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Date: October 12, 2017
Pros and Cons of MIPS Data Submission Methods
This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy11SOW-QIN-D1-12/15/16-11918
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• Telligen: Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Colorado, Illinois and Iowa
• Subject Matter Experts for CMS Quality Performance Initiatives
Telligen QIN QIO
Sandy Swallow Iowa Linda Brewer
Illinois
Temaka Williams Illinois
Courtnay Ryan Colorado
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• Discuss mechanics of multiple data submission methods
• Share QPP updates and recent news
• Open discussion with sharing and Q & A
Today’s Agenda
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When is MIPS 2017 information due?
• Performance period Jan. 1, 2017 – Dec. 31, 2017
• Last day to begin partial (90 day) participation is Oct. 2
• Data submission period: Due to CMS January 1, 2018 – March 31, 2018
• Deadlines for particular EHR or Registry vendors may be earlier – Important to check with your vendor
• Doing the work to generate the information you will need to submit should be happening now
Pros and Cons of MIPS Data Submission Methods
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What do I need to know before submitting data?
• CMS allows multiple options – Only one data submission method for a single performance category
– Option to use a different method for each category
• Some options and instructions for data submission are still under development by CMS – UGH!
• Picking measures and choosing how to submit data are interconnected – Consider both
Pros and Cons of MIPS Data Submission Methods
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Pros and Cons of MIPS Data Submission Methods
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Quality
Claims Qualified Registry
QCDR EHR Direct
Web Interface (25+)
Improvement Activities
Qualified Registry
QCDR EHR Direct
Attestation Portal Web Interface (25+)
Advancing Care Information
Qualified Registry
QCDR EHR Direct
Attestation Portal Web Interface
(25+)
What must be submitted and how?
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How does it work?
• CMS-approved entity that collects clinical data from a clinician
or group and submits it to CMS on their behalf.
• Registry integrates directly with CMS via an API (new way) or
generates and XML file (old way)
• Each registry has met certain criteria and provides detailed information on the list
• Requires reporting on all patients and payers
• Annual qualified registry list available in advance
https://qpp.cms.gov/docs/QPP_2017_Qualified_Registries.pdf
Qualified Registry Submission Method
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How does it work?
• CMS-approved entity that collects clinical data from a clinician or
group and submits it to CMS on their behalf.
• Available to individual MIPS eligible clinicians and groups
• Must submit data via a CMS-specified secure method for data submission, such as a QRDA or XML file.
• Requires reporting on all patients and payers
• Different from a registry
– Not limited to QPP measures
– Can’t by owned or managed by an individual specialty group
• Annual QCDR list available in advance with detailed information
– https://qpp.cms.gov/docs/QPP_2017_CMS_Approved_QCDRs.pdf
Qualified Clinical Data Registry (QCDR)
Submission Method
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Registries and QCDR: Tips and Advice
Tips:
• Many professional societies offer inexpensive options to members
• Pick carefully since the real goal is improving care for your patients
• Find out what the data submission deadlines are since they are earlier than CMS deadlines
Pros: • Largest number of quality
measures available
• Greatest amount of flexibility
• Often comes with advisory services
• Multiple registries available
– Some free or cheap
Cons: • Some require manual entry
• Some are costly
• May be time consuming to enroll
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How does it work?
• Two options – Clinicians submit data to CMS directly through the use of their
certified EHR system
– Work with a third-party qualified health-IT vendor who will submit the
data on their behalf Data is extracted from the EHR technology to an intermediary, the intermediary
would then submit the measures and activity data to CMS in a CMS-specified form
and manner.
• ONC certification process has established standards and
criteria that must be met
• Available to individuals and groups
• Requires reporting on all patients and payers
Electronic Health Record (EHR) Submission Method
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EHR: Tips and Advice
Tips: • If you report multiple CQMs,
CMS will use those yielding the best scores
• Check costs and functionalities carefully before investing
• Get advice from peers or support organizations before choosing an EHR
• Can still avoid a penalty in year one without an EHR
Pros: • Can earn higher MIPS scores by
receiving bonus points
• Allows for real time assessments of quality scores
• Eliminates the need to use a separate submission mechanism
Cons: • Not all EHRs have the ability to
support data submission
• Access may be costly and vendors may charge extras
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How does it work?
• Clinicians select measures and report through claims
• Various QPP codes must be submitted on the initial claim in conjunction with applicable billing codes to denominator eligible claims
• Measure Specification Document provides details and codes to include on claim
• Not available to group reporting (individual EC only)
• Reporting on Medicare patients only
Claims-Based Submission Method
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Claims-Based: Tips and Advice
Tips:
• Can be used to avoid year 1 penalty but not a long-term substitute for having an EHR or participating in a registry
• Claims can not be used for data submission for ACI or IA categories
• Read Measure Specification Sheet carefully
Pros: • Provide continuity if you’re
already submitting quality measures through your claims biller
• Free
Cons: • Least flexible
• Least accurate
• No real time results
• Not available for group reporting
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How does it work?
• Secure internet-based application available to groups of 25 or more MIPS clinicians under a single TIN used to report data to CMS
• Formerly known as GPRO reporting option
• Agree to report on all 15 CMS WI measures
• Must submit full calendar year of data
• Preregistration is required
• Group will report on a sample of 248 MC beneficiaries
• CMS Web-Interface Fact Sheet
CMS Web-Interface Submission Method
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CMS Web-Interface: Tips and Advice
Tips:
• Prepare early
• Determine group size
• Complete registration process (when available for 2018)
• CMS provides prepopulated claims data – be prepared to populate remaining data fields
Pros: • Eliminate need search for &
select measures
• CMS identifies patients for reporting
• Group advantages
Cons: • Must submit 12 months of quality
data (90 days IA and ACI)
• Preregistration required
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How does it work?
• Proposed:
– Data submission method for ACI and IA
– Will be available for individuals and groups
– Requires reporting on all patients and payers
– Waiting for more guidance
Attestation Portal Submission Method
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Key Takeaways
• Can only use one submission method per category
• Choose a submission method that best suites the needs, capabilities and goals of your practice/organization – Look at costs and benefits
– Consider internet/technology access, financial costs, and administrative burdens
• Qualified Registries and QCDRs are available across all categories and reporting types (individual vs. group)
• Attestation portal is “proposed” to be no cost
• Consider submission methods that are sustainable for reporting in future years
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• 2016 PQRS Feedback Reports and 2016 Annual QRUR reports
– Status on 2018 downward payment adjustment for PQRS and VMP
– Access via EIDM Account
• Advanced APM participants Qualifying Participant (QP) determinations based on the first 2017 snapshot period
– Qualifying APM Participant Look-Up Tool
QPP Updates News
Flash!
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New QPP Resources
Telligen QINQIO Website
– MIPS Calculator for non-APM eligible clinicians
– MIPS Calculator demonstration
– MIPS Calculations Worksheet
https://telligenqinqio.com/our-work/quality-payment-program/quality-payment-program-resources/
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• CMS QPP Website: – MIPS Specialty Measures Guide
Anesthesiologist and CRNAs
Emergency Medicine Clinics
Ophthalmologists
Orthopedists
– Group Participation in MIPS Guide
– CMS-approved QCDR Vendor List for 2017
– How to Design an APM Toolkit
– Quality Performance Category Fact Sheet
https://qpp.cms.gov/about/resource-library
New QPP Resources
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QPP Q & A
• Q. Please provide more information on the definition and requirements to be considered a specialized registry?
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Telligen QIN-QIO is Here to Help!
• Experienced quality improvement advisors to provide expert technical assistance and quality improvement support for participating providers across the state
• Join the monthly webinars “Coffee Talks” with subject matter experts:
– Focused QPP topic
– Open discuss with Q & A – dedicated to your questions
– 2nd Thursday every month
– 11:00 a.m. CST for 1 hour
Nov. 9th
Dec. 14th - Final Rule for 2018
• Partner with Telligen QIO on practice improvement activities
– Participation with a QIO in a self-management training program (diabetes)
– Implementation of antibiotic stewardship program
– Implementation of a cardiac quality improvement program
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Thank you for Joining Us!
Contacts: • Iowa – Sandy Swallow
– 515-223-2105
• Illinois – Linda Brewer
– 630-928-5819
• Illinois -Temaka Williams
– 630-928-5838
• Colorado – Courtnay Ryan
– 720-554-1711
www.TelligenQINQIO.com