preparing for macra & cpc+ · 0 or 50 points performance score can report on up to 7-9...
TRANSCRIPT
MIPS 101
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AMG MACRA Readiness Webinar Series
February 8, 2017
The information contained within this presentation is provided as
general guidance, and is not intended to be an all-encompassing
set of guidelines. It is not intended to be used as a substitute for
professional or legal advice and may not address practice-
specific circumstances. Please refer directly to CMS publications
for detailed MACRA guidance when necessary.
INTRODUCTION
Agenda
Topic Timing
Goals for Today 5 min
Overview of MIPS Reporting for Performance Year 2017 10 min
MIPS Performance Categories and Ascension FAQs Quality Cost Advancing Care Information Improvement
40 min
Wrap-up 5 min
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Goals for Today
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Goals for Today
Today we will:
Review the requirements of the Merit Based Incentive Program (MIPS)
Address some AMG frequently asked questions
Please feel free to type in questions. If we are able, we’ll work in answers;
otherwise, we’ll address in written FAQs
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The Quality Payment Program
The Quality Payment Program (QPP) aims to:
• Tie Medicare Part B payments to value for over 600,000 clinicians nationwide
• Improve care across the delivery system
Clinicians will participate in the QPP through one of two tracks:
Today’s Discussion Webinar 2: February 28
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
MIPS Reporting for Performance Year 2017
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MIPS Reporting Timeline for PY 2017
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
Performance:
• The first performance period
opens January 1, 2017 and
closes December 31, 2017.
• During 2017, you will record
quality data and how you
used technology to support
your practice.
Send in Performance Data:
• To potentially earn a
positive payment
adjustment under MIPS,
you must submit data
about the care you
provided and how your
practice used technology
in 2017 The submission
deadline is March 31,
2018.
Feedback:
• Medicare gives
you feedback
about your
performance after
you send your
data.
Payment:
• You may earn a
positive MIPS
payment adjustment
to your FFS
Medicare Part B
rates beginning
January 1, 2019, if
you submit 2017 data
by March 31, 2018.
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MIPS Applicability
Source: CMS, “QPP Overview Fact Sheet,” October 14, 2016
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MIPS Decisions: Individual vs. Group
Option 1: Report as an Individual
• Assessed as an individual across
all 4 MIPS performance categories
Option 2: Report as a Group
(= TIN)
• Must have 2 or more
clinicians (NPIs) who have
reassigned their billing
rights to a single TIN
• Assessed as a group across
all 4 MIPS performance
categories
AMG Preference
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
• When will CMS let MIPS-exempt clinicians know they are exempt for 2017?
• What if we report as a TIN, but one or more individual clinicians within the TIN are exempt from MIPS?
• What if we report as a group and there are changes to the TIN partway through the year, or after the reporting period?
• If a practice is an AMG joint venture or PSA, who is responsible for MIPS reporting?
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MIPS Applicability: FAQs
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MIPS Decisions: Reporting Tracks for PY 2017
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
• Submit some
data after
January 1, 2017
• Neutral or small
payment
adjustment
• Report for a 90-
day period after
January 1, 2017
• “Small” positive
payment
adjustment
• Fully participate
starting January
1, 2017
• “Modest” positive
payment
adjustment
AMG anticipates all TINs
will report at least 90 days
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MIPS Decisions: Data Submission Approach
You can choose to report
through an approved third-
party intermediary:
Intermediary Approval
Needed
EHR Vendor ONC
QCDR CMS
Qualified Registry CMS
CAHPS Vendor CMS
There are a number of ways to get your data to CMS. Your approach has implications on
which quality measures you may select. Key considerations include:
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
• Burden
• Cost
• Past Experience
• Ability to report for at least 90 days / full year
• Will our MIPS score actually be higher if we report
quality measures for a full year rather than 90 days?
• Do we have to use the same reporting modality for
each MIPS category?
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Reporting: FAQs
MIPS Performance Categories
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MIPS Performance Categories
+ + + = FINAL SCORE Quality Advancing
Care Information
Improvement Activities (IA)
Cost (2018+)
Each Clinician’s or TIN’s score from each category is aggregated into a
single MIPS Final Score out of 100:
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
60% 0% 15% 25%
PY 2017 Category Weights
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Quality Performance Category: The Basics
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
Reporting is at the TIN OR individual clinician level (no other combinations allowed). If
the TIN chooses to report the quality category as a TIN, it must report all the other
categories as a TIN also.
CMS provides a wide range of quality measure options. Each TIN chooses 6 or
more of the ~270 individual measures OR a specialty measure set*:
• 1 measure must be an “outcome” or a “high-priority” measure
• The measures you submit must cover at least 50% of the TIN’s patients that meet
denominator criteria
• You may report on more than the minimum number of measures
CMS rates the TIN on its performance based on deciles. If the TIN reported more than
the required number of measures, CMS counts the best scoring measures.
Resulting quality category score is 60% of the TIN’s MIPS Final Score, which
determines the payment adjustment
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* If the TIN uses the CMS Web Interface to report,
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Quality Performance Category: Specialty Measures
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
• Allergy/Immunology
• Anesthesiology
• Cardiology
• Dermatology
• Diagnostic Radiology
• Electrophysiology Cardiac
Specialist
• Emergency Medicine
• Gastroenterology
• General Oncology
• General Practice/Family
Medicine
• General Surgery
• Hospitalists
• Internal Medicine
• Interventional Radiology
• Mental/Behavioral Health
• Neurology
• Obstetrics/Gynecology
• Ophthalmology
• Orthopedic Surgery
• Otolaryngology
• Pathology
• Pediatrics
• Physical Medicine
• Plastic Surgery
• Preventive Medicine
• Radiation Oncology
• Rheumatology
• Thoracic Surgery
• Urology
• Vascular Surgery
TINs can fulfil requirements by utilizing one of the specialty measure sets:
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Quality Performance Category: Near-Term Steps
Decide your TIN’s preferred reporting modality
Review available measures on the CMS website: www.QPP.CMS.gov
Identify measures available based on the reporting modality selected
Determine if you will use any specialty-specific measure sets
Review your current QRUR and sQRURs to identify areas for
performance improvement
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• What are the key differences between MIPS Quality
Category and PQRS?
• Do we have to choose measures that apply to all of
our clinicians?
• We have 2 EHRs in use by the TIN: one for the clinic
and one for the hospital. How will we report?
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Quality Category: FAQs
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Cost Performance Category
No reporting required; CMS will assess cost performance using Medicare
claims data
Cost Category has zero weight in PY 2017 MIPS Final Score
Feedback will still be provided for PY 2017, which can help you prepare
for when costs are rolled in to the Final Score in subsequent performance
years
Measures will mirror the QRUR, which can give you a sense of your
performance on cost
Once in effect (PY 2018+), costs measures will build on the Value
Modifier program:
1. Medicare Spending per Beneficiary (MSPB)
2. Total Per-Capita Cost for All Attributed Beneficiaries for 10
Episodes
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
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Advancing Care Information: The Basics
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
Score Component Score
Base Score Must report on required objectives and measures
0 or 50 points
Performance Score
Can report on up to 7-9 additional measures to secure points for “performance” component of score.
Up to 90 points
Bonus Points
Reporting one or more additional public health and clinical data registries beyond Immunization Registry Reporting measure
5 points
Reporting improvement activities using CEHRT
10 points
Total Score (%)=
Sum of all points
(capped at 100)
Total possible points (100)
Failure to report on any single base score measure will result in a zero base score and zero score for overall composite score
Measures worth 10 points each are available for reporting
The bonus measures require attestation (Y/N)
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Advancing Care Information: Reporting Options
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
For PY 2017, there are two measure sets available, based on your EHR edition:
2015 CEHRT 2014 CEHRT
Advancing Care Information and
Objectives and Measures
Combination of the
two measure sets
2017 Advancing Care Information
Transition Objectives and Measures
Base Measures
Security Risk Analysis
e-Prescribing
Provide Patient Access
Send a Summary of Care
Request / Accept a Summary of Care
Performance Measures
Provide Patient Access Send a Summary of Care
Patient-Specific Education Request/Accept Summary of
Care
View, Download & Transmit Clinical Information Reconciliation
Secure Messaging Immunization Registry Reporting
Patient-Generated Health Data
Base Measures
Security Risk Analysis
e-Prescribing
Provide Patient Access
Health Information Exchange
Performance Measures
Provide Patient Access Health Information Exchange
Patient-Specific Education Medication Reconciliation
View, Download & Transmit Immunization Registry Reporting
Most AMG TINs
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Advancing Care Information: Tracks
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
AMG Expectation
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Advancing Care Information: Flexibility
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
ACI Reporting is optional for:
Hospital-based MIPS clinicians
Clinicians with lack of face-to-face patient interaction
NP, PA, CRNAs and CNS
If a clinician faces a significant hardship and is unable to report ACI measures,
they can apply to have their ACI performance category weighted to zero for
PY 2017
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Advancing Care Information: Near-Term Steps
Identify your CEHRT level by TIN
Ensure all TINs are ready to report on each base score measure
Assess readiness to report on performance measures associated
with your CEHRT
Plan to use 2015 edition CEHRT by performance year 2018
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• What if our TIN includes some clinicians who are
exempt from ACI because they are hospital-based, but
others who are not exempt?
• Does the ACI category affect Medicaid Meaningful
Use?
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Advancing Care Information: FAQs
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Improvement Activities: The Basics
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
Improvement Activities measures assess participation in activities that improve clinical
practice
Each TIN will select a subset of 90+ activities to report on, which fall under 9 categories,
and include some “high weighted” activities that offer higher scores:
• Engagement of new Medicaid patients and follow-up*
• Leveraging a QCDR for use of standard questionnaires
• Leveraging a QCDR to promote use of patient-reported outcome
tools
• Leveraging a QCDR to standardize processes for screening
• Depression screening
• Diabetes screening
• EHR enhancements for BH
data capture
• Co-location PCP and MH
services*
• Implementation of integrated
PCBH model*
• MDD prevention and treatment
interventions
• Tobacco use
• Unhealthy alcohol use
* High weighted activities
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Improvement Activities: Tracks
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
AMG Expectation
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Improvement Activities: Flexibility
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
Groups with 15 or fewer participants, non-patient facing clinicians, or those
in a rural or health professional shortage area have a preferential minimum
reporting requirement:
May attest that you have completed up to 2 activities for a minimum of 90
days
Participants in certified patient-centered medical homes, comparable
specialty practices, or an APM designated as a Medical Home Model will
automatically earn full IA credit
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Improvement Activities: Near-Term Steps
Review available measures on the CMS website: www.QPP.CMS.gov
Identify those measures that you already engage in, with a focus on
“high weighted” activities
Assess PCMH participation, which has a broad definition for QPP
Expand implementation of improvement activities as reasonable
during PY 2017
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• Does the whole TIN have to be doing the improvement
activity for the TIN to receive credit?
• How will we know if we meet the criteria for the
preferential scoring under the Improvement
Category? Will CMS tell us?
• Which PCMH certification programs are recognized by
CMS to receive full credit under the Improvement
Activity category? Do all practices in the TIN have to
be PCMHs?
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Improvement: FAQs
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MIPS Scoring Methodology
+ + + = FINAL SCORE (OUT OF 100) Quality Advancing
Care Information
Improvement Activities (IA)
Cost (2018+)
Note: Scoring methodology within each category is quite complex. See resources
available at https://qpp.cms.gov/resources/education for more information
Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016
60% 0% 15% 25%
PY 2017 Category Weights
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MIPS Payment Adjustment
The majority of TINs are likely to
fall into this category and receive a
modest payment adjustment (under
4%)
Total exceptional performance bonus budget set at $500 million nationally
Source: CMS, “Quality Payment Program Overview, Long Version” October 26, 2016
Wrap-up
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Next Steps
Confirm that you will pursue group reporting
Identify your data submission approach and review applicable
measures
Ensure you can meet the minimum expected reporting and
performance requirements across each performance category
Review your September 2016 QRURs against the benchmarks for
2017 Quality Measures:
Identify strong and weak quality areas
Consider taking remedial actions for weak quality areas within 2017
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Complete AMG MACRA Readiness Assessment by March 1, 2017
MACRA Webinar Series
Topic Timing Purpose
TODAY: MIPS 101: Review of all basic requirements
February 8th 1:00 -2:00 PM ET
Review and clarify the requirements for 2017 MIPS
NEXT: All Things APM: Deep dive into how MSSP and CPC+ participants will be assessed under MACRA
February 28th 1:00 -2:00 PM ET
Review how CMS assesses CPC+ practices, MSSP ACOs, and combinations
for MACRA 2017 (presentation will be geared to Ministries participating in
these models)
Using Data for Internal Quality Improvement
TBD TBD
TBD – Seeking input for final webinar topic
TBD TBD
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APPENDICES
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CMS Educational Resources and Files
Measures Available to Download
2017 MIPS Quality Measures
2017 ACI Measures for 2014 CEHRT
2017 ACI Measures for 2015 CERHT
2017 CPIA Activities
The CMS website has been updated to include an Excel file of the measures available at https://qpp.cms.gov/resources/education
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Steps to Access QRURs
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Steps to Access QRURs
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Steps to Access QRURs
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Steps to Access QRURs
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Steps to Access QRURs
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Steps to Access QRURs
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MIPS and Past Medicare Reporting Programs
Source: CMS, “Quality Payment Program Overview, Long Version” October 26, 2016
QPP combines legacy programs into a single, improved reporting program
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MIPS Applicability:
Source: Manatt analysis of HHS Regulatory Impact Analysis (RIA) within MACRA Final Rule
Merit-Based Incentive Payment System (MIPS)
592 - 642,000 clinicians
$699m total upward MIPS adjustment
$199m total downward MIPS adjustments
Clinicians billing Medicare Part B program
1-1.4m clinicians
• Nearly 1/3 of clinicians excluded for 2017
• However, charges made by this group account
for only 5% of all Medicare spend
• The AMG MACRA Readiness Assessment will
screen for exceptions, which include insufficient
Medicare volume / charges Note: Includes
special reporting
requirements for
particular groups,
likely not applicable
to AMG, such as
groups that primarily
consist of non-patient
facing clinicians
“Advanced Alternative Payment
Models” (A-APMs)
70 - 120,000 clinicians
$333m - $571m incentive payments
Other MIPS-excluded clinicians:
300-700,000 clinicians
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AMG Market MIPS Decisions
Note: The following content assumes that no exclusions or special categories apply,
at least 90 day reporting, and that clinicians are reporting through TIN groups.
Each Ascension TIN that does not report through an APM will need to:
Report as an individual or group AMG assumes most markets will
report as TIN-level groups
Determine response “track,” or how
much data you will be reporting
AMG assumes all markets will
report for at least 90 days
Identify their preferred data submission
approach
AMG assumes this will be
ministry-specific
Understand if any clinicians / TINs
are exempt from MIPS or fall into special
categories (ie, non-patient facing)
AMG will assess for exclusions
through a MACRA Readiness
Assessment