2018 MIPS Update€¦ · Category Reporting Requirements. Quality – Report 6 measures – Include...
Transcript of 2018 MIPS Update€¦ · Category Reporting Requirements. Quality – Report 6 measures – Include...
2018 MIPS Update
Beth HickersonQPP Advisor
November 9, 2017
Value Driven. Health Care. Solutions.
Disclaimer
Medical Advantage Group would like to disclose that no one in a position to control or influence the content of this activity has reported relevant financial relationships with commercial interests.
The information and guidelines contained in this activity are generalized and may not apply to all practice situations. The faculty recommends that legal advice be obtained from a qualified attorney for specific application to your practice.The information is intended for educational purposes and should be used as a reference guide only.
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Housekeeping
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WHAT DOES NOT CHANGE IN 2018?
MIPS Eligible Providers
Years 1 and 2 Medicare Part B clinicians:
Physicians MD, DOPodiatristsOptometristsChiropractorsDentistsPhysician AssistantsNurse PractitionersClinical Nurse SpecialistsCertified Registered Nurse Anesthetists
Year 3+ Medicare Part B clinicians:
Occupational TherapistsPhysical TherapistsSpeech TherapistsAudiologistsNurse MidwivesClinical Social WorkersDietitians
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Who is Exempt from MIPS?
3 groups of clinicians:
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First year of Medicare Part B
participation
Below low patient volume threshold
Certain participants in
ADVANCEDAlternative
Payment ModelsBUT low-volume threshold
has increased!
Category Reporting Requirements
Quality– Report 6 measures– Include at least one outcome or high-priority measureAdvancing Care Information– ACI Objectives and Measures OR– 2017 ACI Transition Objectives and MeasuresImprovement Activities – Attest to up to 4 activities– Double-credit for small, rural, and under-served practicesCost– No submission required, data collected from claims
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Submission Methods
MIPS GENERAL CHANGES
Payment Adjustment Increase
Takeaway:• Stakes are getting higher each year.• Payment year 2021 increases to -/+7%
Payment Year 2019 Payment Year 2020-4% to +4% -5% to +5%
Category Weights
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Quality Advancing Care
Information
Improvement Activities
Cost
50% 25% 15% 10%
Takeaway:• Cost will factor into your 2018 MIPS Final Score!
Reporting Periods
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2017 201Category 2017 2018
Quality 90 days 365 days
Advancing Care Information 90 days 90 days
Improvement Activities 90 days 90 days
Cost 365 days 365 days
Takeaway:• Quality measure workflows and tracking must be in
place by January 1 for optimal performance.
Low-volume Threshold
Takeaway:• Many providers who were NOT exempt in 2017 will be
exempt in 2018.• Elective participation in 2018?
• Individual – no incentive, regardless of performance• Group – subject to same payment adjustment as
group
2017 2018</= $30,000 Part B charges </= $90,000 Part B charges</+ 100 Part B patients </+ 200 Part B patients
Virtual Groups
Combination of 2 or more TINs made up of 1-10 eligible clinicians who report aggregated dataEach TIN must exceed the low-volume thresholdSubject to the same requirements and benefits as single TIN groupsNot specialty or location specificElection process requiredMore info available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/2018-Virtual-Groups-Toolkit.zip
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Performance threshold
Takeaway:• You can NOT avoid penalty by submitting just one
Quality measure.• You CAN avoid penalty by topping out your
Improvement Activities category score.
2017 20183 points 15 points
Exceptional Performer Threshold
Takeaway:• Earning the extra 0.5% to 10% incentive is still very
achievable for providers reporting all MIPS categories.
2017 201870 points 70 points
Complex Patient Bonus
Up to 5 points for the treatment of complex patients – Based on Hierarchical Condition Categories (HCCs)
and– Number of dually eligible patients treatedAdded to MIPS Final Score
Takeaway:• Make sure your providers are coding to maximize
HCCs.
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Small Practice Bonus
Five points automatically added for any individual or group who is in a small practice (15 or fewer providers)Must submit data in at least 1 MIPS categoryAdded to MIPS Final Score
Takeaway:• No extra work necessary!
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MIPS Hardship Exceptions
Designed to accommodate providers impacted by natural disasters (hurricanes, fires, etc.)Impacted providers will not receive a penalty if they fail to report MIPS dataRetroactive to 2017Automatically given in 2017 to all providers in identified areas (hurricanes Irma and Harvey, wildfires, etc.)Providers must apply for exception in 2018
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QUALITY CHANGES
Quality Measures
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2017 2012017 2018
Total # of measures 291 297Specialty measure sets 31 32Removed n/a 3New n/a 9Substantive changes n/a 12
Takeaway:• Vast majority of practices will be able to report the same
Quality measures in 2018
Removed Quality Measures
Stroke and Stroke Rehabilitation: Discharged on Antithrombotic TherapyParkinson’s Disease: Parkinson’s Disease Medical and Surgical Treatment Options ReviewedUse of Imaging Studies for Low Back Pain
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Takeaway:• If you are reporting any of these measures in 2017, you
will not be able to report them in 2018.
New Quality Measures
Well-child visits in the third, fourth, fifth and sixth year of lifeDevelopmental screenings in the first three years of lifeAverage Change in Back Pain following Lumbar Discectomy / LaminotomyAverage Change in Back Pain following Lumbar FusionAverage Change in Leg Pain following Lumbar Discectomy / LaminotomyBone Density Evaluation for Patients with Prostate Cancer and Receiving Androgen Deprivation TherapyPrevention of Post-Operative Vomiting (POV) - Combination Therapy (Pediatrics)Otitis Media with Effusion (OME): Systemic Antimicrobials-Avoidance of Inappropriate UseUterine Artery Embolization Technique: Documentation of Angiographic Endpoints and Interrogation of Ovarian Arteries
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Substantive Measure Changes
Tobacco Use: Screening and Cessation Intervention– Now 3 rates instead of 1Body Mass Index (BMI) Screening and Follow-Up Plan– Decreased BMI measurement frequency from 6 months to 12
monthsInfluenza Immunization– Removed 2 visit requirement for inclusion in denominatorUse of High-Risk Medications in the Elderly– Rate B changed from two different medications to two instances
of the same medicationClosing the Referral Loop: Receipt of Specialist Report – Added option to report via registry
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Data Completeness Criteria
Submission Method 2017 2018Claims 50% of Medicare Part B 60% of Medicare Part B
Registry, QCDR, EHR
50% of all payors 60% of all payers
Web Interface Medicare Part B sampling Medicare Part B sampling
CAHPS for MIPS Medicare Part B sampling Medicare Part B sampling
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Takeaway:• If you submit via claims, manually enter data into a
registry, or practice in multiple settings, make sure you are reporting on 60% of applicable patients
Quality Scoring - No Changes
3-point minimum for all reported Quality measures scored against a benchmark3 points for each measure that– Does not have a benchmark– Does not have at least 20 patients in the denominatorBonus points for additional outcome and high priority measure reportingBonus points for end-to-end electronic reporting
Takeaway:• Keep doing what you’re doing.
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Quality Scoring - Changes
Reported measures that do not meet data completeness requirements will score– 3 points for small practices (15 or fewer providers)– 1 point for larger practices (16 or more providers)
Takeaway:• Small practices – no effective change• Large practices – virtually no credit for reporting
measures that do not meet data completeness standards
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Quality Scoring – Topped Out Measures
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Six measures with 7-point scoring maximum– Perioperative Care: Selection of Prophylactic Antibiotic-First or
Second Generation Cephalosporin– Melanoma: Overutilization of Imaging Studies in Melanoma– Perioperative Care: Venous Thromboembolism (VTE)
Prophylaxis (When Indicated in ALL Patients– Image Confirmation of Successful Excision of Image Localized
Breast Lesion– Optimizing Patient Exposure to Ionizing Radiation: Utilization of a
Standardized Nomenclature for Computerized Tomography (CT) Imaging Description
– Chronic Obstructive Pulmonary Disease (COPD): Inhaled Bronchodilator Therapy
Quality Scoring - Improvement Points
Earn up to 10 points for improving your achievement score (without bonus points) over 2017Improvement measured at the category levelImprovement must be statistically significant to earn pointsMore improvement = more bonus points
Takeaway:• Improvement can have a significant payoff. You will
earn more points for the measure itself AND earn overall improvement points.
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ADVANCING CARE INFORMATION CHANGES
New Base Measure Exclusions
Electronic Prescribing– Claim exclusion if provider/group writes fewer than
100 prescriptions during the reporting periodHealth Information Exchange – Claim exclusion if provider/group refers fewer than
100 patients during the reporting period
Takeaway:• Many providers practicing in acute care settings can
now successfully report ACI.• You can avoid the hassle of sending electronic
summaries of care for a couple more years.
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CEHRT Edition Requirements
Can use 2014 Edition and/or 2015 Edition technology to report2015 Edition will be required in 2019 reporting year90 day reporting period for 2018 and 2019
Takeaway:• You can continue to use the 2017 Advancing Care
Information Transition List of Objectives and Measures in 2018.
• Select a reporting period for 2018 that is prior to your 2015 Edition update, if possible.
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ACI Measures Scoring
Measure Type 2017 2018Base measures Must have 1 in
numerator for each measure to earn 50%
category score
Must have 1 in numerator for each to
earn 50% category score
Performance Measures
Earn 1-10 performance points for each optional
measure submitted
Earn 1-10 performance points for each optional
measure submitted
Public Health or QCDR reporting
Not eligible for performance points
Earn 10% performance points
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T k
Takeaway:• Very similar to 2017 scoring
ACI Bonus Points
Measure Type 2017 2018CEHRT Improvement Activity
10% bonus points 10% bonus points
Use of 2015 CEHRT
No points awarded 10% bonus points
Public Health or QCDR reporting
Earn 5% bonus points 5% bonus point for reporting to second PH
agency or QCDR
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Takeaway:• Additional bonus point options not feasible for most
practices
IMPROVEMENT ACTIVITIES CHANGES
Improvement Activities
Submission Method
2017 2018
Activities List 92 activities 112 activities
PCMH CreditOnly 1 practice site must meet PCMH
requirements
50% of practice sites must meet PCMH
requirementsCEHRT Activities for ACI Bonus Points
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Takeaway:• Even more options for maxing out this category!
COST CHANGES
Cost Measures
2017 2018Total Per Capita Cost Total Per Capita CostMedicare Spending per Beneficiary
Medicare Spending per Beneficiary
10 episode based care measures No episode-based care measures
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Takeaway:• If no Cost score can be calculated, 10% weighting will
be shifted to Quality• Pull your 2016 Quality Resource Use Report (QRUR)
for historical practice data on Cost measures
Cost Measures Explained
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Total Per Capita Cost• All Medicare Part A and Part B costs during the performance
period• Two-step attribution process• 20 patient case minimum for measure scoreMedicare Spending Per Beneficiary
• Medicare costs associated with a hospitalization (immediately prior, during, and immediately after)
• Only for clinicians who see patient in the hospital• Episode attributed to clinician who provided plurality of Part B
services during the admission• 35 patient case minimum for measure score
Q AND A
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