Post on 03-Jul-2020
MIPS IN 2017: A DEEP DIVE
Presented by: James Christina, DPM 301-581-9265 jrchristina@apma.org
SGR
MACRA (The Medicare Access and CHIP Reauthorization Act of 2015)
Quality Payment Program
MIPS APM
Highest total of 100
EPs will receive either a positive or negative payment adjustment to Medicare part B fee schedule based on MIPS score
Almost all podiatrists will report through MIPS first year
MIPS Score
Thresholds
CMS set the Performance Threshold at 3 and the Exceptional Performance Threshold at 70, meaning that any clinician with a score of at least 3—which can be accomplished by submitting, for example, just one Quality measure—will avoid a negative adjustment, and those earning a score of at least 70 will be eligible for an Exceptional Performance Adjustment from the annual $500 million pool.
2019: -4% to +4% (based on 2017 score) 2020: -5% to +5% (based on 2018 score) 2021: -7% to +7% (based on 2019 score) 2022 : -9% to +9% (based on 2020 score)
MIPS Adjustments
Mostly budget neutral
Penalty no more than 4%
Most positive adjustments no more than 4% …positive moved based on budget neutrality
“Exceptional Performance” (MIPS Score of 70 or higher—access to additional $500 million bonus pool)
MIPS Year 1
CMS proposes to define MIPS eligible clinicians or groups who do not exceed the low-volume threshold as an individual MIPS eligible clinician or group who, during the performance period, has Medicare billing charges less than or equal to $30,000 or provides care for 100 or fewer Part B-enrolled Medicare beneficiaries.
Newly Medicare-enrolled eligible clinicians Qualifying APM Participants (QPs) Certain Partial Qualifying APM Participants (Partial
QPs)
Exclusions:
Two determination period options to meet 2017 low volume threshold:
9/1/2015 - 8/31/2016 or 9/1/2016 - 8/31/2017
MIPS
MIPS Participation Status Letter
The Centers for Medicare & Medicaid Services is reviewing claims and letting practices know which clinicians need to take part in MIPS, the Merit-based Incentive Payment System. MIPS is an important part of the new Quality Payment Program. In late April through May, practices will get a letter from the Medicare Administrative Contractor that processes Medicare Part B claims. This letter will tell the participation status of each MIPS clinician associated with the Taxpayer Identification Number or TIN in a practice.
Clinicians should participate in MIPS for the 2017 transition year if they bill more than $30,000 in Medicare Part B allowed charges a year AND provide care for more than 100 Part B-enrolled Medicare beneficiaries a year.
The Quality Payment Program intends to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for their overall work in delivering the best care for patients. It replaces the Sustainable Growth Rate formula and streamlines the “Legacy Programs” Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM), and the Medicare Electronic Health Records (EHR) Incentive Program. During this first year of the program CMS is committed to diligently working with you to streamline the process as much as possible. Our goal is to further reduce burdensome requirements so that you can deliver the best possible care to patients.
MIPS Participation Status Letter
MIPS reporting not limited to Medicare patients* (but some quality measures do have age ranges in their denominators so pay attention to them) *Reporting Quality Component by Claims method is exception
MIPS
Quality 60%
ACI 25%
Clinical PracticeImprovement Activities15%Cost 0%
MIPS Score Performance Year 2017
Three options with regards to MIPS
CHOSE YOUR COURSE OF PARTICIPATION
Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment.
MAXIMUM MIPS
Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment
and to possibly receive a positive MIPS payment adjustment.
MODERATE MIPS
Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative payment adjustment.
MINIMUM MIPS
For the 2017 transition year, if the measure is submitted but is unable to be scored because it does not meet the required case minimum (20), does not have a benchmark, or does not meet the data completeness requirement (at least 50% reporting rate), the measure will receive a score of 3 points
MINIMUM SCORE OF 3
Four percent payment reduction on Medicare Part B Fee For Service
Payments in 2019
WHAT ABOUT NO MIPS?
-4%
Choose 6 MIPS Quality measures One must be an outcome measure (or if no outcome
available then a high priority measure)
All 6 must be reported by the same method
MIPS Quality (60%)
Claims 50% or more of Medicare Part B patients
Registry 50% or more of all patients
EHR 50% of all patients
CMS Web Interface (groups of 25+)
ALL SIX MUST BE SUBMITTED BY SAME MECHANISM
Quality Measures Submission Methods
QPP.CMS.GOV
QPP.CMS.GOV
QPP.CMS.GOV
QPP.CMS.GOV
QPP.CMS.GOV
1. Documentation of Current Meds in the Medical Record*
2. Diabetes: Hemoglobin A1c (HbA1c) Poor Control - Intermediate Outcome
3. Pain Assessment and Follow-Up 4. Pneumococcal Vaccination Status for Older Adults 5. BMI Screening and Follow Up Plan 6. Influenza Immunization 7. Screening for High Blood Pressure and Follow Up 8. Tobacco Screening and Cessation Intervention
QUALITY MEASURES Claims Reporting
*High priority measure
1. Documentation of Current Meds in the Medical Record*
2. Pneumococcal Vaccination Status for Older Adults 3. BMI Screening and Follow Up Plan 4. Influenza Immunization 5. Screening for High Blood Pressure and Follow Up 6. Tobacco Screening and Cessation Intervention
Six Recommended Measures to Report by Claims (Medicare Part B Patients Only)
How Points for Measures are Assigned (Claims Decile)
Documentation of Current Medications in Medical Record*
Pneumococcal Vaccination Status for Older Adults
BMI Screening and Follow Up Plan
Influenza Immunization
Screening for High Blood Pressure and Follow Up
Tobacco Screening and Cessation Intervention
You are submitting by claims method so must be a Medicare Part B Fee for Service patient (not Medicare Advantage, Medicare HMO, etc.)
You must be seeing them for one of the denominator designated codes (essentially an E/M service)
You must place the quality measure code on the claim form under item 24
KEY POINTS
1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control
- Intermediate Outcome 2. Diabetes: Medical Attention for Nephropathy 3. Diabetic Foot and Ankle Care, Peripheral Neuropathy
– Neurologic Exam 4. Diabetic Foot and Ankle Care, Ulcer Prevention –
Examination of Footwear 5. Documentation of Current Meds in the Medical Record 6. Immunizations for Adolescents
QUALITY MEASURES
Registry Reporting
7. Functional Status Change for Patients with Foot or Ankle
Impairments – Outcome 8. Pain Assessment and Follow-Up 9. Pneumococcal Vaccination Status for Older Adults 10. Preventive Care & Screening: Body Mass Index (BMI)
Screening & Follow-Up Plan 11. Preventive Care and Screening: Influenza Immunization 12. Screening for High Blood Pressure and Follow Up 13. Preventive Care and Screening: Tobacco Use: Screening and
Cessation Intervention 14. Preventive Care and Screening: Unhealthy Alcohol Use:
Screening & Brief Counseling
QUALITY MEASURES Registry Reporting
1. Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam
2. Diabetic Foot and Ankle Care, Ulcer Prevention – Examination of Footwear
3. Documentation of Current Meds in the Medical Record*
4. Screening for High Blood Pressure and Follow Up 5. Preventive Care and Screening: Tobacco Use:
Screening and Cessation Intervention 6. Preventive Care & Screening: Body Mass Index (BMI)
Screening & Follow-Up Plan
Six Recommended Registry Measures (All patients)
1. Diabetes: Foot Exam 2. Diabetes: Hemoglobin A1c (HbA1c) Poor Control
(>9%) – Intermediate Outcome 3. Diabetes: Medical Attention for Nephropathy 4. Documentation of Current Medications in the Medical
Record* 5. Falls: Screening for Future Fall Risk* 6. Pneumococcal Vaccination Status for Older Adults 7. Preventive Care and Screening: Body Mass Index
(BMI) Screening and Follow-Up Plan
QUALITY MEASURES
EHR Reporting
8. Preventive Care and Screening: Influenza
Immunization 9. Preventive Care and Screening: Screening for High
Blood Pressure and Follow-Up Documented 10. Preventive Care and Screening: Tobacco Use:
Screening and Cessation Intervention
QUALITY MEASURES
EHR Reporting
When choosing quality measures check minimum case requirements!
Most minimum case requirements listed as 20
QUALITY MEASURES
In 2017, there are two measure set options for reporting. The option you use to submit your data is based on your electronic health record edition. Option 1: Advancing Care Information Objectives and Measures Option 2: 2017 Advancing Care Information Transition Objectives and Measures
You can report the Advancing Care Information Objectives and Measures (Option 1):
If you have technology certified to the 2015 Edition; or If you have a combination of technologies from 2014 and 2015 Editions that
support these measures.
You can report the 2017 Advancing Care Information Transition Objectives and Measures (Option 2): If you have technology certified to the 2015 Edition; or If you have technology certified to the 2014 Edition; or If you have a combination of technologies from 2014 and 2015 Editions.
Advancing Care Information (Think Meaningful Use)
4 Measures if using 2014 ONC Certified EHR
(Transition—Option 2)
Advancing Care Information (25%)
40% credit just for reporting the for base measures
Other 60% depends on performance and bonus measures
No more clinical decision support rule No more CPOE
Advancing Care Information (25%)
Base Score + Performance Score + Bonus Points
Total ACI Score
Base score: 10 points for reporting a measure Base Score: Max 40 Need numerator to be ≥ 1 for each
ACI Base Score
Protect Patient Health Information (yes/no) MUST BE A “YES” OR ZERO FOR ACI Electronic Prescribing At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology. Provide Patient Electronic Access Health Information For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient's health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programing Interface (API) in the MIPS eligible clinician's certified EHR technology Send A Summary of Care For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider-(1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record.
MIPS ACI Base 4 Measures (Transition)
Performance Score: Receive 1-10 points for each measure reported based on performance of that measure
Performance Score: Max 70 points
ACI Performance Score
5 Bonus Points for reporting to any additional public health or clinical data registry
10 Bonus Points for achieving one Improvement Activity via CEHRT
ACI Bonus Points
1. Provide Patient Electronic Access (additional 10%) 2. Health Information Exchange (additional 10%) 3. View, Download, or Transmit (VDT) (up to 10%) 4. Provide Patient-Specific Education (up to 10%) 5. Secure Messaging (up to 10%) 6. Medication Reconciliation (up to 10%) 7. Immunization Registry Reporting (0 or 10%) 8. Syndromic Surveillance Reporting (5% bonus) 9. Specialized Registry Reporting (5% bonus)
ACI Performance and Bonus Measures
Score 100 or above on ACI = full 25 MIPS points
ACI
Reporting Score + Performance Score + Bonuses = Total ACI Score
If earn 100 (or more), get the full 25 MIPS score
If earn less than 100, declines proportionately. It is
not all or nothing! 50 ACI points means 12.5 MIPS points
ACI Total Score
List of more than 90 options
Choose up to 4 activities if in a group of more than 15 clinicians
Choose up to 2 activities if in a group of 15 or fewer clinicians
Clinical Practice Improvement Activities (15%)
Medium weight = 10 points High weight = 20 points Activities double weighted if group of less than
15
Score Needed for full CPIA credit—40 CPIA points
means 15 MIPS points
Clinical Practice Improvement Activities (15%)
QPP.CMS.GOV
1. Registration in your state’s prescription drug monitoring program - Medium
2. Implement Fall Screening & Assessment Program - Medium 3. Provide 24/7 access to clinician who has real-time access
to patient’s medical record - High 4. Assess patient experience of care through surveys,
advisory councils and/or other mechanisms - Medium 5. Use decision support and standardized treatment protocols
- Medium 6. Program to send reports back to referring clinician -
Medium
Clinical Practice Improvement Activities (15%)
7. Collection and follow-up on patient experience and satisfaction data on beneficiary engagement - High
8. Collection and use of patient experience and satisfaction data on access - Medium
9. Consultation of the Prescription Drug Monitoring program - High
10. Engagement of community for health status improvement - Medium
11. Engagement of patients, family and caregivers in developing a plan of care - Medium
Clinical Practice Improvement Activities (15%)
12. Engagement of patients through implementation of improvements in patient portal – Medium
13. Implementation of condition-specific chronic disease self-management support programs - Medium
14. Implementation of use of specialist reports back to referring clinician or group to close referral loop - Medium
15. Improved practices that disseminate appropriate self-management materials - Medium
16. Use of decision support and standardized treatment protocols - Medium
Clinical Practice Improvement Activities (15%)
Calculated by claims review so no additional reporting
Higher points for more efficient resource use
Not implemented in 2017 but CMS is supposed to give providers this analysis so they can anticipate 2018
Cost (0% in 2017)
Exempt from MIPS payment adjustments
Successful participation = 5% bonus and no MIPS adjustment
Have to receive certain amount of payments or see certain number of patients through APM
APMs
Advanced APMs are those in which clinicians accept risk for providing coordinated, high- quality care.
APMs
APMA.org/MACRA
MACRA Made Easy Webinar Series
MIPS in 2017 • Advancing Care Information Quality Performance Category • Improvement
Activities Performance Category For other MACRA-related Resources, visit
APMA.org/MACRA
APMA.org/MacraWebinars
Resources For more information on Quality measures: https://qpp.cms.gov/measures/quality For more information on CPIA: https://qpp.cms.gov/measures/ia For more information on Advancing Care: https://qpp.cms.gov/measures/aci Quality Payment Program (CMS Web Page): https://qpp.cms.gov/
QUESTIONS