MIPS IMPROVEMENT ACTIVITIES PERFORMANCE CATEGORY IN 2019 (YEAR 3) WEBINAR

Thursday, May 23, 2019

Disclaimers

This presentation was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services.

This publication is a general summary that explains certain aspects of the Medicare Program but is not a legal document. The official Medicare Program provisions are contained in the relevant laws, regulations, and rulings. Medicare policy changes frequently, and links to the source documents have been provided within the document for your reference

The Centers for Medicare & Medicaid Services (CMS) employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this guide.

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Topics

• Overview of the Quality Payment Program

• Merit-based Incentive Payment System Basics

• Improvement Activities Performance Category

- Basics

- Reporting Requirements

- Data Submission

- Scoring

• Resources and Technical Assistance

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Quality Payment ProgramQuick Overview

The Quality Payment Program consists of two participation tracks for clinicians:

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MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS) Basics for Year 3 (2019)

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Merit-based Incentive Payment System (MIPS)

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Quick Overview

MIPS Performance Categories

• Comprised of four performance categories in 2019

• So what? The points from each performance category are added together to give you a MIPS Final Score

• The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment

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Merit-based Incentive Payment System (MIPS)MIPS Eligible Clinician Types

For 2019, MIPS Eligible Clinicians Include:

• Physicians

• Physician Assistants

• Nurse Practitioners

• Clinical Nurse Specialists

• Certified Registered Nurse Anesthetists

• Clinical Psychologists

• Physical Therapists

• Occupational Therapists

• Audiologists

• Speech Language Pathologists

• Registered Dieticians or Nutrition Professionals

• Groups of such clinicians

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Merit-based Incentive Payment System (MIPS)Low-Volume Threshold

How Does the Low-Volume Threshold Work?

• CMS conducts MIPS determination periods where we’ll look to see if you as an individual MIPS eligible clinician exceed the following criterion:

• Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS)

AND

• Furnish covered professional services to more than 200 Medicare beneficiaries

AND

• Provide more than 200 covered professional services under the PFS

So What?

• If you exceed all three criterion, you are included in MIPS and required to participate by submitting performance data

• If you do not exceed all three criterion, you are excluded from MIPS

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General Timeline

Merit-based Incentive Payment System (MIPS)

Performance period

2019Performance Year

• Performance period opens January 1, 2019

• Closes December 31, 2019

• Clinicians care for patients and record data during the year

submit

March 31, 2020Data Submission

• Deadline for submitting data is March 31, 2020

• Clinicians are encouraged to submit data early

Feedback available

Feedback

• CMS provides performance feedback after the data is submitted

• Clinicians will receive feedback before the start of the payment year

adjustment

January 1, 2021Payment Adjustment

• MIPS payment adjustments are prospectively applied to each claim beginning January 1, 2021

IMPROVEMENT ACTIVITIESPerformance Category Basics

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Improvement Activities in 2019Performance Category Basics

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The Improvement Activities Performance Category is worth 15% of the MIPS Final Score in 2019

Improvement Activities for Year 3Performance Category Basics

The Improvement Activities Performance Category:

• Assesses participation in activities that improve clinical practice, including:

- Ongoing care coordination

- Clinician and patient shared decision making

- Regular implementation of patient safety practices

- Expanding practice access

• Has a minimum performance period of 90 continuous days (for 2019, up to and including the full calendar year (January 1, 2019, through December 31, 2019))

- Each activity can be reported only once during the 12-month performance period unless otherwise specified within the improvement activity description

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Improvement ActivitiesPerformance Category Basics

Clinicians can choose to participate in an APM or choose from 118 activities under 8 subcategories:

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1. Expanded Practice Access (EPA) 2. Population Management (PM) 3. Care Coordination (CC)

4. Beneficiary Engagement (BE)5. Patient Safety and

Practice Assessment (PSPA)6. Achieving Health Equity (AHE)

7. Integrating Behavioral and Mental Health (BMH)

8. Emergency Preparedness and Response (EPR)

Improvement Activities in Year 3New in 2019

• There are 6 new improvement activities available for the 2019 performance period:

- Comprehensive Eye Exams (Activity ID: IA_AHE_7)

- Financial Navigation Program (Activity ID: IA_BE_24)

- Completion of Collaborative Care Management Training Program (Activity ID: IA_BMH_10)

- Relationship-Centered Communication (Activity ID: IA_CC_18)

- Patient Medication Risk Education (Activity ID: IA_PSPA_31)

- Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinician Decision Support (Activity ID: IA_PSPA_32)

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Improvement Activities in Year 3New in 2019

• There are 5 existing improvement activities that were modified for the 2019 performance period:

- Care Transition Documentation Practice Improvements (Activity ID: IA_CC_10)

- Chronic Care and Preventative Care Management for Empaneled Patients (IA_PM_13)

- Participation in MOC Part IV (Activity ID: IA_PSPA_2)

- Use of Patient Safety Tools (Activity ID: IA_PSPA_8)

- Implementation of Analytic Capabilities to Manage Total Cost of Care for Practice Population (Activity ID: IA_PSPA_17)

• One improvement activity [IA_PM_9] was removed because it is duplicative of IA_PM_17: Participation in Population Health Research.

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IMPROVEMENT ACTIVITIESReporting Requirements

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Improvement Activities in 2019

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Reporting Requirements

Total Points = 40

Activity Weights

Medium = 10 points High = 20 points

Special Status Weights*

Medium = 20 points High = 40 points

*For clinicians in small, rural, and underserved practices or with non-patient facing clinicians or groups

Improvement Activities in 2019Reporting Requirements

Reporting Requirements for Clinicians With or Without Special Statuses

Clinicians Who Do Not Qualify for Special Statuses

If you…

Are participatingin MIPS as an

individual, group, or virtual group

andDo not qualify

for aspecial status*

…then the following are your reporting requirements:

• 2 high-weighted activities; or• 1 high-weighted activity and

2 medium weighted activities; or

• 4 medium-weighted activities

Clinicians Who Qualify for Special Statuses

If you…

Are participatingin MIPS as an

individual, group, or virtual group

andDo qualify

for aspecial status

…then the following are your reporting requirements:

• 1 high-weighted activity; or• 2 medium weighted activities

Note: When reporting as a group or virtual group, your small practice, non-patient facing, rural, or HPSA designations must be granted at the group or virtual group level to qualify for the reduced reporting requirements described above. Specifically, more than 75 percent of the National Provider Identifiers (NPIs) billing under your group’s Tax Identification Number (TIN) or virtual group’s TIN must be designated as either non-patient facing, rural, or located in a geographic HPSA. Non-patient facing determinations are made using claims and Medicare Provider Enrollment, Chain, and Ownership System (PECOS) data analyzed during the two segments of the MIPS determination period. Rural area and geographic HPSA determinations don’t use the MIPS determination period.

Special statuses include: small practice (15 or fewer clinicians), rural, Health Professional Shortage Area (HPSA), non-patient facing

*APM or MIPS APM participants and certified/recognized Patient-Centered Medical Home (PCMH) or comparable specialty practices are not considered special statuses, but may qualify for credit in the Improvement Activities performance category.

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Improvement Activities in 2019Reporting Requirements: PCMH or Comparable Practice

A MIPS eligible clinician who is in a practice that is certified or recognized as a PCMH, including:

- A Medicaid Medical Home Model (MMHM)

- Medical Home Model (MHM)

OR

- Comparable specialty practice

Will receive 100 percent for the IA performance category

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• Starting in performance year 2018, at least 50 percent of the practice sites within a group’s TIN must be recognized as a patient-centered medical home or comparable specialty practice

• They must attest to their status as a PCMH or comparable specialty practice to receive full credit

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Improvement Activities in 2019Reporting Requirements: APM or MIPS APM Participants

APM Participants

• If you’re a MIPS eligible clinician participating in an APM that is not a MIPS APM and is not scored under the APM Scoring Standard, you can get credit for participating in an APM and receive at least one half of the total points (50 percent) for the MIPS IA score

• You will need to select additional improvement activities to achieve the highest score

MIPS APM Participants

MIPS eligible clinicians identified as participating in a MIPS APMs are scored under the APM scoring standard and are assigned an IA score

• This score will be at least 50 percent of the highest potential score and may be higher

• CMS will develop an IA score for each MIPS APM by comparing the requirements of the specific MIPS APM with the list activities in the IA Inventory

• After completing the comparison, if the MIPS APM does not receive the maximum IA score, the APM entity can submit additional improvement activities

IMPROVEMENT ACTIVITIESScoring

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Scoring for the IA Category

Improvement Activities

Performance Category Score

=

Total number of points scored for completed activities

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Total maximum number of points (40)

x 100

• Note: Starting with the 2019 MIPS performance year, CMS is not awarding Promoting Interoperability performance category bonus points for completing improvement activities using Certified EHR Technology (CEHRT) qualifications

Quick Tip: Maximum Score cannot exceed 100 percent

Scoring for the IA CategoryExample

• Scenario 1: You are a clinician in a large practice and complete 1 medium-weighted improvement activity for 10 of 40 points in the category. 10 of 40 = 25% of available points for Improvement Activities.

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IA Score: 25%

IA Weight: 15% =

IA Final Score:3.75%

Tip: Credit in the Improvement Activities category is capped at 40 points or 100 percent. So, Improvement Activities can contribute toward no more than 15 percent of your final score even

if you submit more than 40 “points worth” of activities

Scoring for the IA CategoryExample

• Scenario 2: You are a clinician in a large practice and complete 1 high-weighted improvement activity and 1 medium weighted activity for 30 of 40 points in the category. 30 of 40 = 75% of available points for Improvement Activities.

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IA Score: 75%

IA Weight: 15% =

IA Final Score:11.25%

Tip: Credit in the Improvement Activities category is capped at 40 points or 100 percent. So, Improvement Activities can contribute toward no more than 15 percent of your final score even

if you submit more than 40 “points worth” of activities

Scoring for the IA Category – Special StatusExample

• Scenario 3: You are a clinician in a small practice (group with 15 or fewer clinicians) and complete 1 medium-weighted improvement activity for 20 of 40 points. 20 of 40 = 50% of available points for Improvement Activities.

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IA Score: 50%

IA Weight: 15% =

IA Final Score:7.5%

Tip: Credit in the Improvement Activities category is capped at 40 points or 100 percent. So, Improvement Activities can contribute toward no more than 15 percent of your final score even

if you submit more than 40 “points worth” of activities

IMPROVEMENT ACTIVITIESData Submission

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Improvement Activities in 2019Data Submission Types

New for 2019

• Beginning with the 2019 MIPS performance year, MIPS eligible clinicians, groups, and virtual groups may submit improvement activities data using multiple data submission types provided that the individual clinician/group/virtual group uses the same and constant identifier(s) for all performance categories and all data submissions.

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Improvement Activities in 2019Data Submission Types

Improvement Activities performance category data can be submitted using the following submission types:

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Submission Type Description

Direct

Individuals, clinicians, groups, virtual groups, and third-party intermediaries can perform a direct submission, transmitting data through a computer-to-computer interaction, such as an Application Programming Interface (API). A third-party intermediary is an entity that has been approved to submit data on behalf of a MIPS eligible clinician, group, or virtual group for one or more of the Quality, Improvement Activities, and Promoting Interoperability performance categories - such intermediaries can be a qualified registry, a qualified clinical data registry (QCDR), a health IT vendor or other authorized third party that obtains data from a MIPS eligible clinician's CEHRT, or a CMS-approved survey vendor.

Log-in and UploadAllows individual clinicians, groups, virtual groups, and third-party intermediaries to upload and submit data in the form and manner specified by CMS with a set of authenticated credentials. Currently, this occurs on qpp.cms.gov.

Log-in and Attest

Individual clinicians, groups, third-party intermediaries, and virtual groups with a set of authenticated credentials can log in and manually attest to their improvement activities data on qpp.cms.gov.

For each improvement activity that is performed for at least a continuous 90 days during the performance year, individuals, groups, and/or virtual groups using the “log in and attest” submission mechanism must attest to the improvement activity by submitting a “yes” response for each of these improvement activities within the Improvement Activities Inventory.

Groups and virtual groups can attest to an improvement activity if at least one clinician in the group or virtual group participated in the improvement activity for a continuous 90 days during the performance year.

Improvement Activities in 2019Data Submission Requirements

How to Attest

• You attest by answering “Yes” to each improvement activity that meets the 90-day requirement (ongoing activities performed for at least 90 consecutive days during the 2019 performance year)

• If you’re in a group or virtual group, you can attest to an improvement activity as long as one clinician in your group or virtual group participated in the activity for at least 90 continuous days during the performance year

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For more information on data validation, you can view our fact sheet:2019 MIPS Data Validation Criteria

Improvement Activities in 2019Data Submission Requirements

Qualified Clinical Registry Data (QCDR) Improvement Activities:

• To receive credit for these improvement activities, you must perform the improvement activity for a minimum of a continuous 90-day period and attest to the improvement activity during the submission period if using the “login and attest” submission mechanism

OR

• Have the QCDR submit the specific improvement activities on your behalf

• Simply participating with a QCDR and having them submit data for the Quality or Promoting Interoperability performance categories does not satisfy any requirements for the Improvement Activities performance category

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QUALITY PAYMENT PROGRAMResources, Help & Support

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Technical Assistance

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Help and Support

CMS has no cost resources and organizations on the ground to provide help to eligible clinicians included in the Quality Payment Program:

To learn more, visit https://qpp.cms.gov/about/help-and-support.

Improvement Activities in 2019Annual Call for Improvement Activities

• Each year we hold an “Annual Call for Improvement Activities” where stakeholders—including clinicians, professional organizations, researchers, consumer groups, and others—can identify and submit new improvement activities or modifications to an improvement activity for consideration in future years of MIPS

• Improvement activity nominations submitted between February 1, 2019 and July 1, 2019 are considered for the calendar year 2020 rulemaking cycle for possible implementation starting in calendar year 2021

• Submissions received after the July 1, 2019 deadline are considered for future years. For more information, review the 2019 Call for Measures and Activities resources (zip)

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NOTE: Proposing a new improvement activity is completely voluntary and not a requirement of participation.

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Improvement Activities Performance CategoryResources

To learn more about the Improvement Activities performance category:

View the following web pages on QPP.CMS.GOV:

• Improvement Activities Webpage

Download the following resources in the Resource Library:

• 2019 Improvement Activities Fact Sheet

• 2019 List of Improvement Activities

• 2019 Call for Measures and Activities

Q&A SESSION

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Q&A Session

• To ask a question, please submit it to the Q&A box.

• Speakers will answer as many questions as time allows.

• Ask most important questions first.

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