HOMENURSING HOMEHOSPITALHOSPITAL PHYSICIANPHYSICIAN Examples of Existing Medicare P4P / P4R Programs  Hospital Compare* Reporting Public Reporting  Premier Hospital Quality Incentive Demonstration  Medicare Health Care Quality Demonstration**  Reporting Hospital Quality for Annual Payment Update*  Gainsharing Demonstration  Hospital Compare* Reporting Public Reporting  Premier Hospital Quality Incentive Demonstration  Medicare Health Care Quality Demonstration**  Reporting Hospital Quality for Annual Payment Update*  Gainsharing Demonstration  Nursing Home Compare Public Reporting*  Nursing Home P4P Demonstration**  Nursing Home Compare Public Reporting*  Nursing Home P4P Demonstration**  Medicare Physician Group Practice Demonstration*  Medicare Care Management Performance Demonstration**  Physician Voluntary Reporting Program*  Medicare Physician Group Practice Demonstration*  Medicare Care Management Performance Demonstration**  Physician Voluntary Reporting Program* *Pay-for-reporting Initiatives **Implemented with phased-in approach: pay-for-reporting evolves to pay-for-performance NOTE: Programs sorted from oldest to most recent (based on establishment through law or regulations)
    12. 12. © Avalere Health LLC Page 12 Medicare P4P / P4R Initiatives Tend To Have Long Gestation Periods 2000 2001 2002 2003 2004 2005 2006 BIPA 2000  Physician Group Practice MMA  Medicare Health Support (Sec. 722)  Medicare Care Management Program (Sec 649)  Medicare Health Care Quality Demo (646)  Medicare Value Purchasing Act 2005 (Senate and House Versions)  Medicare Physician Payment Reform and Quality Improvement Act of 2006  In January, CMS initiates PVRP** as part of its quality improvement initiative TRHCA***  Physician Payment and Quality Improvement (Division B, Title I, Section 101) *Medicare Modernization Act **PVRP is Physician Voluntary Reporting Program ***Tax Relief and Health Care Act Introduced, but never passed
    13. 13. © Avalere Health LLC Page 13 New Law Links Physician Reimbursement in Medicare to Quality Reporting 1.5% Bonus Payment for all Medicare covered Part B servicesIncentive 2007 Physician Voluntary Reporting Program Measures (PVRP)Measures  Physicians  Physician Assistants  Nurse Practitioners  Qualified Speech-Language Pathologists  Other Medicare Covered Part B Providers Eligible Providers The Tax Relief and Health Care Act of 2006 details the specifics of the quality reporting program
    14. 14. © Avalere Health LLC Page 14 The 2007 Physician Voluntary Reporting Program Facilitate gathering and analyzing data on the quality of physician care provided to beneficiaries to improve the quality of care Implemented Conditions Covered by Measures Objective  New measure set of 66 released October 2006  Reporting on new set began on January 1, 2007  Cardiac care  Diabetes  End-stage renal disease  Glaucoma, macular degeneration, and cataracts  Osteoporosis  Melanoma  Depression  Elder care  Physical medicine  Nuclear medicine  Interventional radiology  Radiation oncology Specialties Without Measures* Source: http://www.cms.hhs.gov/PVRP/01_Overview.asp; Inside Health Policy, “Therapy Providers Scramble To Create Quality Measures To Receive Bonuses Next Year.” December 20th , 2006 *Four of six specialties without measures listed
    15. 15. © Avalere Health LLC Page 15 The Legislation Establishes Timeline for Participation and Expansion Jan 1: 2007 PVRP measures in effect Jan 31: Revisions to measures completed April 1: Revised measure published July 1: 2007 Reporting program begins August 15: 2008 measures must be released for public comment November 15: 2008 measures must be published in the Federal Register Dec 31: 2007 Reporting program concludes Jan 1, 2008: Absent Congressional/CMS intervention, physician payments face a ~ 10% cut
    16. 16. © Avalere Health LLC Page 16 The New Law May Encourage Physician Participation in Pay-for-Reporting Accelerants Power of the law Consistent with the approach for hospitals and nursing homes, the legislation now establishes physician pay-for-reporting Provides a phased-in approach Allows providers time to adapt by providing incentives for reporting No timeline to move from pay-for-reporting to pay-for-performance; reduces anxiety Expands already existing CMS program (PVRP) May mitigate physician inertia since it leverages already established program Provides bonuses not penalties May improve physician buy-in by providing a carrot not a stick +
    17. 17. © Avalere Health LLC Page 17 But, There Remain Several Unresolved Issues That May Limit Widespread Participation Retardants Establishes 6 months reporting period for 2007  May limit ability of program to gain momentum  May be insufficient time to adequately assess program results  Requires additional legislative action to continue reporting program in 2008 Establishes initial bonus payment at 1.5%  Remains unclear whether 1.5% bonus payment will be sufficient Limits pool of measures to approved PVRP measures May exclude specialty providers for whom no consensus measures exist Deadline to revise measures is Jan 31 May further restrict meaningful revisions to existing measurement set -
    18. 18. © Avalere Health LLC Page 18 MedPAC Believes Payment Incentives For Quality Are Key To Transforming Physician Payment in Medicare For the Commissioners, though the nature of the transformation is unclear… “Pathway One” “Pathway Two”  Repeal SGR and expenditure target  Develop and adopt new approaches for improving value » Options to improve value to be outlined in MedPAC’s March 2007 report  Expand expenditure targets to encompass ALL providers  Expenditure targets based on geography  Provisions to spur greater care coordination  Incorporation of quality and efficiency ratings …pay-for-performance provisions are likely to be part of any SGR reform Sources: Avalere Summary of MedPAC Public Meetings, Jan 8, 9, 2007 CQ HealthBeat, MedPAC Fix For Flawed Doctor Payment System May Mean Transforming Health System, Jan 10, 2007 OR?
    19. 19. © Avalere Health LLC Page 19 Adoption of P4P in Medicare Is Likely To Rest on Our Capacity to Answer and Agree These Key Questions Is the motivation to improve quality or to save money? How well do incentives work in improving quality? Measuring Quality How can HIE encourage the collection and dissemination of quality data? How do we overcome the infrastructure challenges faced by small practices? What are we measuring? Process improvements, quality-of-care-delivered, and/or health outcomes? How will we overcome the methodological issues? 66 77 88 33 44 Structural Readiness Pay-for-reporting, pay-for-performance, pay-for- improvement, or pay-or-don’t be-paid? What is the right type of incentive to motivate adoption? Payment Methods 11 22 System-Level Reform 55
    20. 20. © Avalere Health LLC Page 20 Assessing the Probability of Adoption of P4P in Medicare: Keep a Lookout for…  Results from other P4P efforts  The initial assessment of the success of PVRP  Consensus among Congressional Support Agencies* on the future of SGR  Greater specificity on the role of quality in payment reform  Momentum from provider stakeholders (AMA, other specialty groups) to expand efforts  Congressional action to continue (expand) programs, particularly, PVRP Congressional Support Agencies include: MedPAC, GAO and CBO
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