Are You Ready for P4P?
As payers step away from fee for service, they’re taking a closer look at your outcomes.
BY JOSEPH BURNS
For better or worse, pay for performance is coming. Though it has yet to take hold in significant numbers, within the next year or two ophthalmologists can expect to see the widespread implementation of pay for performance (P4P) and other compensation systems such as bundled payment and risk-sharing agreements, according to consultants and practice administrators.
With P4P comes the obvious potential advantage of more income. But it also brings downsides as well. Practices may need more robust information systems to collect the data and perform the analyses they’ll need to develop new performance metrics. Seeking to ease the data collection and performance analysis burden, the American Academy of Ophthalmology is testing a new system to gather and report data from EHRs that one advocate says could solve many of the problems inherent in measuring and analyzing physician outcomes. (See “‘Game Changer’: AAO Registry Will Support Practices in Data Collection,” page 56.)
Risk Sharing Is Coming
Factors driving the movement to P4P include the passage of the Affordable Care Act in 2010 and the development of patient-centered medical homes, accountable care organizations (ACOs) and physician-hospital organizations (PHOs) that push payers and physicians to share the financial risk of delivering care, says David Dopp, administrator of the Wheaton Eye Clinic, a practice outside Chicago with 27 ophthalmologists.
Each of these factors is forcing the health-care system away from fee-for-service payment based on volume toward payment based on value. The challenge for ophthalmologists is to recognize how payers define value. One way involves having eye specialists share the savings they generate or share the financial risk of delivering care.
“There will be more risk sharing among all providers,” says Mr. Dopp who also is executive director of DuPage Valley Physicians, an independent practice association of 358 multispecialists. “All physicians will be affected, including ophthalmologists and other eye specialists,” he says.
Ophthalmology may not be among the first specialties to share risk or adopt P4P arrangements because it does not contribute to hospitals’ bottom lines as other specialties do, Mr. Dopp says. Instead, the first wave may take in cardiologists and orthopedists. “But there’s no doubt that ophthalmology will move in that direction as well,” he predicts.
Capitation Déjà vu
Risk sharing may take the form of capitation models that were prevalent in the 1980s and 1990s and are now being implemented again, Mr. Dopp says. Also, payers may adopt bundled payment systems in which physicians get a set price for a procedure. The set price may cover all costs for cataract surgery, for example, including the ASC or hospital fee, he adds.
Bundled payment for eye surgery, although rare today, is ideal for cataracts, says William L. Rich, III, MD, FACS, the AAO’s medical director of health policy. Dr. Rich is also a senior partner in Northern Virginia Ophthalmology Associates, an 11-physician practice in Fairfax, Va. “Potentially there is a significant amount of money to be made in shared risk or shared savings arrangements for eye surgery,” Dr. Rich says. “In fact, it will be easier to do with eye surgery than it is with hips and knees.”
The volume of cataract surgeries — some 3.2 million such surgeries were done in 2010, according to the Centers for Medicare & Medicaid Services (CMS) — make it an ideal candidate for bundled payment, Dr. Rich adds. Yet, hip and knee replacements are among the most common surgeries that health plans and CMS are covering under bundles.
Bundled payment is one way for plans to contain costs and shift the risk of complications to providers because, as Dr. Rich points out, the ophthalmologist is responsible for the patient throughout the entire episode of care, including any postoperative complications.
Shared Risk, Shared Rewards
In addition to sharing the risk, payers also are willing to share the savings that ophthalmologists can produce by doing procedures more efficiently. Mr. Dopp cites LASIK surgery as an example. Years ago, such surgery was costly and time consuming. But after years of doing this laser refractive procedure many times over, ophthalmologists have become more adept and more efficient. Also, competition helped drive down the price.
“Physicians who have relationships with ambulatory surgery centers have already seen what happened with LASIK procedures,” Mr. Dopp explains. Similarly, payers will want lower prices for certain common procedures, and so will patients who will be paying more out of pocket, he adds. “The day will come when you will see cataracts and the surgical side of ophthalmology moving in the same direction: toward lower payment,” Mr. Dopp says.
The movement toward incentive-based payment formulas results from a shift away from paying for volume, says Jeffrey B. Milburn, a compensation consultant with the MGMA Healthcare Consulting Group in Colorado Springs. “In addition to productivity bonuses that many practices have, at least 25% of practices have other financial incentive systems in place or they are giving them serious consideration,” he says.
“I wouldn’t be surprised if over the next three to five years we see 50% to 75% of most physician reimbursement tied to an incentive payment system,” Mr. Milburn adds. He foresees practices adding financial incentive payments for physicians who achieve clinical quality targets. Eventually they will move to risk-based population management resembling capitation, and medical and surgical subspecialties will need to participate with these new models, he says.
Are the Rewards Enough?
CMS is promoting increased value through the Physician Quality Reporting System (PQRS). The problem with PQRS is that the rewards, which were about 0.5% of Medicare’s annual payment to a physician or group in 2012, may not be enough to get ophthalmologists’ attention, says Donald U. Stone, MD, at the Dean McGee Eye Institute at the University of Oklahoma College of Medicine. In fact, among all specialties qualifying for PQRS incentive payments in 2010, ophthalmology ranked first in average incentive payment received, but that only amounted to $7,751 per provider (TABLE).
TABLE: PQRS Incentive Payments by Specialty: The Top 5 | |||||
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Specialty | Eligible Physicians Qualified | Maximum Incentive | Mean Incentive | Median Incentive | Total Payments (millions) |
Cardiology | 6,798 | $62,655 | $6,583 | $5,642 | $44.75 |
Ophthalmology | 5,216 | $81,073 | $7,751 | $6,182 | $40.43 |
Internal Medicine | 15,844 | $34,604 | $2,226 | $1,537 | $35.27 |
Emergency Medicine | 27,772 | $16,106 | $1,187 | $971 | $32.95 |
Radiologist | 9,461 | $119,864 | $2,811 | $2,105 | $26.60 |
Source: Physician Quality Reporting System; data for 2010 |
Dr. Stone and his university colleagues published research last year in Archives of Ophthalmology on how PQRS will impact ophthalmologists specifically.1 Funded in part by a grant from the Research to Prevent Blindness foundation, their research showed that implementation of the Physician Quality Reporting Initiative (or PQRI as it was called until this year), did not result in improved documentation of practice patterns.
“The amount of money from PQRI was not enough for ophthalmologists to make a difference in their usual practice patterns,” Dr. Stone says. “Also, most of the ophthalmologists were already following best practices but some of them may not have been checking the appropriate boxes to document compliance with PQRI,” he explains.
The research showed a slight difference in practice patterns before and after PQRI was introduced, from 80.9% compliance before PQRI was implemented to 77.9% in the first year of PQRI implementation. “From this research, you could argue that PQRI is one way to introduce pay-for-performance and that it is successful in getting ophthalmologists to check boxes on patients’ charts. But in terms of affecting practice patterns, it may not have that much of an effect,” Dr. Stone concludes.
Compliance Under PQRS
To be sure, rates of 78% to almost 81% are fairly high. Among ophthalmologists, compliance rates for PQRS (as the program is called now) fall in a range from 40% to 46%, says Dr. Rich, adding that AAO is working to improve those numbers. In agreement with Dr. Stone, Dr. Rich says many ophthalmologists are likely following best practice guidelines but simply failing to check the appropriate boxes on patients’ charts. To assess the difficulty of gathering information for P4P, Dr. Rich’s practice has been collecting data on complication rates and how many patients returned to the operating room within 30 days of surgery.
“For a cataract surgery bundled payment initiative, you might anticipate having to report to CMS the number of patients, the complication rate, how many times patients return to the OR in 30 days, and patient-reported outcomes or quality of life benefit,” Dr. Rich says. “To report on patient satisfaction and patient-reported outcomes, a practice needs to survey its patients and collect, analyze, and report the resulting data. Such data collection and reporting is time consuming and costly and has to be considered as part of your underlying cost, not just your surgical time.”
‘Game Changer’: AAO National Registry Will Support Practices in Data Collection |
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This year, the AAO will test a national clinical registry system that has the potential to support ophthalmologists in many significant ways, says the AAO’s William L. Rich III, MD, FACS.
The registry system will collect data from individual ophthalmologists and ophthalmology groups regardless of the EHR systems they use. It will report data to CMS for the Physician Quality Reporting System (PQRS) and for the Physician Feedback/Value-Based Payment Modifier Program. It will also allow ophthalmologists to comply with the government’s meaningful use standards for EHR and with the AAO’s Maintenance of Certification requirements, Dr. Rich says. “We are testing the system this year in six practices and plan to introduce it to more practices next year,” he says. “We hope to have 2,200 ophthalmology sites using this system by 2015 and then will roll it out to more practices after that.” Getting EHRs to Talk “Because it will collect data from EHRs, this is a complex undertaking that has the potential to improve outcomes and professional performance while also advancing the science of ophthalmology,” Dr. Rich says. “Having a national clinical registry is potentially a game changer in how we do clinical research and in how we evaluate new drugs and devices. It could be the biggest change I’ve seen in ophthalmology in 40 years.” Most EHRs do not communicate with each other and so collecting data from every ophthalmologist in every practice setting, including hospitals and ambulatory surgery centers, is all but impossible. For this reason, the AAO needed what Dr. Rich calls a software systems integrator. “This integrator is EHR neutral and can extract all the data you need for quality reporting,” he says. “When it’s connected to a practice, everyone in the practice contributes to the data warehouse. That means you could compare yourself in an instant to your competitors or colleagues and/or see how your practice compares with others around the country. You could also look at how you’re meeting benchmarks however you define them. “Data collection on this scale hasn’t been done before,” he says. “That’s why it’s a game changer for ophthalmology and possibly for all of medicine.” |
Recognizing the demands data collection places on practices for P4P or PQRS, the AAO is developing an electronic data collection system that will gather numbers from individual physicians’ and groups’ EHRs and compile the data into a patient registry. To be introduced in six beta sites this year, this system will allow ophthalmologists to increase the current level of PQRS compliance from about 46% to 90% or higher, Dr. Rich says.
How Physician Compensation Models May Look in a P4P World |
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Most private physician practices either have a pay-for-performance program or are considering one, says Jeffrey B. Milburn, consultant with the MGMA Healthcare Consulting Group. Interestingly, private practices offer P4P bonuses of 5% to 10% of a physician’s total compensation but large integrated health systems offer P4P bonuses of 10% to 20%, he says.
“If you’re offering an ophthalmologist $1,000 in a yearend P4P bonus, they might not pay any attention to that amount,” he says. “To be meaningful to most doctors, the rewards have to be at least in the 5% to 10% range. At that level and above, they will pay attention and take action to get the incentive.” Here are five other strategies for making P4P work in the practice: ► Incentives should be true. Incentive payments should add to physicians’ take-home pay rather than withhold a portion of salary and require the physician to earn the amount back by achieving certain targets, Mr. Milburn says. “Occasionally I see combination systems, meaning a 5% withhold where the physicians have to do certain things they should be doing anyway such as attending meetings or getting paperwork done on time,” he adds. “Then, another 5% is additive and paid if the physicians do extra work or meet metrics that are above the norm. “In the long run, such combination plans may work well because they make sure doctors focus on what needs to be done and allow for a performance bonus when they do extra work or hit targets beyond the normal ones,” Mr. Milburn says. ► Define clinical goals. The most common financial incentives practices have paid doctors have been based on productivity. Today, practices commonly add incentives for reaching clinical targets and improving patient satisfaction. An example of a clinical goal is ensuring that all diabetes patients have an annual eye exam. ► Set multiple targets. This is important when implementing P4P rather than having one financial incentive linked to one metric, Mr. Milburn says. If the physicians fail to achieve this one goal, they could lose interest in the program. “But on the other hand, you don’t want too many metrics either. The ideal might be to have three to five metrics,” Milburn says. “Then the physicians have an improved chance of achieving one or more of the metrics to earn a reward. Having multiple metrics also allows the practice to revise the offerings once physicians reach a certain level, such as 90% compliance with one goal. You could delete one target and add a new clinical metric or one that encourages physicians to meet a practice strategy, such as increasing new patient visits.” ► Targets should be achievable. Impossible targets could cause physicians to lose interest, Mr. Milburn advises. “Getting physician input into the targets will help gain support for the metrics,” he says. “That means when implementing clinical targets for ophthalmology, they must pertain to ophthalmology.” ► Use credible data. Physicians need to trust the data that defines their performance. “If they don’t trust the data, they won’t pay any attention to it,” he says. |
How AAO’s Registry Works
This ophthalmic clinical registry will allow all ophthalmologists to see their own PQRS compliance scores and other practice metrics and compare them with competitors, national averages or other benchmarks. It will collect the requisite data automatically from each practice’s EHR and then submit that data to CMS and other payers. In this way, the system will help ophthalmologists comply with PQRS and avoid any noncompliance penalties. In addition, it will help practices comply with CMS’ Physician Feedback/Value-Based Payment Modifier Program and meet the government’s meaningful use standards for EHRs.
The Physician Feedback/Value-Based Payment Modifier Program is part of CMS’ efforts to push toward a value-based rather than volume-based payment model, CMS says. The program will use PQRS data that CMS will then report back to physicians in the form of comparative performance information, CMS says. Physicians and groups can use the data to improve the quality and efficiency of care they deliver.
“Practices will want to avoid the penalties in 2015 under PQRS, the value-based modifiers and meaningful use because those penalties could average 5% to 7% per year and will be compounded every year,” Dr. Rich says. “For all ophthalmologists, the revenue we get totals almost $6 billion per year. On that amount, 5% to 7% is a big number. For my group with 11 physicians, that’s a couple hundred thousand dollars.”
While P4P may not be present in many practices now, it is coming and will take a wide variety of forms. To achieve the maximum possible rewards, ophthalmologists first will need to put in place the systems required to collect and analyze the requisite data. OM
REFERENCE
1. Nikpoor N, Butt AL, Hromas AR, Stone DU. Effect of the physician quality reporting initiative on ophthalmologists’ documentation of practice patterns. Arch Ophthalmol. 2012;130:1351-1352.
Joseph Burns (www.josephburns.net) is a writer and editor in Falmouth, Mass., who specializes in health care. |