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Advanced Care Planning MACRA ALEC M. ANDERS, MD FAMILY MEDICINE PRACTITIONER

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Page 1: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Advanced Care Planning

MACRA

ALEC M. ANDERS, MD

FAMILY MEDICINE PRACTITIONER

Page 2: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Who Can Perform ACP Services

oPhysicians

oNon Physician Practitioners whose scope of practice includes independent CMS billing and the delivery of Advanced Care Planning services

Page 3: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Talking to the Patient

Who starts the conversation?

•Patient can initiate conversation

•Physician can initiate when there has been a change in status or a transition in care

•Advance care planning is voluntary, patient’s discretion

•Face-to-face only; no telemedicine

•Patient must be present unless he or she lacks capacity

Page 4: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Conversation Points

What do practitioners talk about?

◦ Quality of life expectations through transitions in health

◦ Patient’s preferences for treatment and options for achieving

goals

◦ Advance care planning tools – e.g., living wills, health care proxies, and more

◦ Advance care planning forms

Page 5: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

What Diagnosis Must be Used?

oThe condition for which you are counseling the beneficiary regarding the Advance Directives discussion

Page 6: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Advanced Care Planning

CPT codes 99497 and 99498

NIHARIKA KHANNA, MBBS,MD,DGO

ASSOCIATE PROFESSOR FAMILY AND COMMUNITY MEDICINE

DIRECTOR MARYLAND LEARNING COLLABORATIVE

Page 7: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Medicare Part B effective Jan 1, 2016

oCPT code 99497 for Advanced Care Planning (ACP) billed when services are provided as a part of the Annual Wellness Visit

oPlus CPT code 99498 for any additional 30 minutes needed

oIn addition to Annual Wellness Visit codes G0438 and G0439

oWhen ACP services are offered as part of Annual Wellness Visit, the coinsurance and deductible are not applied for ACP (Once per year)

oModifier 33 (Preventive Services) is to be used when ACP and Annual Wellness Visit is billed together

oACP and Annual Wellness Visit must be billed together on the same claim

Page 8: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Medicare Part B effective Jan 1, 2016

Why are there two codes?

◦ 99497 applies to the first 30 minutes of an advance care planning discussion

◦ 99498 applies to each additional 30 minutes (in conjunction with 99497)

◦ Codes do not exclude other members of a practice from taking part

◦ Billing practitioner must “manage, participate and meaningfully contribute to the provision of these services”

Page 9: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Billing CPT codes 99497 and 99498 Frequency

oThere are no limits to the number of times Advanced Care Planning billing codes can be used

oThe CMS expects that each time bills are dropped, the beneficiary health status and wishes regarding his/her end of life care is discussed

o99497 and 99498 can be billed with most other E/M codes on the same day

o99497 and 99498 can be billed with Transition of Care Management (TCM) and Chronic Care Management (CCM) codes and within global surgical periods

Page 10: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

In What Settings can Advanced Care Planning Codes 99487 and 99498 be Used?

oThere are no place of service limitations on ACP billing codes

oACP codes maybe billed depending on the needs and conditions of the beneficiary

oThe ACP codes can be billed by physicians/practitioners in both inpatient and hospital settings

Page 11: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Advanced Care Planning Service Delivery Documentation

oDiscussion with the beneficiary, or family members and/or surrogate

oVoluntary nature of the encounter

oExplanation of the Advanced Directives

oCompletion of Advanced Directives forms and scanning into the chart

oWho was present at the encounter

oTime spent in face-to-face encounter

oCompletion of the Advanced Directive is not a requirement for billing the service

Page 12: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

What if I can’t Answer All My Patient’s Questions?

◦CMS.gov◦National Hospice and Palliative Care Organization◦American Academy of Hospice and Palliative Medicine

◦End of Life Care Program◦Compassion and Support at the End of Life

Page 13: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

References

ACP for PCP’s : National Hospice and Palliative Care Organization

MLN Matters Number : MM9271 Advanced Care Planning (ACP) as an Optional Element of an Annual Wellness Visit (AWV)

CMS FAQs

Page 14: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

What is MACRA?Medicare Access and CHIP Reauthorization Act (MACRA)

Replaced the Sustainable Growth Rate (SGR) in 2015

Increases focus on quality and value of care delivered

Provides incentives for clinicians to improve their practices and the quality of care they provide

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Page 15: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

QPPQuality Payment Program (QPP)

The program through which clinicians demonstrate improvements to their practices or quality of care provided

Began in 2017

Provides tools and resources to clinicians who participate in Medicare Part B

Offers an incentive or a performance-based adjustment to participating providers

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Page 16: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Options for Participating

MIPS adjustments

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

MIPS adjustments

5% lump sum bonus

Not in APM In APM In Advanced APM

+APM-specific rewards

APM-specific rewards

+If you are a Qualifying APM

Participant (QP) =

Page 17: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Year 2 (2018)

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Quality CostImprovement

Activities

50% 10% 15%

25%

AdvancingCare

Information

The MIPS Final Score is compared to the MIPS performance threshold to determine if you

receive a positive, negative, or neutral payment adjustment.

Change: Performance Category Weights

Page 18: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

MIPS Year 2 (2018) Timeline

2018

Performance

period

Feedback

available

Submit

Data

March 31,

2019

Payment

adjustment

January 1,

2020

Increase to minimum performance periods

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

12 months (New)

◦ Quality performance category

◦ Cost performance category

90 days (No Change)

◦ Improvement Activities performance category

◦ Advancing Care Information performance category

Page 19: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Change: Low-Volume Threshold

MIPS eligible clinicians billing more than $90,000 a year in Medicare Part B allowed charges

AND

providing care for more than 200 Medicare patients a year.

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Page 20: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

5 Steps to Avoid a Penalty in 20191. Understand what is at stake for your practice with the implementation of

MACRA and the QPP

2. Determine if your practice is exempt from MIPS or if your practice could tolerate extra risk under an Advanced APM

3. Understand the requirements of each payment model and determine which model will work best for your practice – MIPS and APMs

4. Make a plan to begin collecting data and join an APM or Advanced APM if you have decided to implement one of those models

5. Begin collecting data to report by March 31, 2019

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Page 21: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

MACRA Awareness and Support (MAS)Goal is to assist stakeholders subject to MACRA, such as ambulatory practices and

hospitals, in adjusting their approach and practice management to comply with MACRA

specifications.

Educates stakeholders on the components of Merritt-based Incentive Payment System

(MIPS) and Advanced Payment Models (APMs).

Practices in Maryland—especially small practices located in rural or underserved areas

and/or not affiliated with a hospital—may benefit from technical and administrative support

to transform practice workflows and optimize the use of health IT.

More resources are available at

http://mhcc.maryland.gov/mhcc/pages/apc/apc/apc_macra.aspx

Page 22: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

More Information From CMSQPP Resource Library

https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html

QPP Year 2 Final Rule Fact Sheet

https://www.cms.gov/Medicare/Quality-Payment-Program/resource-library/QPP-Year-2-Final-Rule-Fact-Sheet.pdf

QPP Year 2 Final Rule Executive Summary https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/QPP-Year-2-Executive-Summary.pdf

MHCCM A R Y L A N D

HEALTH CARE

COMMISSION

Page 23: Advanced Care Planning · Total Beneficiaries Cost National Benchmark Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420 COPD 33 $25,358 $29,613 IHD 34 $24,524 $22,117

Practice: John Doe, MD

Tax Identification Number: 123456789

Enrollment Date: 12/12/16

Quality and Resource Use

Report (QRUR) 2016

Total Beneficiaries

Cost National

Benchmark

Practice Total 381 $10,518 $12,380 Diabetes 163 $15,583 $18,420

COPD 33 $25,358 $29,613

IHD 34 $24,524 $22,117 CHF 34 $29,641 $33,953

Readmissions Rate

58 15.36% 15.29%

Total Cost Difference 2015 to

2016 QRUR:-$99.86

2016 QRUR Average Risk Score 69th Percentile

Current Phase in Practice

TransformationPhase 4

Patient and Family Engagement

Key Performance Indicators Practice Transformation Progress

0%

20%

40%

60%

80%

Performance % National Benchmark

Active e-tool NO Health Literacy Survey NO

Shared Decision Making YES Medication Management YES

Patient Activation NO Support for Patient & Family Voices

YES