macra: mips and apms for small practices … · feb 21, 2018 jit chawla chief consultant macra:...
TRANSCRIPT
Feb 21, 2018
Jit Chawla
Chief Consultant
MACRA: MIPS and APMs for Small Practices
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About EHR 2.0
© 2017 EHR 2.0. All rights reserved. To purchase reprints of this document, please email [email protected].
EHR 2.0 Mission: To assist healthcare organizations develop and implement practices to secure IT systems and comply with HIPAA/HITECH regulations.
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About the speaker: Jit Chawla
© 2017 EHR 2.0. All rights reserved. To purchase reprints of this document, please email [email protected].
▪ Master of Health Administration, Clinical Informatics Certificate
▪ Chief Consultant for technology and management consulting firm. Years of experience helping practices with achieving Meaningful Use, PQRS and Value-Based Modifier initiatives.
▪ Six Sigma Green Belt, Toastmaster Club Member, competitive tennis player, foodie and loves to travel
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Agenda Topics
About MACRA and MIPS/ APM Programs
How it works
Why should you care
Next steps for you
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Origin of MIPS
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MIPS: Components
Source: CMS Press Office press release 4/27/16 http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html
Performance Category Details
Quality Clinicians choose to report six measures from a range of options that accommodate differences among specialties and practices
Advancing Care Information Clinicians choose to report customizable measures that reflect how they use technology in their day-to-day practice
Clinical Practice Improvement Activities
Rewards clinical practice improvements, such as activities focused on care coordination, beneficiary engagement, and patient safety
Cost Score based on Medicare claims using 40 episode-specific measures, meaning no reporting requirements for clinicians
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MIPS: Eligible Clinicians
PhysiciansPhysician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered Nurse
Anesthetists
Source: CMS Press Office press release 4/27/16 http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html
These include:
Non-facing Clinicians
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MIPS: Eligibility Criteria
1. Revenue threshold –allowable charges Part B Medicare
AND
2. Volume threshold- number of Part B patients
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MIPS: Exclusions
The following are reasons for providers to not participate without incurring a penalty:
• Low Volume : Less than $30,000 per year from Medicare or fewer than 100 Medicare patients per year
• First year of participant in Medicare Part B Program
• Significant participation as an Advanced APM
• Operating as a Rural Health Clinics and Federally Qualified Health Centers paid differently under Medicare
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Example of a Quality Measure
Purpose: Reward for quality of care demonstration in certain populations
300 spanning various specialties (full list https://qpp.cms.gov/mips/quality-measures), some common ones are:
Diabetes Foot Exam:Numerator: Patients who received visual, pulse and sensory foot examinations during the measurement period.
Denominator : Patients 18-75 years of age with diabetes with an eligible visit (defined as a signed chart note with one of the following encounter types: Office Visit, Nurse Visit, Nursing Home Visit, or Home Visit) during the measurement period.
Denominator Exclusions: Patients who have had either a bilateral amputation above or below the knee, or both a left and right amputation above or below the knee before or during the measurement period.
• Performance Benchmark for MIPS: 76.17%
Source: practice fusion
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Quality Scoring
Source: CMSHHgov
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Calculating the Measure Quality Points
Source: acumend.com
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Quality Score
Source: CMSHHgov
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Example of ACI Base Measures
Purpose: Reward for use of the certified EMR to record and send certain data Total of 15 offered, (full list-https://qpp.cms.gov/mips/advancing-care-information) some common ones used are…
Source: www.cms.gov
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Example of ACI Performance Measures
Source: www.cms.gov
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ACI Criteria per Measure
Source: www.cms.gov
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ACI Scoring
Source: CMSHHgov
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Example of CPIA Measures
Purpose: Reward for care focused on care coordination, beneficiary engagement, and patient safety.
Total of 93 offered, (full list-https://qpp.cms.gov/mips/improvement-activities) some common ones used are…
Diabetes Screening- For people with schizophrenia or bipolar disease who are using antipsychotic medication.
Engagement of new Medicaid patients and follow-up-Seeing new and follow-up Medicaid patients in a timely manner, including individuals dually eligible for Medicaid and Medicare.
Implementation of antibiotic stewardship program- Measures the appropriate use of antibiotics for several different conditions (URI Rx in children, diagnosis of pharyngitis, Bronchitis Rx in adults) according to clinical guidelines for diagnostics and therapeutics
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CPIA Measure Weights
Source: CMS.gov
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CPIA Scoring
Source: CMSHHgov
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CIPA Scoring
Source: CMSHHgov
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Cost Scoring
Source: CMSHHgov
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Cost Scoring
Source: CMSHHgov
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MIPS Overall Score
Source: CMSHHgov
50*60+ 100*15+80*25+0*0 = 65% * 100 = 65 points
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Points/Rewards Relationship
Source: CMSHHgov
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Incremental Payment Adjustments
Physician Fee Schedule
(updates)
APM(incentive payments)
MIPS(payment
adjustments)
0.5% 0.5%0.5% 0.5% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
5.0% 5.0% 5.0%5.0% 5.0%
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
+/-4%
+/-5%
+/-7.0%
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
MIPS performance period +/- 9%
Key Takeaway: Physicians who have relied on payments going up year after year will be living in a world where, without change, they will be going down.
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MIPS Data Submission Methods
Source: Society of Thoracic Surgeons
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MIPS: Pick Your Pace - Performance Year 1
CMS announced new options for MIPS participants to increase flexibility in reporting in 2017.
Test
• Submit data for one quality measure, OR one improvement activity, OR the four required ACI measures and avoid a negative payment adjustment.
Partial
• Submit at least 90 days of data for more than one quality measure, OR more than one improvement activity, OR more than the four required ACI measures and avoid a negative payment adjustment. Partial participation also allows ECs to possibly receive a small positive payment adjustment.
Full
• Submit at least 90 days of data for all required quality measures, AND all required improvement activities, AND all four required ACI measures to avoid a negative payment adjustment. Full participation also allows ECs to possibly receive a moderate positive payment adjustment
Source: AAFP
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MIPS: Changes for 2018
Source: HITECHanswers
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MIPS: Changes for 2018
Source: HITECHanswers
REG OVERVIEW HOW WORKS WHY CARE NEXT STEPS
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MIPS: Changes for 2018
Source: HITECHanswers
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MIPS: Changes for 2018
Source: HITECHanswers
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MIPS: Changes for 2018
Source: HITECHanswers
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MIPS: 2018 Final Rule Stipulations
Source: HITECHanswers
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MIPS: 2018 Final Rule Stipulations
Source: HITECHanswers
REG OVERVIEW HOW WORKS WHY CARE NEXT STEPS
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MIPS Categories Weighting
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Definition:• Approach giving additional monies for high-quality, cost-efficient
care• Applicable to specific conditions, care episodes and populations• Advanced APMs (a subset), allow 5% higher incentive payment by
taking some risk related to patient outcomes• AAPM models include:
* Comprehensive End-Stage Renal Disease Care* Comprehensive Primary Care Plus* Medicare Shared Savings Program – Track 2* Medicare Shared Savings Program – Track 3* Next Generation ACO Model* Oncology Care Model (two-sided risk arrangement)* Comprehensive Care for Joint Replacement –Track 1
Alternate Payment Models
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APM Criteria
Source: CMSHHSgov
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Risk in APMs
Source: CMSHHSgov
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APM MIPS Criteria- SSP, Next Gen
Source: cms.gov
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APM MIPS Criteria- All other APMs
Source: cms.gov
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MACRA Programs Comparison
MACRA Strategy Advantages Disadvantages
MIPS • Familiarity with Legacy Programs • Incentives are highly dependent on measure selection and peer performance
• Downside risk up to 9% in 2022
MIPS APM • Eases report burden• If partially qualifying provider, may
be able to avoid MIPS reporting• Less likely to involve risk• May yield more than 5% bonus
• Do not get the 5% upside bonus, but still significant infrastructure costs associated with APMs
• Positive MIPS adjustments make it harder to achieve savings in APMs
Advanced APM • 5% lump sum bonus• Bonus is not counted against APM
medical budget• Physicians may be attracted to an
Advanced APM to avoid MIPS
• Downside risk amount can be substantial and varies by model
• Can participate without being a qualified provider; specialists may have a more difficult time qualifying
• Requires infrastructure investment• Some providers not ready to go at risk
REG OVERVIEW HOW WORKS WHY CARE NEXT STEPS
Source: Stroudwater
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Important MIPS related changes in 2018
January 1, 2018
•Deadline to begin including new codes and national provider number on Medicare claims
July 1, 2018
•HHS to begin providing info to each MIPS-eligible clinician about items and services provided to the professional’s patients by other suppliers and providers of services
December 2, 2018
•MIPS adjustments announced
December 31, 2018
•Statutory deadline for achieving national priority of widespread interoperability of EHRs
January 1, 2019
•First performance period for 2021 payment adjustments, including through Other Payer APMs
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Practical/ To Do Steps-Attestation for 2017
Step 1:Ensure that data is collected and organized for the various MIPS categories
Step 2:Login (or create an account with ) Quality Payment Program website. Can start early as 1/2/18 ( except Web Interface reporting starts at 1/22/18).
Step 3:Submit, deadline -March 31, 2018
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Practical/ To Do Steps-Attesting this year
Step 1:Ensure have certified EMR with MIPS reporting dashboard
Step 2:Look at revenue/ volume of patients in designated time period
Step 3:Pick Quality Metrics, EMR measures and list of Clinical Practice Improvement Areas that fit within your organization’s goals to achieve, ensuring can comfortably collect data on these measures
Step 4:Map out workflows, educate staff/providers on what data to record in EMR (if unable to do in-house seek outside expert consultation)
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Key Take Away Points
• Your reimbursement will be affected- like it or not !
• Get paid for taking good quality care of your patients
• MIPS not much different from past programs, APMs like ACOs
• Start now –proper workflow takes times, capture good data
• Don’t have to do everything on your own – not worth your time, cost-effective. Let the experts do their thing !
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MIPS/ MACRA Offerings
1. 2017 MIPS/ APM Attestation Assistance
2. 2018 MIPS/ APM Data Collection Assistance
3. MIPS/ APM Strategy Consulting
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EHR2.0/ AHS -Other Offerings
MACRA OVERVIEW MIPS ADVANCED APMs CPC+
OSHA Assessment and Consulting
Gold PackageSilver PackageBronze Package
Security Risk Analysis & HIPAA
Meaningful Use Medicaid Assistance
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Thank you!
(919) 228-8744www.acehealthsolutions.com
© 2017 EHR 2.0. All rights reserved. To purchase reprints of this document, please email [email protected].
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