First steps toward APM participation for radiologists

2018 03 16 20 44 0625 Morris Richard 20180316203124

There's no doubt that Medicare's payment for physician services is moving toward a value-based system, and many other healthcare payors are following that lead. The U.S. Centers for Medicare and Medicaid Services (CMS) is mandated under the Medicare Access and CHIP Reauthorization Act (MACRA) to implement value-based payments.

So far, most radiology practices are struggling to comply with the Merit-Based Incentive Payment System (MIPS) branch of the two-pronged MACRA system, but the goal of CMS is to eventually move all physicians to the other branch: alternative payment models (APMs).

Working within MIPS

Richard Morris, director of value-based strategy at Healthcare Administrative Partners.Richard Morris, director of value-based strategy at Healthcare Administrative Partners.

The transition to the APMs can begin while a practice is still working within MIPS. For example, participation in specific MIPS improvement activities (IAs) will position the radiology group to become part of an APM at the appropriate time. One IA solution that is readily available to radiologists is the American College of Radiology's (ACR) Radiology Support, Communication, and Alignment Network (R-SCAN).

R-SCAN is a collaborative action plan that brings radiologists and referring clinicians together to improve imaging appropriateness based on a growing list of imaging Choosing Wisely topics developed by the ACR. It prepares radiology practices for a future of value-based payment models by allowing radiologists and referring physician practices to fulfill IA credit requirements.

Reducing inappropriate imaging seems like the best way for radiologists to get started in value payment programs, particularly as accountable care organizations (ACOs) begin to expand, according to an article in the ACR Bulletin by Dr. Gregory Nicola, chair of the ACR MACRA Committee.

"As ACOs mature, they will need to look deeper to find ways to save, and they're going to look at inappropriate imaging," Nicola wrote. "Participating in R-SCAN now can show an ACO that your radiology group is proactive and already managing imaging patterns. It's better to be early than late to this game, because ACOs may find ways to control imaging utilization without you -- and then you're a commodity."

Partnership with other physicians

Radiologists can partner with primary care doctors who are motivated to avoid ordering inappropriate imaging. This has the added benefit of preparing the practice for Medicare's rule that will require ordering physicians to use a clinical decision-support (CDS) system to consult appropriate use criteria (AUC) beginning in 2020.

There are also opportunities to enhance the radiology group's relationship with other hospital-based physicians, such as those in the emergency department (ED). ED physicians may be participating in their own emergency quality network, which is a support and alignment network (SAN) complementary to R-SCAN.

Pros and cons of APM participation

Improving patient care is the real reason for participating in any quality improvement program, but the considerations that arise before embarking on a project like this include a financial component, whether it is enhanced reimbursement or penalty avoidance. The Harvey L. Neiman Health Policy Institute in 2017 reported that only 20% of ACOs existing at that time had any radiologist participation.

Until collaborative programs such as those described above are implemented, inappropriate imaging will not be reduced and, therefore, participation in shared savings for radiologists will be minimal.


Nicola reminded us of the following in another ACR Bulletin article: "It's important for radiology groups to know there will be a redistribution of Medicare payments from groups that don't make value-based changes to groups that do."

Currently, most groups are participating in MIPS, at least to the extent that they will avoid a payment penalty. Learning how to maximize reimbursement under MIPS while preparing for APM participation is the strategy forward-thinking radiology groups will adopt.

Richard Morris is the director of value-based strategy for Healthcare Administrative Partners.

The comments and observations expressed are those of the author and do not necessarily reflect the opinions of

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