MACRA/Quality Payment Program/MIPS Participation without ... · •Reporting through EHR, Registry or QCDR and claims •Set of clinicians whose NPIs are tied to a shared TIN •Submit

MACRA/Quality Payment Program/MIPS

Participation without an EHR August 2017

In Partnership with Alliant Quality

Michele Stanek, MHS South Carolina Office of Rural Health Center for Practice Transformation

Transformation

• Changes in Healthcare Delivery System

• Changes in Payment Systems

• Changes in Culture

MACRA/QPP Medicare Access and CHIP Reauthorization Act of 2015

• New framework of physician reimbursement –

rewards better care (value) rather than more care (volume)

• Repeals and replaces sustainable growth rate (SGR) • Primarily still based on fee-for-service architecture • Consolidates Medicare quality programs

– Meaningful Use – Physician Quality Reporting System (Quality) – Value Based Payment Modifier Program (Cost)

Quality Payment Program

Medicare Physician Reimbursement MIPS (Merit-Based Incentive Program): • Based on fee-for-service • Performance score based on

“value” • FFS payment adjusted based on

performance score APMs (Alternate Payment Models): • Moves to population-based and

episode-based payment • Requires shared two-sided risk • Incentives for organizations to

move towards APMs (bonus)

QPP

MIPS

MIPS

APM

APM

Source: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-LAN-PPT.pdf

Merit-Based Incentive Program

Each physician or eligible professional or group will receive a composite performance score: 0-100; score will determine reimbursement

Quality

60%

Improvement

Activities

15%

Cost

0%

Advancing

Clinical

Information

25%

Final Score

(0-100)


MIPS • Quality: 6 performance measures (1 outcome/high value) or

one specialty-specific or subspecialty-specific measure set (PQRS)

• ACI: 5 required measures of EHR functionality & how well you are using EHR/HIT/HIE); optional measures that provide bonus points (MU)

• Cost: Claims-based; total per capita cost per attributed beneficiary & Medicare spending per beneficiary; 30% CPS by 2019/2021 (VM)

• IA: high and medium weighted activities; PCMH recognition maximum points; must complete 4 medium or 2 high-weighted activities; small practices 1 high or 2 medium; activity that involves CERHT gets bonus score

MIPS


Transitional Year:

Threshold 3 points; > 70

points eligible for bonus

adjustments

Pick Your Pace Measurement Year 2017; Payment Year 2019


2017 data must be submitted by March 2018

Pick Your Pace Testing QPP to Avoid Negative Adjustement

Source: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-presentation.pdf

✔ ✔ ✖

Clinical Quality

Clinical Quality

• Must select and report on 6 clinical quality measures from list of 271 measures - https://qpp.cms.gov/mips/quality-measures

• 1 of 6 measures must be an outcome measure; if an outcome measure is not available that is applicable to your specialty you can select another high priority measures

• Data completeness: must report on at least 50% of all Medicare Part B patients

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



Quality Measures

Selecting Measures

Selecting Measures

Selecting Measures

Selecting Measures

Reporting

Report as an Individual Reporting by group

• Report by NPI tied to single TIN

• Reporting through EHR, Registry or QCDR and claims

• Set of clinicians whose NPIs are tied to a shared TIN

• Submit group level data through CMS web interface or an electronic health record, registry, or a qualified clinical data registry

• Option for solo or small practices to create virtual group for MIPS reporting


Reporting

Registry Reporting

Source: qpp.cms.gov

• Explore listing of approved registries - https://qpp.cms.gov/about/resource-library

• Many specialty societies have an approved registry

• Different methods to interact with registry

• Must meet data completeness standard of 50% of all eligible Medicare Part B patients; must include at least 20 patients

https://qpp.cms.gov/about/resource-library




Registry Reporting

Source: https://qpp.cms.gov/about/resource-library

Claims Reporting

Source: qpp.cms.gov

Claims Reporting

Claims Reporting

• Codes that ensure patient is part of denominator and numerator

• Denominator: CPT or HCPCS – Codes to eliminate patient from

denominator if they meet exclusion

• Numerator: Mostly CPT II and modifier codes – CPT II are tracking codes – Paired with cost of $0.00 or $0.01

• Submit 1 patient using codes to “Test Program”

• To partial or fully participate must have a case minimum of 20 patients and must report on 50% of all Medicare Part B patients


Claims Reporting


Scoring

Scoring

Improvement Activity

Practice Improvement Activities • Practices must attest to the completion of

approved practice improvement activities for a minimum of 90 days – 92 approved practice improvement activities

– Activities rated as either high and medium activities

• Must complete 4 medium or 2 high-weighted activities;

• Small practices must complete 1 high or 2 medium activities – 15 or fewer clinicians attached to one Tax ID #

– Rural or health professional shortage area

– Non-patient facing specialties


Practice Improvement Activities

• PCMH or PCSP recognition maximum points • Groups qualifying for specials scoring as an MIPS APM

(MSSP Track 1, Oncology Care Model…) have no additional PI reporting requirement; receive maximum points

• Groups participating in other APM will get automatic half credit

• Activities that involves CERHT gets bonus score • Total Points available 40 points

– Medium Activity = 10 points – High Activity = 20 points

• Small, rural, or non-patient facing clinicians – 40 points – Medium = 20 points – High = 40 points


Reporting

• Report through attestation through CMS portal – not yet available

• Must be able to provide documentation on selected improvement activities


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


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

ACI: Reweighting

Reweighting

• Hardship Exemption: To have ACI category to be reweighted to 0%, ECs/groups must meet the following: – Insufficient Internet Connectivity – Extreme or Uncontrolled Circumstances – Lack of control over the Availability of CEHRT Must submit application to CMS

• Automatic Reweighting: To qualify for automatic reweighting: – Hospital-based MIPS clinician – PA – NP – CNS – CRNA – Clinician who lack face-to-face interactions with patients ACI Category will be reweighted at 0% with the 25% assigned to the Clinical Quality Category

QUESTIONS?

Documents

MACRA/Quality Payment Program/MIPS Participation without ... · •Reporting through EHR, Registry or QCDR and claims •Set of clinicians whose NPIs are tied to a shared TIN •Submit