MIPS Today: 101 and 102

Seema Rathor and Christopher WellsPractice Facilitators, HealthInsight Oregon

Poll: Who Is in the Room?

• Please stand when I mention your category:– Primary care provider– Administrator/manager for outpatient office– Clinician or representative of a non-outpatient

office, other setting of care (e.g., hospital, LTPAC, home health)

– Community stakeholder: Patient/family/advocate; state or local government; health department or health district; community program; other

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What You Will Learn Today

• How you can still participate in MIPS—it’s not too late!

• How to select and report quality measures to increase your MIPS score

• Top-down, bottom-up approaches to roles and responsibilities in quality improvement and reporting

• Real-world scenarios of role management, experienced through an empathetic learning session

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Medicare Access and CHIP Reauthorization Act of 2015

The intent of MACRA is fourfold:1. Repearls Sustainable Growth Rate (SGR)

2. Improves care for Medicare beneficiaries

3. Reauthorizes the Children’s Health Insurance Program (CHIP)

4. Changes our physician payment system from focus on quantity of services to quality of care

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MACRA = Quality Payment Program

• MACRA is being implemented as the Quality Payment Program (QPP)

• The QPP encompasses two pathways:

The Merit-based Incentive

Payment System (MIPS)

orAdvanced

Alternative Payment Models

(APMs)

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What Is MIPS?

• Moves Medicare Part B clinicians to a performance-based payment system

• Provides clinicians with flexibility to choose the activities and measures that are most meaningful to their practices

• Reporting standards align with Advance APMs wherever possible 6

2017 2018 2019

Quality decreases 60% 50% 30%

Cost increases 0% 10% 30%

Advancing Care Information 25% 25% 25%

Improvement Activities 15% 15% 15%

Merit-based Incentive Payments

MIPS BreakdownA physician’s MIPS composite score, which determines future payment adjustments, is calculated through a changing ratio of four key categories of information each year.

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Ways to Check Eligibility

• QPP Website • Letter• Non-patient-facing providers (calculator)

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MIPS Eligible Clinicians

Medicare Part B clinicians billing more than $30,000 a year AND providing care for

more than 100 Medicare patients a

year.

Physicians Physician AssistantsNurse

PractitionerClinical Nurse

Specialist

Certified Registered

Nurse Anesthetists

Quick Tip:Physician means doctor of medicine, doctor of osteopathy (including osteopathic practitioner), doctor of dental surgery, doctor of dental medicine, doctor of podiatric medicine, or doctor of optometry, and, with respect to certain specified treatment, a doctor of chiropractic legally authorized to practice by a State in which he/she performs this function.

These clinicians include:

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Who Is Excluded from MIPS?

Below the low-volume threshold• Medicare Part B

allowed charges less than or equal to $30,000 a year

OR• See 100 or fewer

Medicare Part B patients a year

Newly enrolled in Medicare

• Enrolled in Medicare for the first time during the performance period (exempt until following performance year)

Significantly participating in Advanced APMs

• Receive 25% of your Medicare payments

OR• See 20% of your

Medicare patients through an Advanced APM

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Participation for Clinicians in Specific Facilities

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Participation for Clinicians in Specific Facilities

Hospital-based Clinicians• Clinicians are considered hospital-based if they provide

75% or more of their services in an– Inpatient Hospital;– On-campus Outpatient Hospital; or– Emergency Room.

• Hospital-based clinicians are subject to MIPS if they exceed the low volume threshold and should report the Quality and Improvement Activities performance categories.

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Participate in an Advanced Alternative

Payment Model

• Some practices may choose to participate in an Advanced Alternative Payment Model in 2017

MIPS: Test Pace

• Submit somedata after January 1, 2017

• Avoid negative payment adjustment

Pick Your Pace in 2017 (Transition Year)

MIPS: Partial Year

• Report for 90-day period after January 1, 2017

• Small positive payment adjustment

MIPS: Full Year

• Fully participate starting January 1, 2017

• Modest positive payment adjustment

Not participating in the Quality Payment Program for the transition year will result in a negative 4% payment adjustment.

Individual OR Group Reporting

• No registration required for group reporting

• Groups have the option to report at the individual (NPI) or group (TIN/NPI) level

• Advantage of group /individual reporting

• Groups may use only one submission mechanism per performance category

• Groups can report, or submit data, using different submission mechanisms for each performance category

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Submission Methods for MIPS

Category Individual Group

Quality

• Qualified Clinical Data Registry (QCDR)

• Qualified Registry• EHR• Claims

• QCDR• Qualified Registry• EHR• Administrative Claims• CMS Web Interface• CAHPS for MIPS Survey

Improvement Activities

• QCDR• Qualified Registry• EHR• Attestation

• QCDR• Qualified Registry• EHR• CMS Web Interface• Attestation

Advancing Care Information

• QCDR• Qualified Registry• EHR• Attestation

• QCDR• Qualified Registry• EHR• CMS Web Interface• Attestation

Cost • No submission required• CMS will use claims data• No submission required• CMS will use claims data16

Getting Your Data to CMS

• Advantages and disadvantages of each method of submission– Registry– EHR– Claims

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MIPS Scoring

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Quality 60%Advancing

Care Information

25%

Improvement Activities 15%

2017

MIPS:Quality Measures

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Select Quality Measures

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Example 1:

• 6 Measures• 1 Outcome• 5 Process

No Bonus Points

Example 2:

• 6 Measures• 2 Outcome• 4 Process

2 Bonus Points

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Examples of Bonus Points

Example 3:

• 6 Measures• 4 Outcome• 2 Process

6 Bonus Points

1 bonus point for additional high-priority measure

Requirements for Scoring

• Sufficient case volume (20 cases for most measures) in a benchmarked quality measure

• Data completeness is met• Example

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Strategies for Success

• Think about topped out measures• Outcome/High Priority• Measures without benchmarks• Bonus points giving you extra credit• Benchmarks • Understand formula for quality calculation• QRUR report

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Quality Example

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Quality Example

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Quality Example

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Roles and Responsibility Exercise

Role1. Provider

2. MA/Nurse

3. Biller

4. Front desk

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ResponsibilityA. Ensure clinical

data are entered

B. Track Quality Measures

C. Report Quality Measures

D. Decide on improvement strategy

MIPS Category: Advancing Care Information (ACI)

• Promotes patient engagement and the electronic exchange of information using certified EHR technology

• Replaces the Medicare EHR Incentive Program (a.k.a. Meaningful Use)

• Resource for details on Advancing Care Information:– https://qpp.cms.gov/docs/QPP_ACI_Fact_Sheet.pdf

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https://qpp.cms.gov/docs/QPP_ACI_Fact_Sheet.pdf

Some Other Facts

• Hospital must still report Meaningful Use.• Medicaid EHR incentive Program continues until 2021. • Reweighting the ACI category• Hospital-based MIPS eligible clinician types qualify for an

automatic reweighting of the Advancing Care Information performance category to zero.

• If data are submitted, CMS will score their performance and weight their ACI performance accordingly.

• If these clinicians do not submit, the 25% ACI score will be reassigned to the Quality performance category.

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ACI Base Score

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ACI Performance Score

Advancing Care Information Measures and Scores

2017 Advancing Care Information Transition Measures and Scores

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ACI Performance Score (continued)

Advancing Care Information Measures and Scores

2017 Advancing Care Information Transition Measures and Scores

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ACI Bonus Score

Advancing Care Information Measures and Scores

2017 Advancing Care Information Transition Measures and Scores

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MIPS Category: Advancing Care Information (ACI)

• State Registry and QCDR• Security Risk Analysis

– ONC Security Risk Analysis (SRA) Tool Tutorial

– Two or more providers and enrolled in OHA • OCHIN can help• Contact: Kavon Wynia—email: wyniak@ochin.org

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Advancing Care Information (ACI): Patient Portal Sign-up

Revenue Potential

Advertise Prior to Rooming

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MIPS Category: Improvement Activities

• Attest to participation in activities that improve clinical practice– Examples: Shared decision making, patient safety,

coordinating care, increasing access

• Clinicians choose from 90+ activities under 9 subcategories:

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Special Considerations

• You will automatically earn full credit if clinic is:– A participant in certified patient-centered

medical homes– A comparable specialty practice– Part of Shared Savings Program Track 1 – Participating in Oncology Care Model

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Some Facts about Improvement Activities

• Documentation to validate your activities should demonstrate consistent and meaningful engagement during attestation period.

• Eligible clinicians are encouraged to retain documentation for 6 years.

• You must attest by indicating “Yes” to each activity that meets the 90-day requirement.

• MIPS Data Validation criteria– https://qpp.cms.gov/about/resource-library

• The maximum score for full Credit for IA Category is 40 points• Points are awarded based on the weight of activity and number of

clinicians, location and if clinicians are non-patient-facing.

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18 Improvement Activities That Can Count Toward 10 Bonus Points

Provide 24/7 access to eligible clinicians or groups who have real-time access to patient’s medical record

Implementation or use of specialist reports back to referring clinician or group to close referral loop

Anticoagulant management improvements Implementation of documentation improvements for practice/process improvements

Glycemic management services Implementation of practices/processes for developing regular individual care plans

Chronic care and preventative care management for empaneled patients

Practice improvements for bilateral exchange of patient information

Implementation of methodologies for improvements in longitudinal care management for high risk patients

Use of certified EHR to capture patient reported outcomes

Implementation of episodic care management practice improvements

Implementation of medication management practice improvements

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Bonus Point Improvement Activities, Continued

Use of decision support and standardized treatment protocols

Electronic Health Record Enhancements for BH data capture

Leveraging a QCDR to standardize processes for screening

Engagement of patients through implementation of improvements in patient portal

Implementation of integrated PCBH model

Engagement of patients, family and caregivers in developing a plan of care

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MIPS Category: Cost

• For the transition year, the cost performance category will not impact payment in 2019.

• For 2018 proposed rule. Cost may be 0%.• For data submission, no action is needed from

the clinician.• Claims only.• Clinician will still get feedback report on Cost• 2019: 30% of cost

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In Summary

• For Transition Year 2017:

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Why MIPS?

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STEP 9 – SUBMIT DATA BETWEEN JANUARY 1-MARCH 31, 2018

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Exercise on Improvement Activity/Final Activity

• Implementation of methodologies for improvements in longitudinal care management for high-risk patients

• Connect this with TCM– Workflow development in small group

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CMS QPP Resources

The CMS Quality Payment Program website offers information on MIPS, including a fact sheet,

multiple slide decks, in-depth information on the four MIPs components and scoring, etc.

Website: QPP.CMS.gov

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https://qpp.cms.gov/

HealthInsight Is Ready to Help

• MACRA/QPP training and support for all MIPS providers

• Resources on Annual Wellness Visits, Chronic Care Management and Transitions of Care Management

• HIPAA Privacy and Security Solutions– Webinars, boot camps, and compliance training and

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QIN-QIO Improvement Activities

• Diabetes Self Management and Chronic Disease Self Management

• Million Hearts Coalition • Appropriate use of antibiotics with links to the

Choosing Wisely initiative• Immunizations • Depression and alcohol misuse screenings,

measurement and billing support

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Questions and More Information

HealthInsight QPP SupportCall: 866-797-6512

Email: qpp@healthinsight.orgWeb: www.healthinsight.org/qpp

This material was prepared by HealthInsight, the Medicare Quality Innovation Network-Quality Improvement Organization for Nevada, New Mexico, Oregon and Utah, 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. 11SOW-D1-17-70-OR

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mailto:qpp@healthinsight.orghttp://www.healthinsight.org/qpp

MIPS Today: 101 and 102Poll: Who Is in the Room?What You Will Learn TodayMedicare Access and CHIP Reauthorization Act of 2015 MACRA = Quality Payment ProgramWhat Is MIPS?Merit-based Incentive PaymentsSlide Number 8Ways to Check Eligibility MIPS Eligible CliniciansWho Is Excluded from MIPS?Participation for Clinicians �in Specific FacilitiesParticipation for Clinicians �in Specific FacilitiesPick Your Pace in 2017 �(Transition Year) Individual OR Group ReportingSubmission Methods for MIPSGetting Your Data to CMSMIPS ScoringMIPS:�Quality MeasuresSelect Quality MeasuresExamples of Bonus PointsRequirements for Scoring Strategies for SuccessQuality ExampleQuality ExampleQuality ExampleRoles and Responsibility ExerciseMIPS Category: �Advancing Care Information (ACI)Some Other Facts ACI Base ScoreACI Performance ScoreACI Performance Score (continued)ACI Bonus ScoreMIPS Category: �Advancing Care Information (ACI)Advancing Care Information (ACI): �Patient Portal Sign-upMIPS Category: �Improvement ActivitiesSpecial Considerations Some Facts about �Improvement Activities18 Improvement Activities That Can Count Toward 10 Bonus PointsBonus Point Improvement Activities, ContinuedMIPS Category: CostIn Summary Why MIPS?Step 9 – submit data between January 1-march 31, 2018Exercise on Improvement Activity/�Final ActivityCMS QPP ResourcesHealthInsight Is Ready to HelpQIN-QIO Improvement ActivitiesQuestions and More Information