The introduction of the Physician Quality Reporting Initiative (PQRI) signaled how Medicare planned to move from volume-based fee-for-service physician payments to a system of value-based care. The PQRI program was voluntary and offered physicians the opportunity to participate in the national incentive program by reporting quality data on specific measures. At that point, PQRI was all carrot and no stick, with the potential to earn an extra 1.5% of Medicare Part B payments as a reward for successful reporting. PQRI transitioned to the Physician Quality Reporting System (PQRS) in 2011 and became mandatory in 2015 with the passage of The Medicare Access and CHIP Reauthorization Act (MACRA). Incentive payments for successful participation continued and penalties (payment adjustments) were also introduced.
Strategic Decisions
MSN had participated in Medicare’s foray into quality reporting since the voluntary PQRI stage and in 2015, leadership weighed the future implications of Medicare’s commitment to a new Quality Payment Program. This involved a number of key strategic decisions. Should MSN tap into the market’s available registry options or create its own? Should it be a Qualified Registry (QR) or a Qualified Clinical Data Registry (QCDR) since the QR option would require fewer resources to develop and maintain? What would it take to develop a program that would truly offer value-added services for MSN billing and practice management clients?
Bo Trotter, MSN Founder and President, acknowledged the level of commitment required to launch and maintain the QCDR. “At the time,” he said, “we didn’t know if a QCDR would be financially sustainable and had to balance that risk with the value we knew it would provide to our clients. There were initially many QCDR options available in the market but the regulatory demands made it challenging to stay in the game. In the end, we decided in favor of providing a valuable benefit to MSN clients and invested in both the technology and team expertise it would take to succeed. It was the right thing to do.”
Claudia Murray, one of the MSN experts leading the organization’s quality journey, concurs. “After a few years of learning the ins and outs of reporting, it was evident Medicare would most likely not only continue, but expand, the program. We had learned enough to feel we could successfully provide value to MSN clients while maybe assuming a leadership role in the industry.”
In the end, MSN did not take the easier route but invested in the people and technology to launch and maintain a CMS-approved QCDR. This represented an intricate junction of processes, data analysis, forecasting and expertise—demands few independent practices could support on their own. For example, MSN QCDR leadership observed that, as available national measures eventually “topped out” and were retired, practices relying on the QR option found it difficult to achieve performance levels earning positive payment adjustments. MSN elected to work with practicing physicians to develop new measures for CMS approval and has consistently been a leading contributor of new quality measure options.
Marissa Pearce, MSN Executive Director of Quality Payment Programs noted, “MSN’s Radiology and Pathology Quality Measure Development Workgroups have been instrumental in bringing more than twenty quality QCDR measures to the MIPS program. We thank our dedicated workgroup members and other clinicians who have assisted us in developing and testing quality measures over the years. Without that dedication and expertise, many groups would have found it impossible to avoid a penalty.”
MSN continued to learn during the 10 years since the registry was first launched and the results are impressive. MSN QCDR clients have earned twice the national average in positive payment adjustments. In 2024, the most recent performance year published by CMS, MSN QCDR clients earned an average MIPS Score of 91.97 vs. the National Average MIPS score of 83.27. And MSN continues to work with their clients to prepare for success under future iterations of the program.
Standard Services
The MSN QCDR offers two service levels, beginning with a baseline standard program designed to support the group with an internal MIPS team. Services include:
- Access to reporting QCDR measures
- Annual planning/strategic call with MIPS experts
- Monthly feedback reports outlining year-todate performance, peer-average benchmarks and provider-specific report cards
- Educational resources including MSN’s Provider Documentation Guide and webinars
- Access to MSN’s QCDR Portal for secure, real-time access to “missed” encounters
- Annual list of improvement activities and highlighting those common to your specialty
- Optimization of MIPS score after year-end, with recommendations on measures to report
- End-of-year timely submission of MIPS Data to CMS
- Accuracy Review of final QPP feedback report from CMS for score calculations, with assistance if errors are found
- Audit assistance, if practice is chosen by CMS for an audit
MIPit Add-On Service
MIPS consulting (MIPit) is an optional concierge service to help increase the practice’s MIPS score and maximize incentive payments. MSN’s MIPS experts provide expertise, advice and guidance that can help improve MIPS scores and potentially maximize incentive payments.
MIPit provides all services listed in the standard agreement as well as the enhanced services, including:
- Monthly meetings with a dedicated MIPS expert to review performance, prioritize efforts, answer questions and provide guidance
- Cost analysis to review and positively impact cost scores
- Forecast of MIPS scoring, including estimated payment adjustments and financial impact throughout the year
- Development of a customized MIPS strategy, including quality measure and improvement activity selection
- Regular performance monitoring and identification of trends
- Filing of Extreme and Uncontrollable Circumstance Applications if applicable
- Interpretation of MIPS regulatory changes as they relate to your practice to prepare you for future success
Value-Based Payment Consulting (VBP)— Beyond MIPS
Some practices have the option of joining an ACO or have found their providers unknowingly associated with APMs and it is impacting their MIPS payments. Others have been approached by their commercial insurance carriers who have begun implementing value-based payment programs of their own. MSN offers consulting options to help clients navigate through the full range of options.
Projects have included:
- Review and evaluation of value-based performance contracts
- Employer-based insurance programs
- Performance improvement under VBP contracts
- Consulting on pros/cons and considerations of joining a Clinically Integrated Network (CIN) or Accountable Care Organization (ACO)
- Analysis and guidance regarding Alternative Payment Models (APM) payments
- Evaluating the economic impact of success/failure under a VBP contract
The Future
There is no doubt Medicare’s focus on value-based payment will continue to evolve and drive more provider accountability, increased competition and an increasing financial impact. MSN’s QCDR continues to mature as well and leadership monitors and adjusts service offerings to keep pace.
Under MIPS, increasing penalties (the stick) now outweigh the benefits of positive payment adjustments (the carrot). Newer models introduced by CMS, such as the Ambulatory Specialty Model (ASM) that goes into effect January 1, 2027 start with penalties at 9% but ramps up to 12% penalties by 2031.
CMS continues to expand their inventory of MIPS Value Pathways (MVPs) and announced the sunsetting of traditional MIPS after 2028, leaving fewer options with more clinically relevant and challenging measures. CMS has expressed a desire to eventually score providers against others in the same specialties, rather than against all other providers in the nation, further increasing competition.
With so many changes on the horizon, now is a pivotal moment to stay aware and ahead of CMS proposals as the QPP continues to mature. MSN’s QCDR and MIPiT experts remain up-to-date on regulatory changes, providing constructive input to improve clients’ current and future positions under these programs.
Beyond just Medicare, MSN also monitors commercial insurance quality programs and assists practices wishing to participate in them. As nongovernmental plans observe the success of QPP, we anticipate a continued expansion of programs in this arena as well.
The government’s quality payment programs have evolved over the 10 years of MSN’s QCDR. Certain aspects, such as the weight, inclusion and discontinuation of certain measures for example, have been modified as the program itself continues to evolve.
