Post on 27-Jul-2020
© 2016, Telligen, Inc.
Michelle Brunsen & Sandy Swallow
April 27, 2017
The Qual i ty Component of MIPS:
T ips for Success
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▪ Quality Payment Program At-A-Glance
▪ Quality Category– Rules for Quality Submissions
– Benchmarks
– Point Estimation Differences
▪ Quality Scoring Methodology– Individual Scoring
– Hypothetical Example
– Tips to Maximize Score
▪ Assistance & Resources
Objectives
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Physician Quality Reporting System
(PQRS)
Value-Based Modifier (VBM or VM)
Medicare EHR Incentive Program
(aka: Meaningful Use)
Quality Payment Program (QPP)
Alternative Payment
Models (APM)
Merit-Based Incentive Payment
System (MIPS)
MACRA Background
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▪ First 2 years 2017 & 2018
– Physicians
▪ MD, DO, dental surgery, dental medicine, podiatric medicine, optometry, and chiropractic
– Physician Assistant (PA)
– Nurse Practitioner (NP)
– Clinical Nurse Specialist (CNS)
– Certified Registered Nurse
Anesthetist (CRNA)
▪ Secretary has discretion to specify additional ECs starting in Year 3 which may include:
– Certified Nurse Midwife
– Clinical Social Worker
– Clinical Psychologist
– Registered Dietitian or Nutrition Professional
– Physical or Occupational Therapist
– Speech-Language Pathologist
– Audiologist
Eligible Clinicians (EC)
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Exempt▪ Low Volume Threshold
– Medicare Part B Allowable Charges < $30k
OR
– Unique Patients < 100 attributed to you
– 2-year Low Volume Threshold determination period (either year)
▪ 9/1/15 – 8/31/16
▪ 9/1/16 – 8/31/17
▪ Newly enrolled in Medicare
▪ Significant participants in an Advanced APM
Eligible Clinicians (EC) cont.
Note: CMS eligibility letters to be sent by May 31, 2017
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Reporting Options
Type Identification Mechanism
Individual • Single NPI tied to TIN• Submit individual-level data• Data submission via claims, EHR, registry or QCDR
Group • Set of clinicians identified by NPIs sharing common TIN• Submit group-level data • Register as a group by June 30, 2017 if 25+ clinicians using
CMS web interface to submit data• Data submission via CMS web interface (25+), EHR, registry
or QCDR
APM Entity Group orMIPS-APM
• Collection of entities participating in an APM that don’t qualify for Advanced APM or meet thresholds
• Submit MIPS data to avoid downward payment adjustment
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Performance Category Weights
Quality Payment Program
Quality 60% MIPS
50% MIPS-APMs
Advancing Care Information
25% MIPS30% MIPS-APMs
Improvement Activities 15% MIPS
20% MIPS-APMs
Cost 0%
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2017 Transition Year Only
Pick Your Pace
Test PaceSubmit Something
Neutral or small bonus
Avoid Penalty
Partial Year 90 day Submission
Neutral or small bonus
No penalty
Full Year Submission
Neutral or Moderate bonus, No penalty
Participate in an Advanced APM in
2017
Don’t ParticipateReceive -4% payment
adjustment
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QPP Performance Category
Quality
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▪ Submit 6 quality measures (select 6 of 271 quality measures)
▪ Requirement: 1 Outcome Measure (or intermediate outcome)
▪ If no Outcome Measure available, choose a High Priority Measure– Appropriate Use
– Patient Safety
– Efficiency
– Patient Experience
– Care Coordination
2017 Rules for Quality Submissions
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▪ If fewer than 6 measures apply, submit all that apply
▪ If submit more than 6 measures, only top 6 will be scored
▪ NO Cross Cutting Measure requirement
▪ Required to use the same reporting mechanism for all submitted measures
▪ 1 Administrative Claims Measure for groups > 16 providers and >200 Attributed Hospitalizations – 30 Day Hospital Readmissions
▪ Total 70 points
Note: Quality requirements for CMS Web Interface or MIPS-APMs participation are different.
2017 Rules for Quality Submissions
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What if I have too few measures?
▪ Missing measures are scored and averaged in with those submitted
▪ Not scored (not averaged in) if denominator <20
▪ Need not go beyond the measures in your Specialty or Subspecialty Measure Set
▪ Reformatted Measure Applicability Validation Test (MAV) coming in 2018
2017 Rules for Quality Submissions
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▪ Measure Type– 2 Points for additional Outcome or Patient Experience Measures
– 1 Point for any other High Priority Measure
– Bonus Points capped at 10% of denominator
▪ Electronic Submission– 1 point per measure for end-to-end electronic reporting (CEHRT)
– Electronic Submission Bonus Points also capped 10% of denominator
– Qualifications
▪ Clinical data must be documented in CEHRT
▪ Processing must not include abstraction or pre-aggregation
▪ All mechanisms eligible except claims
Quality Measure Bonus Points
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CAHPS for MIPS
▪ Optional – No longer required
▪ Applicable to groups > 2 providers
▪ Must use CMS-approved Survey Vendor
▪ Survey counts as 1 Patient Experience Measure– 2 point Bonus for an Experience Measure
▪ Need 5 other quality measures– Including 1 Outcome Measure
2017 Rules for Quality Submissions
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Data Completeness Criteria
Requirements for Quality Submissions
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Special 2017 Scoring Standards for MIPS-APMs
Category Reporting Requirements
Category Scoring CategoryWeight
Quality (PQRS) • The ACO submits 30+ MSSP quality measures on behalf of ACO participant TINs and their MIPS eligible clinicians via the CMS Web Interface.
• Full calendar year reporting
• Data is submitted on the first 248 consecutively ranked and assigned Medicare beneficiaries. The ACO submits this information once for purposes of both the Medicare Shared Savings Program and MIPS.
• MIPS benchmarks will be used to assign one score at the APM Entity Group (ACO) level. In other words, all MIPS eligible clinicians on the certified ACO Participation list will receive the same score (unless they are excluded from MIPS).
• Note that the performance of all clinicians in the ACO will contribute to this score, even if they are not subject to MIPS payment adjustments.
50%
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Benchmarks – What are they?
▪ Each quality measure assessed against benchmark to determine number of points measure earns
▪ Clinician can receive 3 to 10 points for each measure (not including bonus points)
▪ Specific to type of submission mechanism
▪ Based on actual performance data submitted to PQRS in 2015, except for CAHPS
▪ CAHPS benchmarks based on 2 sets of surveys: 2015 CAHPS for PQRS and CAHPS for ACOs
2017 Rules for Quality Submissions
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Point Estimation
Decile Number of Points Assigned for the 2017 MIPS Performance Period
Below Decile 3 3 points
Decile 3 3-3.9 points
Decile 4 4-4.9 points
Decile 5 5-5.9 points
Decile 6 6-6.9 points
Decile 7 7-7.9 points
Decile 8 8-8.9 points
Decile 9 9-9.9 points
Decile 10 10 points
QPP Quality Program in 2017
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Benchmark breakdown for each measure
▪ Measure name and ID
▪ Submission type (EHR, QCDR/Registry, claims)
▪ Measure type (outcome, process)
▪ Whether or not benchmark could be calculated for that measure/submission mechanism
▪ Range of performance rates for each decile
▪ Whether the benchmark is topped out (measure isn’t showing much variability and may have different scoring in future years)
QPP Quality Category for 2017
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Where Do I Find Benchmarks?
2017 Quality Benchmarks available at: https://qpp.cms.gov/resources/education
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Navigating to the 2017 Benchmarks
CMS QPP Website Screenshots
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MIPS Benchmarks
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2017 Quality Benchmarks
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MIPS Benchmark Results Example
QPP Quality Category for 2017
Table 2: MIPS Benchmark Results
Measure_NameMeasure_
IDSubmission_
MethodMeasure_
TypeBenchmark
Decile 3 Decile 4 Decile 5
Decile 6
Decile 7
Decile 8
Decile 9
Decile 10
Topped Out
Breast Cancer Screening 112 Claims Process Y38.46 -48.01
48.02 -55.67
55.68 -62.78
62.79 -69.41
69.42 -77.18
77.19 -87.87
87.88 -98.52
>= 98.53 No
Breast Cancer Screening 112 EHR Process Y12.41 -22.21
22.22 -32.30
32.31 -40.86
40.87 -47.91
47.92 -55.25
55.26 -63.06
63.07 -73.22
>= 73.23 No
Breast Cancer Screening 112Registry/QC
DR Process Y14.49 -24.52
24.53 -35.70
35.71 -46.01
46.02 -55.06
55.07 -63.67
63.68 -74.06
74.07 -87.92
>= 87.93 No
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Category Benchmark
Quality 2 years prior to performance year
New Measures Performance year
Web Interface MSSP benchmarks
Cost Performance year
▪ Specific to submission method
▪ 3 point floor for new measures
▪ Risk adjusted to Hierarchical Condition Codes (HCC)
▪ > 20 eligible instances to contribute
▪ Zero percent performance not included
More on Quality Benchmarks
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QPP Performance Category
Quality Scoring Methodology
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Individual Measure Scoring
▪ Each measure scored on 1-10 decile scale
▪ Missing measure score = 0
▪ Measures submitted and valid but not scored removed from average– Must have a benchmark to be scored
– Must have > 20 eligible instances to be scored
▪ Top 6 measures are scored when extra measures Scores are reversed for inverse measures (positive performance is seen in a lower score). Higher scores are in lower deciles, but lowest decile still receive lowest points.
2017 Quality Performance Scoring
Converting a Performance Rate to a Standard ScoreSubmit to CMS Expressed as a Normalized Score
0-100% 1.0 – 10.0
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▪ CMS Web Interface Reporter total score– 120 points for groups with
complete reporting and the readmission measure
– 110 points for groups with complete reporting and no readmission measure
▪ Other submission mechanisms total score– 70 points for 6 measures + 1
readmission measure
– 60 points if readmission measure does not apply
MIPS Scoring for Quality
Maximum Number of Points
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Converting a Performance Rate to a Standard Score
2017 Quality Performance Scoring
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Hypothetical Scoring Example
2017 Quality Performance Scoring
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Hypothetical Scoring Example
2017 Quality Performance Scoring
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Hypothetical Scoring Example
2017 Quality Performance Scoring
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Hypothetical Scoring Example
2017 Quality Performance Scoring
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Survive and Thrive in the Quality Category
▪ Review past performance
▪ Select measures that matter
▪ Have extra measures in the hopper
▪ Continuously monitor your performance
▪ Continuous metric improvement program
Data Value Stream
– Providing the care
– Capturing data without disrupting workflow
– Documenting the care
– Extracting the data
– Submission compliance
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Quality Payment Program
Assistance & Resources
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Where Can Eligible Clinicians Go for Help?
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Full Service QPP Technical Assistance
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▪ CMS QPP Website– Resource Page: https://qpp.cms.gov/resources/education
▪ 2017 Quality Benchmarks (below Registries, QCDRs and EHR Vendors)
– Slides from MIPS Overview - Understanding Quality and Cost Webinar: CMS Quality and Cost Webinar
– Quality Measure Selection: https://qpp.cms.gov/measures/quality
▪ Quality Measure Benchmarks Overview: Quality Measure
Benchmarks Overview
Resources
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Questions?
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▪ MIPS Survive & Thrive: Advancing Care Information – Thursday, May 25
– 12:00 p.m. – 1:00 p.m. Central
– Register here OR go to https://telligenqpp.com/events/ and select the May 25th webinar
Next Webinar
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Thank you for joining us!
Sandy Swallow515-223-2105
Sandy.swallow@area-D.hcqis.org
www.telligenqinqio.com
Michelle Brunsen515-453-8180
mbrunsen@telligen.com
www.telligenqpp.com
This material was prepared by Telligen, the Quality Payment Program Small, Underserved and Rural Support contractor for Iowa, Nebraska, North Dakota and South Dakota, 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 policy. HHSM-500-2017-00012C
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 policy