MACRA and MIPS Preparation for your Small Group Practice...Jun 21, 2017 · MACRA and MIPS . Preparation for your Small Group Practice. Beth Hickerson. Lead Quality Improvement Advisor

MACRA and MIPS Preparation for your Small Group Practice

Beth HickersonLead Quality Improvement Advisor

June 21, 2017

Value Driven. Health Care. Solutions.

MACRA Jumpstart – Navigating the Quality Payment Program

2Value Driven. Health Care. Solutions.

There are many questions surrounding MACRA, but the bottom line is if you participate in Medicare you will be impacted by MACRA and the Quality Payment Program (QPP)

MIPS or APM? Today we’ll help you determine which track to participate in

If you’re MIPS eligible, what is your readiness level?

MACRA Jumpstart – Using Free CMS Resources for MIPS Success


At the close of our MACRA Jumpstart presentation you should have a better idea of which track to participate in and we will share free CMS Resources for MIPS support

– QPP Resource Center– www.qppresourcecenter.com

– Medical Advantage Group’s MACRA Jumpstart– www.medicaladvantagegroup.com/macra

jumpstart/– [email protected]

http://www.qppresourcecenter.com/

http://www.medicaladvantagegroup.com/macrajumpstart/

mailto:[email protected]

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)


Repealed the Sustainable Growth Rate (SGR) methodology– Supported by organized medicine– Passed with over 90 percent

support in both the House and Senate; bi-partisan legislation

Created Quality Payment Program which moves Medicare into value-based payments– Alternative Payment Model (APM)– Merit-based Incentive Payment

System (MIPS)

Quality Payment Program (QPP)

January 1, 2017 – physicians enter the MIPS track or the APM trackFor the first few years of the QPP, majority of clinicians in MIPS


Quality Payment Program (QPP)

Merit-based Incentive Payment System (MIPS)

Alternative Payment Model (APM)

Advanced APM MIPS APM

ALTERNATIVE PAYMENT MODELS (APMS)

What are APMs?

Payment approach that incentivizes clinicians to provide high-quality, cost-effective careStructured models that promote coordination and cooperation among providersFull list of 2017 APMs at https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf


https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf

APM vs Advanced APM

Alternative Payment Model – Participation requirements

unique to each APM model– Participants must still

report MIPS, but have a modified scoring system that takes their APM activities into account

Advanced Alternative Payment Model (AAPM)– More stringent participation

requirements, usually involve some level of risk

– Qualifying Participants (QPs) are exempt from MIPS and receive 0.5% bonus payment

– Partial Qualifying Participants (Partial QPs) can opt out of MIPS without penalty


2017 Advanced APMs


MSSP Track 2 MSSP Track 3Comprehensive

Primary Care Plus (CPC+)

Next Generation ACO

Comprehensive ESRD Care Model

Oncology Care Model-Two sided

QPs and Partial QPs for AAPMs

Qualifying Participants (QPs)– Exempt from MIPS– Earn an annual lump sum payment of 5 percent of the MPFS

from 2019-2024CMS predicts that approximately 100% of eligible clinicians in Advanced APMs will be QPs in performance year 2017


Performance Year 2017 2018 2019 2020 2021 2022 and later

Percentage of Medicare payments through an Advanced APM

Percentage of Medicare patients through an Advanced APM

25%

20% 35% 35% 50% 50%20%

50% 50% 75% 75%25%

QPs and Partial QPs for AAPMs

Partial Qualifying Participants (Partial QPs)– Can opt out of MIPS without penalty– Can report MIPS for possible incentive


Performance Year 2017 2018 2019 2020 2021 2022 and later

Percentage of Medicare payments through an Advanced APM

Percentage of Medicare patients through an Advanced APM

20%

10% 25% 25% 35% 35%10%

40% 40% 50% 50%20%

MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)

Overview

Impact on the MPFS

Instead of a 21 percent payment cut – No increase in MPFS (January – June 2015)– Increase 0.5 percent (July 2015 – December 2015)– Increase 0.5 percent per year (2016 – 2019)– No increase (January 2020 – December 2025)– 2026 and beyond:

– APM participants –0.75 percent annual increase

– MIPS participants –0.25 percent annual increase


0

0.2

0.4

0.6

0.8

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

2026

2027

MIPS Impact on Current Programs

– PQRS Quality– VM Cost– EHR Advancing

Care Information

– Improvement Activities is a new measure in MIPS


CMS legacy programs become measures in the MIPS program

MIPS Overview

Provides both upside and downside adjustments to the MPFS Maximum adjustments: – 2019: 4 percent– 2020: 5 percent– 2021: 7 percent– 2022 & beyond: 9 percentFirst MIPS performance year-2017First MIPS payment year-2019


Threshold

4x% 5x% 7x% 9x%

-4x% -5x% -7x% -9x%2019 2020 2021 2022

MIPS Eligible Providers

Years 1 and 2 Medicare Part B clinicians:

Physicians MD, DOPodiatristsOptometristsChiropractorsDentistsPhysician AssistantsNurse PractitionersClinical Nurse SpecialistsCertified Registered Nurse Anesthetists

Year 3+ Medicare Part B clinicians:

Occupational TherapistsPhysical TherapistsSpeech TherapistsAudiologistsNurse MidwivesClinical Social WorkersDietitians


Who is Exempt from MIPS?

3 groups of clinicians:


First year of Medicare Part B

participation

Below low patient volume threshold

Qualified Participants in

ADVANCEDAlternative

Payment Models100 or fewer Part B patients

OR billing no more than $30k/year

NOTE: MIPS does not apply to hospitals or facilities

MIPS Category Measures Over Time

A score of 0-100 developed for each eligible clinician based on performance in four categories:


QualityAdvancing Care

InformationImprovement

Activities CostReplaces PQRS Replaces MU New (PCMH) Replaces VBM

2017 60% 25% 15% 0%

2018 50% 25% 15% 10%

2019+ 30% 25% 15% 30%

Three MIPS Options to Participate in 2017

To avoid a negative adjustment in 2019, submit to CMS one of the following in 2017:


1Quality

Measure

1Improvement

Activity

5Required Advancing Care

Information Measures

OR OR

Reporting

Individual – defined as a single NPI tied to a single TIN– CEHR– Registry– Qualified clinical data registryGroup – must share a common TIN– CEHR– Registry– Qualified clinical data registry– CMS web interface – must register by June 30, 2017


Quality – 60%

Select 6 measures to report on from about 300 quality measuresOr select from a set of specialty specific measuresFull list of measures at https://qpp.cms.gov/measures/quality


Must report for at least 90 days to be eligible for a positive adjustment

3-10 points per measure based on performance against a benchmark 60 possible pointsBonus points for high-priority and EHR reporting

60Points

https://qpp.cms.gov/measures/quality

Advancing Care Information – 25%


Choose between 2 lists of Advancing Care Information (ACI) Objectives ad Measures

ACI Objectives and Measures 2017 ACI Transition Objectives and Measures

5 required base measures 4 required base measures9 optional performance measures 7 optional performance measures2015 Certified EHR 2014 Certified EHRStage 3 Meaningful Use standards Modified Stage 2 Meaningful Use

standards

Advancing Care Information Performance Category Fact Sheet available athttps://qpp.cms.gov/resources/education

https://qpp.cms.gov/resources/education

Advancing Care Information – 25%


– Security risk analysis– e-Prescribing– Provide patient access– Health Information

Exchange

– 5 percent for public health/clinical data registry reporting

– 10 percent for improvement activity alignment

– Provide patient access– Health information

exchange– View, Download, or

Transmit– Patient-specific education– Secure messaging– Medication Reconciliation– Immunization Registry

reporting

Required base score*

Optional performance score*

Bonus score

50 90 15

*2017 ACI Transition Objectives and Measures

Improvement Activities – 15%

Attest to completing activities that improve clinical practice for at least 90 days during the year92 activities in 9 categoriesAccumulate 40 points for maximum category scoring– Medium-weighted activities

(10 points)– High-weighted activities (20

points)Points are doubled for small, rural, and health professional shortage area practices


1. Expanded PracticeAccess

2. Population Management

3. Care Coordination

4. Beneficiary Engagement

5. Patient Safety and

Practice Assessment

6. Participation in an APM

7. Achieving Health Equity

8. Integrating Behavioral and Mental Health

9. Emergency Preparedness and Response

Improvement Activities – 15%

Full credit for clinicians in CPC+, in a PCMH, or in similar specialist practice– PCMH certifications for MIPS include: a national program,

a regional or state program, a private payer, or other body that certifies at least 500 practices

Partial or full credit for participation in an APMFull list of Improvement Activities, with details on action required and suggested documentation, available at https://qpp.cms.gov/resources/education under MIPS Data Validation Criteria


https://qpp.cms.gov/resources/education

Cost – 0%

Clinicians are not required to submit cost data to CMS– CMS assesses clinicians based on Medicare claims data CMS compares resources used to treat similar care episodes and clinical condition groups across practicesCost measures adjusted for geographic payment rates and beneficiary risk factorsECs earn a maximum of 10 points per episode cost measure


MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)

Reporting Requirements and Scoring

Pick Your Pace Options

Three options to participate in MIPS in 2017:


Don’t submit

Pick Your Pace Options

Four options to participate in MIPS in 2017:


No Participation

Minimum Participation

Partial Participation

Full Participation

• Report nothing

• -4% penalty

• Report 1 Quality measure

Or 1 Improvement

ActivityOr

4/5 Required Advancing Care

Information measures

• 0% adjustment

• Report more than minimum for at least 90 days

• Small incentive

• Report all categories for at least 90 days (preferably one full year)

• Up to 4% incentive

• Possible bonus if ≥ 70 points

Scoring Basics

Each provider/practice will receive a final score for each MIPS category based on performanceCategory scores will be calculated (based on category weighting) to produce a total score between 1-100


Payment Adjustment Basics

CMS will publish a “performance threshold” score at the start of each year Each Eligible Clinician’s (EC’s) final score is compared to the performance threshold score ECs with a score exactly at threshold will receive no MIPS adjustmentECs with a score below threshold will receive a negative payment adjustmentECs with a score above threshold will receive a positive payment adjustment factorAdjustment percentages are variable based on EC score compared to threshold score


2017 Final Scores and Adjustments


Final Score Payment Adjustment

≥70 points – Positive adjustment– Eligible for exceptional performance bonus – minimum of

additional 0.5%4-69 points – Positive adjustment

– Not eligible for exceptional performance bonus3 points – Neutral payment adjustment

0 points – Negative payment adjustment of -4%– 0 points = does not participate

33

Budget Neutrality

>> Amounts accrued from penalties assessed against ECs with scores below the threshold will fund payments for ECs with scores above the threshold


Additional Incentive Payments and Support

For 2019-2024, maximum of $500 million per year in additional incentive payments may be available to distribute to ECs who have “exceptional performance”– Final score of 70 or higher qualifies for an additional payment in

2017 (2019 payment year)– Not budget neutral Technical support for small and rural practices– QPP Small, Underserved, and Rural

Support (QPP SURS)


Example of MIPS Negative Adjustment


MPFSReimbursement

2017 data/2019 payment

2018 data/ 2020 payment

2019 data/ 2021payment


Maximum Loss 4% 5% 7% 9%

$50,000 $2,000 $2,500 $3,500 $4,500

$100,000 $4,000 $5,000 $7,000 $9,000

$400,000 $16,000 $20,000 $28,000 $36,000

Example of MIPS Positive Adjustment

36

MPFSReimbursement

2017 data/2019 payment




Plus or Minus 4% 5% 7% 9%

Bonus 10% 10% 10% 10% 10%

$50,000 $7,000 $7,500 $8,500 $9,500

$100,000 $14,000 $15,000 $17,000 $19,000

$400,000 $56,000 $60,000 $68,000 $76,000


Physician Compare Website

Shows MIPS composite scores and individual performance category scores Patients can see health care providers rated on a scale of 0 to 100 and how physician compares to peers nationally


PREPARING FOR MIPS 2017

Based on your practice’s capabilities

Pick Your Pace - Minimum and Ideal

Good - Submit data on at least one quality measure, one improvement activity or four advancing care information transition measures to avoid a 4% negative adjustmentBetter - Submit more than the required data in 1 or more categories for least 90 days to possibly earn a modest positive adjustmentBest - Submit full data in all 3 categories for at least 90 days (one full year preferred) to possibly earn the maximum positive adjustment


If you previously reported PQRS

1. Review the list of 2017 Quality measures to verify that your previous measures are still available https://qpp.cms.gov/measures/qualityMeasures Group reporting is no longer an option!

2. If reporting Quality via Claims, continue adding the appropriate codes to Medicare claims

3. If reporting Quality via EHR or registry, review your quality measure reports for accuracy, and

contact your vendor if there are obvious issues4. Begin improving performance on quality measures


https://qpp.cms.gov/measures/quality

If you previously reported Meaningful Use

1. Review the list of 2017 ACI Transition Objectives and Measures https://qpp.cms.gov/measures/aci

2. Print your 2017 Year-to-Date ACI or MU report3. Verify that you are able to meet all required base

measures (especially the Health Information Exchange measure)

4. Begin improving on your optional performance measures


https://qpp.cms.gov/measures/aci

If you do have an EHR & have not reported

1. Choose an improvement activity that you can complete for 90 days, and begin implementationReview the list at https://qpp.cms.gov/measures/ia

2. Contact your EHR vendor for guidance on MIPS reportingDo you need a software upgrade?How do you review Quality and ACI reports?How much is MIPS reporting per provider?


https://qpp.cms.gov/measures/ia

If you do not have EHR & have not reported

1. Choose an improvement activity that you can complete for 90 days, and begin implementationReview the list at https://qpp.cms.gov/measures/ia

2. Begin learning how to submit quality information via claims Contact your billing company to see if they can assist Begin educating yourself at

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2016PQRS_Claims_CodingRpgPrinc.pdf

3. Begin exploring EHR options


https://qpp.cms.gov/measures/ia

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2016PQRS_Claims_CodingRpgPrinc.pdf

TYING IT ALL TOGETHER

Start Working on QPP Activities now

Next Steps – Using Free CMS Resources for MIPS Success


Determine your eligibility – MIPS or APMIf you’re MIPS eligible, and your practice is under 15 physicians, rural, or underserved, you likely qualify for FREE support through the QPP Resource CenterHow to Sign Up: visit the www.qppresourcecenter.com – click the “Join Now” button at the top, answer a few short questions about your practice and you’re on your way! Questions: Contact Us - 800.264.7221 or [email protected]

http://www.qppresourcecenter.com/

mailto:[email protected]

Next Webinar – July 12


Visit Medical Advantage Group’s MACRA Jumpstart Page:– www.medicaladvantagegroup.com/mac

rajumpstart/

Register for our July 12 webinar: – MACRA Jumpstart: Preparing Your

Small Practice for MIPS Success

http://www.medicaladvantagegroup.com/macrajumpstart/

Questions?


Beth [email protected]


Documents

MACRA and MIPS Preparation for your Small Group Practice...Jun 21, 2017 · MACRA and MIPS . Preparation for your Small Group Practice. Beth Hickerson. Lead Quality Improvement Advisor