Scott Hughes, DPM, ASPS, ACFAS › resources › Documents › 2018 Prese… · 2018 MIPS Quality...
Transcript of Scott Hughes, DPM, ASPS, ACFAS › resources › Documents › 2018 Prese… · 2018 MIPS Quality...
Scott Hughes, DPM, ASPS, ACFAS
Webinar Topic Date
2018 Improvement Activities Performance Category June 19, 2018
2018 MIPS Overview May 23, 2018
2018 MIPS Quality Category May 2, 2018
2018 MIPS Cost Performance Category April 25, 2018
How to Avoid a 2020 Penalty for 2018 MIPS Reporting February 12, 2018
MIPS Year 2 Final Rule November 30, 2017
Registry Reporting October 30, 2017
MACRA Made Easy Webinar Series on MIPS Year 2
All past webinars and materials are posted online:
www.apma.org/MACRAWebinars
SENATE VOTE IN FAVOR OF
MACRA
92-8
HOUSE VOTE IN FAVOR OF
MACRA
392-37
Highest total of 100
EPs will receive either a positive or negative
payment adjustment to Medicare part B fee
schedule based on MIPS score
MIPS Score
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
0 MIPS points = -4%
3 MIPS points = Neutral
15 MIPS points = +0.05%
40 MIPS points = +0.16%
94 MIPS points = +1.9%
100 MIPS points = +2.02%
2017 MIPS Points And Adjustments
Fact Sheet: 2019 Merit-based Incentive Payment System (MIPS) Payment Adjustments based on 2017 MIPS Final Scores : https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-MIPS-Payment-Adjustment-fact-sheet.pdf
2017 Results
2018 Final Rule
Threshold to avoid a penalty moves
from 3 MIPS points to 15 MIPS points
Mostly budget neutral
Penalty no more than 5%
Most positive adjustments no more than 5%
…positive moved based on budget neutrality
“Exceptional Performance” (70)
MIPS 2018
Physician Compare
https://www.medicare.gov/physiciancompare/#
Yelp ?
Employers ?
Private Insurance Carriers ?
Scores Will Be Publically Reported
2018 Final Rule
Exclusion Criteria
Less than or equal to $90K in Medicare
Part B allowable
OR
Less than or equal to 200 Medicare Part B
beneficiaries
https://qpp.cms.gov/participation-
lookup
https://qpp.cms.gov/participation-
lookup
Other Exclusions Still Exist
Newly Medicare-enrolled eligible
clinicians
Qualifying APM Participants (QPs)
Certain Partial Qualifying APM
Participants (Partial QPs)
Clinicians affected by Harvey,
Irma, Maria can file a hardship
exemption for 2018 reporting
period for Quality, ACI, and CPIA
2018 Final Rule
https://cmsqualitysupport.service-
now.com/exception_application.do
2018 Final Rule Category Weights
Quality – 50%
PI (ACI) – 25%
CPIA – 15%
Cost – 10%
Quality 50%
PI (ACI) 25%
Clinical PracticeImprovement Activities15%
Cost 10%
MIPS Score Performance Year 2018
If practice has greater than 15 eligible clinicians
2018 Final Rule Option
PI (ACI) exception for practices
with 15 or fewer clinicians!!
Re-weights Quality to 75%
Quality – 75%
PI (ACI) – Exception!
CPIA – 15%
Cost – 10%
2018 Final Rule Category Weights With PI Exception
Quality 75%
PI (ACI) 0%
Clinical PracticeImprovement Activities15%
Cost 10%
MIPS Score Performance Year 2018*
* With PI Exception
5 MIPS points added to final score of any EP or group who is in a small practice (15 or fewer clinicians)
EP or group must submit data on at least 1 performance category.
New Small Practice Bonus for 2018
Quality – 50% or 75%
Report 6 Quality measures
One must be an outcome measure
If outcome measure not available, must report on at
least one high priority measure
All 6 must be reported by the same mechanism
MIPS Quality (50% or 75%)
Claims
60% or more of Medicare Part B patients
Registry
60% or more of all patients
EHR
60% or more of all patients
CMS Web Interface (groups of 25+)
ALL SIX MUST BE SUBMITTED BY SAME MECHANISM
2018 Quality Measures Submission Methods
QPP.CMS.GOV
QPP.CMS.GOVQPP.CMS.GOV
QPP.CMS.GOVQPP.CMS.GOV
Claims
Registry
EHR
CMS Web Interface (groups of 25+)
ALL SIX MUST BE SUBMITTED BY SAME MECHANISM
Quality Measures Submission Methods
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
9. Falls Risk Assessment
10. Falls Plan of Care
QUALITY MEASURES
Claims Reporting
1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control - Intermediate Outcome
2. Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam
3. Diabetic Foot and Ankle Care, Ulcer Prevention –Examination of Footwear
4. Documentation of Current Meds in the Medical Record
5. Immunizations for Adolescents
QUALITY MEASURES
Registry Reporting
7. Pain Assessment and Follow-Up
8. Pneumococcal Vaccination Status for Older Adults
9. Preventive Care & Screening: Body Mass Index (BMI) Screening & Follow-Up Plan
10. Preventive Care and Screening: Influenza Immunization
11. Screening for High Blood Pressure and Follow Up
12. Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
13. Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling
14. Falls Risk Assessment
15. Falls Plan of Care
\
QUALITY MEASURES
Registry Reporting cont.
APMA.ORG/MIPS2018
Denominator – 18 or older, E&M
Claims - Documentation of Current Medications in the Medical Record
Numerator –
Performance Met: G8427 - Eligible clinician attests
to documenting in the medical record they
obtained, updated, or reviewed the patient’s
current medications
Performance Not Met: G8428 - Current list of medications
not documented as obtained, updated, or reviewed by
the eligible clinician, reason not given
Claims - Documentation of Current Medications in the Medical Record
Promoting Interoperability
(Advancing Care Information) (25%)
50% credit just for reporting
Other 50% depends on performance
No more clinical decision support rule
No more CPOE (Computerized Provider Order
Entry)
Promoting Interoperability (25%)
QPP.CMS.GOVQPP.CMS.GOV
Two Reporting Options
2014 CEHRT Only
4 required base
measures
7 additional optional
performance measures
2015 CEHRT Only
OR
2014 + 2015 CEHRT
5 required base measures
10 additional optional performance measures
Additional 10 bonus pointsfor using 2015 edition certified EHR exclusively
4 Required PI Measures - 2014 CEHRT Only
1. Security Risk Analysis
2. e-Prescribing
3. Provide Patient Access
4. Health Information Exchange
7 Additional Optional PI Measures
2014 CEHRT only
1. View, Download, or Transmit (VDT)
2. Patient-Specific Education
3. Secure Messaging
4. Medication Reconciliation
5. Immunization Registry Reporting
6. Specialized Registry Reporting
7. Syndromic Surveillance Reporting
1. Security Risk Analysis
2. e-Prescribing
3. Provide Patient Access
4. Send a Summary of Care
5. Request/Accept Summary Care
5 Required PI Measures – 2015 CEHRT or Combo
1. Patient Specific Education
2. View, Download or Transmit (VDT)
3. Secure Messaging
4. Patient-Generated Health Data
5. Clinical Information Reconciliation
6. Immunization Registry Reporting
7. Clinical Data Registry Reporting
8. Syndromic Surveillance Reporting
9. Electronic Case Reporting
10. Public Health Registry Reporting
10 Additional Optional PI Measures2015 CEHRT only or Combo
Clinical Practice Improvement Activities
(15%)
List of 93 options
Medium weight = 10 points
High weight = 20 points
Activities double weighted if group of 15 or less or solo
Score = points / 40
Clinical Practice Improvement Activities (15%)
Group of more than 15 clinicians:
Choose 4 medium weight or 2 high weight
activities or 1 high weight + 2 medium weight
Group of 15 or fewer clinicians or solo:
Choose 2 medium weight or 1 high weight
activity(s)
Clinical Practice Improvement Activities (15%)
QPP.CMS.GOVQPP.CMS.GOV
QPP.CMS.GOVQPP.CMS.GOV
1. Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real- Time
Access to Patient's Medical Record HIGH
2. Use of a QCDR to generate regular feedback reports that summarize local
practice patterns and treatment outcomes, including for vulnerable populations.
HIGH
3. Implementation of Use of Specialist Reports Back to Referring Clinician or Group
to Close Referral Loop MEDIUM
4. Implementation of improvements that contribute to more timely communication of
test results MEDIUM
5. Collection and follow-up on patient experience and satisfaction data on
beneficiary engagement HIGH
6. Participation in a QCDR, that promotes implementation of patient self-action
plans. MEDIUM
Clinical Practice Improvement Activities (15%)
7. Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms. MEDIUM
8. Improved Practices that Disseminate Appropriate Self-Management Materials MEDIUM
7. Annual registration in the Prescription Drug Monitoring Program MEDIUM
8. Consultation of the Prescription Drug Monitoring Program HIGH
9. Use of decision support and standardized treatment protocols MEDIUM
Clinical Practice Improvement Activities Cont. (15%)
12. Implementation of fall screening and assessment programs MEDIUM
13. CDC Training on CDC’s Guideline for Prescribing Opioids for Chronic Pain HIGH
12. Completion of CDC Training on Antibiotic Stewardship HIGH
13. Initiate CDC Training on Antibiotic Stewardship MEDIUM
14. Engagement of New Medicaid Patients and Follow-up HIGH
Clinical Practice Improvement Activities Cont. (15%)
Cost Category 10%
Cost calculated by:
Medicare Spending per Beneficiary (MSPB)
and
Total Per Capita Cost Measures (TPCC)
2018 Final Rule
Cost
Total Per Capital Cost (TPCC)
Total Cost per Beneficiary
Payment standardized
Annualized
Risk adjusted
Specialty adjusted
Medicare Spending Per Benificiary
(MSPB)
Minimum Cases
2018 Final Rule Reporting Periods
Quality: 365 days
PI (ACI): 90 days
CPIA: 90 days
Cost: 365 days
Proposed for 2019
Meet ONE of these:
o ≤ $90K in Part B allowable
o Provide care to ≤ Part B 200 beneficiaries
o Provide ≤ 200 Part B services
However, option to opt in if you only meet one or two
of those
2019 Proposed Low Volume Threshold
-7% to +7%
2021 Adjustment Based on 2019 Performance
Threshold to avoid a penalty moves from 15 to 30
Exceptional Performer threshold moves from 70 to 80
2019 Proposed Thresholds
Quality: 45% (down from 50%)
Cost: 15% (up from 10%)
Promoting Interoperability: 25% (no change)
Improvement Activities: 15% (no change)
Proposed 2019 Category Weights
If you only submit on one category
max MIPS score is 30
2019 Proposed QPP Proposed Rule
Remains 6 measures
One must be an outcome measure
If outcome measure not available, must report on at least
one high priority measure
60% of applicable patients throughout performance
year
Quality Category – 2019 Proposed
Different quality measures can be
reported via different mechanisms
Can submit a single quality measure via
multiple mechanisms – get the higher score
Quality Category – 2019 Proposed
Quality measures proposed for removal in 2019:
◼163: Comprehensive Diabetes Care: Foot Exam
◼154: Falls: Risk Assessment
◼155: Falls: Plan of Care
◼318: Falls: Screening for Future Fall Risk
(CMS proposes to replace these 3 falls measures with a new combined Falls measure)
Quality Category – 2019 Proposed
Limit claims-based reporting to
clinicians in small practices (< 15
eligible clinicians)
Quality Category – 2019 Proposed
Must use 2015 CEHRT
Elimination of base, performance, and bonus
scoring
Just numerator / denominator or Yes/No
PI Category – 2019 Proposed
CMS proposes to no longer apply a small
practice bonus to the final score, but
rather add a small practice bonus to the
quality performance category.
2019 Proposed QPP Proposed Rule
CMS estimates that 95.1 percent of
MIPS eligible clinicians will
participate in MIPS in 2019
2019 Proposed QPP Proposed Rule
COMING SOONAPMA MyMipsScore APP
An Analytic Tool to Maximize Your
MIPS Score
APMA is negotiating this as a member benefit
available to all APMA members
Analytics of the tool allow you to evaluate your
progress on MIPS Measures, maximize your
performance thus increasing your MIPS score and
therefore earn a your maximum incentive
Lets you simulate an increase in your performance
on a measure to see effect on MIPS score and
incentive payment
Additional Bonus Feature
Allows any APMA member to submit their
MIPS data to the APMA Registry even if
your EHR has not integrated with the
APMA Registry