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QUALITY PAYMENT PROGRAM SMALL UNDERSERVED RURAL SUPPORT (QPP SURS) WEBINARFEBRUARY 20, 7:00 PM ET AND FEBRUARY 22, 11:00 AM ET
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IMPLICATIONS OF THE 2018 FINAL RULE FOR SOLO PRACTITIONERS AND SMALL GROUP PRACTICES
IMPLICATIONS OF THE 2018 FINAL RULE
HOUSEKEEPING ANNOUNCEMENTS
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If you are listening to this webinar through your computer, please remember to unmute your computer speakers.
For assistance, enter your issue in the chat box.
To ask a question, enter your inquiry in the chat box.
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IMPLICATIONS OF THE 2018 FINAL RULE
POLLING QUESTIONWhat is your role?▸
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A clinician working in a practice with 15 or fewer clinicians
Non clinical staff from a practice with 15 or fewer clinicians
A clinician working in a practice with more than 15 clinicians
Non clinical staff in a practice with more than 15 clinicians
Quality Payment Program contractor
Other person helping practices prepare for MIPS
Other
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POLLING QUESTIONWhat describes your progress in using the CMS platform for submitting data? ▸
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Considering using it but no EIDM account or use yet
I have an EIDM account but haven’t accessed the site yet
Accessed the site but haven’t finished yet
Think I’m done but want to make sure I’ve done it right
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IMPLICATIONS OF THE 2018 FINAL RULE
CMS WELCOME
Brenda Gentles, RN, BS, MS
Division of ESRD, Population & Community Health
Centers for Medicare & Medicaid Services
QPP SURS Central Support Contractor COR
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IMPLICATIONS OF THE 2018 FINAL RULE
Robert Mencunas, Senior Program Coordinator. Healthcentric Advisors
Bruce Spurlock, MDPresident & CEO,Cynosure Health
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Adam Richards, Division of ESRD, Population and
Community Health Centers for Medicare &
Medicaid Services
Roger D. Wells, PAHoward County Medical Center
St. Paul, Nebraska
IMPLICATIONS OF THE 2018 FINAL RULE
SETTING THE STAGE▸
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Focus: To understand how the 2018 Final Rule impacts small practices
Strategy: Focus on aspects with largest potential affect on small practices
Not an exhaustive summary of the entire 2018 Final Rule https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/QPP-Year-2-Final-Rule-Fact-Sheet.pdf
Topic Overview: Resources for free support and answers to your questions
Overview of what has not changed
Summary of most important changes in the 2018 Rule for small group practices
Using the Chat Box
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IMPLICATIONS OF THE 2018 FINAL RULE
RESOURCES FOR FREE SUPPORT8
Small, Underserved & Rural Direct Support Organizations (DSO)
Free technical assistance and advice available for small practices from CMS-funded DSOs. Contact information for each DSO at: https://qpp.cms.gov/docs/QPP_Support_for_Small_Practices.pdf
• General information about QPP for eligible clinicians participating in MIPS or Advanced APMs: https://qpp.cms.gov/
• Questions to CMS about Quality Payment Program:[email protected]
• Sources of support for larger practices and APM participants described in: https://qpp.cms.gov/docs/QPP_Technical_Assistance_Resource_Guide.pdf
QUESTION:
There was a 2017 Final Rule. So what remains the same between the 2017 and 2018 Final Rules?
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IMPLICATIONS OF THE 2018 FINAL RULE
UNDERSTANDING THE 2018 FINAL RULE: WHAT HAS NOT CHANGED▸ Keeping many of the flexibilities from the transition year
No change in the types of clinicians eligible to participate
No change in non-patient facing criteria
Continue to use 2014 certified EHR technology
Continuing to award small practices 3 points for measures in the Quality performance category that don’t meet data completeness requirements
Submission methods have not changed
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IMPLICATIONS OF THE 2018 FINAL RULE
MISCONCEPTIONS OF THE FINAL RULE
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Performance scoring for Improvement activities and Advancing Care Information has not changed.
Continued flexibility for small practices.
Data Submission methods have stayed the same.
ACI exclusions for HIE (Health Information Exchange) and ePrescribing are still intact if you do less than 100 ePrescriptions or referrals for that time period.
Scoring targets are continuously moving.
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QUESTION:
What has changed for Year 2?
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OVERVIEW OF WHAT HAS CHANGED▸
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No Pick Your Pace
Low Volume Threshold
Performance Category Changes
Quality Measures
Improvement Activity (IA)
Advancing Care Information (ACI)
Cost category
Performance Threshold and Payment Adjustments
Reporting options
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IMPLICATIONS OF THE 2018 FINAL RULE
LOW VOLUME THRESHOLD INCREASE
▸ Low-Volume Threshold has increased.
MIPS-eligible clinicians billing more than $90,000 a year in Medicare Part B allowed charges AND providing care for more than 200 Medicare patients a year.
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IMPLICATIONS OF THE 2018 FINAL RULE
ADVICE FOR CLINICIANS THAT MAY BE EXEMPT DUE TO LOW-VOLUME THRESHOLD▸
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Still can voluntarily report and may be eligible again in future years
Meeting MIPS requirements prepares you for the future
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QUESTION:
How have Quality Measure reporting requirements changed?
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IMPLICATIONS OF THE 2018 FINAL RULE
OVERVIEW OF CHANGES TO QUALITY MEASURES▸
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50% of Final Score in 2018
12 months minimum reporting period
270+ measures available
You select 6 individual measures
1 must be an Outcome measure OR
High-priority measure
You may also select a specialty-specific set of measures
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IMPLICATIONS OF THE 2018 FINAL RULE
MIPS SCORING IMPROVEMENT FOR QUALITY
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Improvement scoring will be based on the rate of improvement such that higher improvement amounts result in more points for those who have not previously performed well.
Improvement will be measured at the performance category level.
Up to 10 percentage points available in the Quality performance category.
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IMPLICATIONS OF THE 2018 FINAL RULE
IMPORTANT IMPLICATIONS FOR SMALL GROUP PRACTICES:
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• Paying attention to data completeness
• More attention to your patient population and how that affects your quality measures
QUESTION:
▸How have Improvement Activities and ACI requirements changed?
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IMPLICATIONS OF THE 2018 FINAL RULE
IA AND ACI CHANGESNo changes to Improvement Activity Scoring.
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ACI is 25% of Final Score in 2018.
Promotes patient engagement and the electronic exchange of information using certified EHR technology.
Two measure sets available to choose from based on EHR edition.
Burden Reduction Aim: MIPS eligible clinicians may use either the 2014 or 2015 CEHRT or a combination in 2018.
A 10% bonus is available for using only 2015 Edition CEHRT.
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IMPLICATIONS OF THE 2018 FINAL RULE
ACI CHANGES▸
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For the performance score, MIPS-eligible clinicians and groups will earn 10% for reporting to any one of the Public Health and Clinical Data Registry Reporting measures as part of the performance score.
For the bonus score a 5% bonus score is available for reporting to an additional registry not reported under the performance score.
Additional Improvement Activities are eligible for a 10% Advancing Care Information bonus for completion of at least 1 of the specified Improvement Activities using CEHRT.
Total bonus score available is 25%
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IMPLICATIONS OF THE 2018 FINAL RULE
ACI CHANGES: HARDSHIP EXCEPTIONS▸
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Reweight the ACI performance category to 0 and reallocate the performance category weight of 25% to the Quality performance category.
Automatic reweighting for special status.
Ambulatory Surgical Center (ASC)— based MIPS eligible clinicians, finalized retroactive to the transition year (NEW).
New hardship exception for clinicians in small practices.
New decertification exception for eligible clinicians whose EHR was decertified, retroactively effective to performance periods in 2017.
Significant hardship exceptions—CMS will not apply a 5-year limit to these exceptions.
New deadline of December 31 of the performance year for the submission of hardship exception applications for 2017 and future years.
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HOW ACI CHANGES MAY IMPACT SMALL GROUP PRACTICES▸
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Eligible clinicians will have more flexibility and the opportunity to request for hardship exceptions.
Invest in a Certified EHR, join a practice with an EHR or affiliate with an ACO.
Explore feasibility of registry participation.
If no EHR, reach out to billing company or if you do it in-house to find measures to use and pull out “non” billable codes to send via claims.
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QUESTION:
▸What is the cost category and how will it affect your 2018 MIPS scoring?
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IMPLICATIONS OF THE 2018 FINAL RULE
COST CATEGORY
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10% of MIPS Score in 2018.
Two measures are averaged to produce cost score:
Medicare Spending per Beneficiary (MSPB)
Total per capita cost measures
If only one measure can be calculated, the score on that measure will be the cost score.
12 Months minimum performance period—scores based on comparisons with scores of other clinicians and groups during the same period.
Cost score calculated by CMS using claims data so no additional reporting required.
10 episode-based measures adopted for the 2017 MIPS performance period will not be used.
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IMPLICATIONS OF THE 2018 FINAL RULE
COST CATEGORY: WHAT THIS MEANS TO YOU▸
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Awareness of containing costsTo learn more about Cost March LAN WebinarReview QRUR report here: https://portal.cms.gov/wps/portal/unauthportal/home/Cost category remains at 10%, but still matters
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QUESTION:
▸What other changes will affect scoring?
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IMPLICATIONS OF THE 2018 FINAL RULE
▸ Increase to 15 points
Report all required Improvement Activities.
Meet the ACI base score and submit 1 Quality measure that meets data completeness.
Meet the ACI base score, by reporting the 5 base measures, and submit one medium-weighted Improvement Activity.
Submit 6 Quality measures that meet data completeness criteria.
PERFORMANCE THRESHOLD INCREASE29
IMPLICATIONS OF THE 2018 FINAL RULE
PAYMENT ADJUSTMENT INCREASE30
IMPLICATIONS OF THE 2018 FINAL RULE
SMALL PRACTICE BONUS31
▸ 5 bonus points added to final score of any MIPS eligible clinician or group who is in a small practice, so long as the MIPS eligible clinician or group submits data on at least 1 performance category in an applicable performance period.
▸ Up to 5 bonus points available for treating complex patients based on medical complexity.
▸ Burden Reduction Aim: We recognize the challenges of small practices and will provide a 5 point bonus to help them successfully meet MIPS requirements.
IMPLICATIONS OF THE 2018 FINAL RULE
EXTREME AND UNCONTROLLABLE CIRCUMSTANCES IN YEAR 2 (2018)▸
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The Final Rule with Comment Period for Year 2 extends the Transition Year hardship exception reweighting policy for the Advancing Care Information performance category to now include Quality, Cost, and Improvement Activities.
This policy applies to all of the 2018 MIPS performance categories.
A hardship exception application is required.
The hardship exception application deadline is December 31, 2018.
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IMPLICATIONS OF THE 2018 FINAL RULE
IMPLICATIONS FOR SMALL GROUP PRACTICES33
▸ Strategies for getting the small practice bonus points
▸ Hardship exemption pros and cons
QUESTION:
▸Are there any changes to the options we have for reporting our data?
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IMPLICATIONS OF THE 2018 FINAL RULE
MIPS YEAR 2 REPORTING OPTIONS35
IMPLICATIONS OF THE 2018 FINAL RULE
SUBMISSION METHODS HAVE NOT CHANGED36
QUESTION:
▸What final advice can you give to small practices for how to succeed in 2018?
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IMPLICATIONS OF THE 2018 FINAL RULE
PRACTICAL ADVICE TO SUCCEED IN 201838
▸ Start now; activities need to be performed for entire year
▸ Ask for help from your DSO, particularly for ACI and Cost scoring planning
▸ Take advantage of the free help
▸ Dive into your data
▸ Look to the future (ACO, APM?)
FREE RESOURCES FOR ASSISTANCE FROM CMS▸
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QPP website: https://qpp.cms.gov/--includes information tailored for the needs of small practices https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-Events.html
Contact the Quality Payment Program at: [email protected] or call 1-866-288-8292
Support and Available resources for Small, Underserved, and Rural Practices: https://qualitypaymentprogram.cms.gov/about/small-underserved-rural-practices
Small Underserved Rural Support Direct Support Organizations (see list on slide 8)
Contact information is available at: https://qpp.cms.gov/docs/QPP_Support_for_Small_Practices.pdf
Available websites of each Direct Support Organization
Types of help: needs assessments, webinars, technical support, links to peers you can talk with, assistance getting signed up to report through an approved channel that meets your practice’s needs
FREE Technical Assistance funded by CMS is also available for larger group practices and for clinicians interested in participating in an Alternative Payment Model. More information on those programs is available at: https://qpp.cms.gov/docs/QPP_Technical_Assistance_Resource_Guide.pdf
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FREE RESOURCES FOR ASSISTANCE FROM CMS▸
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Benefits of Electronic Health Records Year 2 Overview Fact SheetFinal Rule Executive SummaryData Submission fact sheetCMS Data Submission instructional videos : Merit-based Incentive Payment System (MIPS) Data Submission
Advancing Care Information (ACI) Data Submission for Alternative Payment Models (APMs)
Data Submission via a Qualified Clinical Data Registry and Qualified Registry
Other national webinars focused on small practicesOther national events about Quality Payment Program
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POLLING QUESTIONWhat do you think will be your biggest challenges in adjusting to changes in the 2018 Final Rule?
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WRAP-UP ACTIVITIES▸ Reminders:
The deadline to submit 2017 data via the QPP portal is March 31, 2018.
The deadline to submit 2017 via claims is March 1, 2018.
Annual Call for Measures and Activities for MIPS
Information available here
▸ Study on Burdens Associated with Reporting Quality Measures to Receive Improvement Activity Credit for 2018. Apply here
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Links to the recordings of the event are available here: https://qppsurs.wordpress.com/resources/
March: How to Prepare for MIPS Cost Scoring
March 20, 2018 at 11:00am ET: Register
March 22, 2018 AT 7:00pm ET Register
▸ Please provide feedback on this event: Feedback Form
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REFERENCESSome of the materials contained in these slides is drawn from:
https://www.cms.gov/Medicare/Quality.../QPP-Year-2-Final-Rule-NPC-Slides.pdf
http://www.healthcarefornewengland.org/event/qpp_year2_mha/
Slide decks created by event panelists also provided information reflected in this presentation. The input from project panelists is gratefully acknowledged.
Other documents on the https://qpp.cms.gov/ and https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html website provide additional detail about the MIPS program.
Disclaimer: This presentation was current at the time it was published or uploaded onto the web. Medicare policy changes periodically so links to the source documents have been provided within the document for your reference. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.
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