© 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