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MIPS 2020AUGUST 27, 2020PRESENTER: MAGGIE DELCAMP, RNEHR SPECIALIST & MIPS CONSULTANT
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(877) 243-8881
MIPS 2020 : Information & Planning
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What will this webinar include?
MIPS in a Minute overview
Potential financial impact
2019 finalized scores are in
Minimum requirements for 2020
Hardship Application
MIPS Training & Assistance Available
Q & A
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LET’S GET STARTED!
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DisclaimerPlease note that his information was current as of April 9, 2020 at 11am, however new guidance is being delivered daily, please check cited resources frequently for updates!
Disclaimer: Although AZCOMP Technologies, Inc. makes every effort to ensure that information regarding MIPS and other government programs are checked and accurate in both our documentation and training, the Medicare/Medicaid programs are constantly changing and individual providers may have unique circumstances that go beyond the typical guidelines laid out in the respective programs they are participating in. Therefore, it is the sole responsibility of each provider to study, interpret and remain abreast of the Medicare/Medicaid program requirements and deadlines, contacting program administrators directly as needed. Any documentation and training provided by AZCOMP Technologies, Inc. is based on our interpretation of the programs and certification rules published by the Department of Human Services and are subject to change. Information and training provided is “as is” and without any express or implied warranties. AZCOMP Technologies, Inc. assumes no responsibility for any inaccuracies, errors, or omissions, expressly disclaiming liability for damages of any kind arising out of the use of, reference to or reliance on any content provided. Using certified electronic health record (EHR) systems and other certified health IT to provide and attest to meaningful use is the sole responsibility of the eligible provider.
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The latest MIPS regulations can be found on the CMS web site at https://qpp.cms.gov/EHR Incentive Program Information Center - Phone: 1-866-288-8292 Email: [email protected]
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MIPS REVIEW IN A MINUTE
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(877) 243-8881
The Beginning: MIPS IS INTRODUCED
Medicare Meaningful Use
PQRS (Physician Quality Reporting
System)
Value Based Payment Modifier
MIPS
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SUMMARY OF PARTICIPATION
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Collect Data
•Performance period during calendar year
Report Data
•Historically Q1 of the following year
• Jan 4 – Mar 31, 2021.
Feedback Available
•Generally in the Summertime
Payment Adjustment
•Begins 2 years after performance year
Jan – Dec 2020 Jan 4 - March 31, 2021 TBD Adjustment applies 2022
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CATEGORIES & WEIGHTS CHANGE2017
Quality - 60%Advancing Care Information (ACI) - 25%Improvement Activities (IA) - 15%
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2018
Quality - 50%Promoting Interoperability (PI) - 25%Improvement Activities (IA) - 15%Cost - 10%
2019
Quality - 45%Promoting Interoperability (PI) - 25%Improvement Activities (IA) - 15%Cost - 15%
Cost 15%
Quality60%
ACI 25%
IA15%
Quality50%
Quality45%
IA15%
IA15%
PI 25%
PI 25%
Cost 10%
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PRELIMINARY SCORE
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YEARFULL Negative Payment Adjustment
PARTIAL Negative Payment Adjustment
NEUTRAL Adjustment
POSITIVE Adjustment
POSITIVE Adjustment +
Exceptional Performer Bonus
2019[applies 2021]
0 Points (-7%) 1 – 29 points 30 points 30 – 75 points > 75+ points
2018[applies 2020]
0 Points (-5%) 1 – 14 points 15 points 16 – 69 points > 70+ points
2017[applies 2019]
0 Points (-4%) 1 – 3 points 3 points 4 – 69 points > 70+ points
- % 0- % + % + %
Adjustment is based on MIPS Final ScoreTHRESHOLDS .
INCREASE|
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PAYMENT ADJUSTMENT TIMELINE
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Have you decided how you will participate in MIPS for 2020?
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NOW AVAILABLE: 2019 Feedback
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THE FINANCIAL IMPACT
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MIPS Payment Adjustment
Annual Medicare Part B Reimbursement
2017 (4%) 2018 (5%) 2019 (7%) 2020 (9%)
$90k $3,600 $4,500 $6,300 $8,100
$120k $4,800 $6,000 $8,400 $10,800
$150k $6,000 $7,500 $10,500 $13,500
$200k $8,000 $10,000 $14,000 $18,000
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TOTAL (if no MIPS data was reported 2017-
2020)
$22,500
$30,000
$37,500
$50,000
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COVID-19 Response: Additional Flexibilities Expanded availability to apply for exception
Doubled Complex Patient Bonus for 2020
NEW Improvement Activity COVID-19 Clinical Trials
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CMS COVID-19 Response & added flexibilities : https://qpp.cms.gov/about/covid19
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2020 STRATEGYLearn, Plan & Manage
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2020 MIPS Breakdown
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Measures & Activities
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IMPROVEMENT ACTIVITIES
• Collect data on the 6required measures ANDsubmit “yes” to 3 attestation statements.
• Collect and report for the SAME continuous 90-dayperformance period in CY 2020
• Will need to select 2 – 4 activities
• Perform and report for the SAME continuous 90-dayperiod in CY 2020 (or as indicated by the measure description)
• Will need to select and report at least 6 measures
• Collect data for eachmeasure for the 12-month reporting period (Jan-Dec)
* Applies to MOST Clinicians.
Clinicians do not need to collect or submit and data for cost measures. CMS collects and evaluates that data for you.
COST
PROMOTING INTEROPERABILITYQUALITY
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(Your application must be approved by CMS to qualify for reweighting.)
Promoting Interoperability (PI)
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PI Requirements
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2020 Promoting Interoperability Quick Start Guide:https://qpp-cm-prod-content.s3.amazonaws.com/uploads/822/2020%20Promoting%20Interoperability%20Quick%20Start%20Guide.pdf
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2020 EXCEPTION OPTIONSEXTREME AND UNCONTROLLABLE CIRCUMSTANCES EXCEPTION
Allows you to request one or more performance categories be reweighted to 0%.
Eligible Clinicians – Individual Clinicians, Groups & Virtual Groups
Circumstances to Apply –• If you believe you have been affected by an extreme and uncontrollable circumstance (such as the public health emergency triggered by the COVID-19 pandemic), you can apply for this exception.
MIPS PROMOTING INTEROPERABILITY PERFORMANCE CATEGORY HARDSHIP EXCEPTION
Allows you to request reweighting—specifically for the PI category (to 0%).
Eligible Clinicians – Individual Clinicians, Groups & Virtual Groups
Circumstances to Apply –• You're a small practice • You have decertified EHR technology • You have insufficient Internet connectivity • You face extreme and uncontrollable circumstances such as
disaster, practice closure, severe financial distress or vendor issues
• You lack control over the availability of CEHRT
* Lacking 2015 Edition CEHRT does not qualify as a reason to submit an application.
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Both applications are available through QPP website using HARP account. https://qpp.cms.gov/loginDecember 31, 2020 at 8 pm (ET) is the Deadline to Apply
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Will CMS automatically apply any of the exceptions?
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MIPS Promoting Interoperability Performance Category Hardship Exception (qualifying clinician types)
Extreme and Uncontrollable Circumstances Exception(Individual clinicians)
Extreme and Uncontrollable Circumstances Exception(Groups/Virtual Groups)
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CMS Documentation Says…
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https://qpp.cms.gov/participation-lookup
Checking Provider Status & Eligibility
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Wash your hands of potential surprises later
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Reweighting
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Reweighting categories varies based on the categories for which the waiver is requested.
https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1054/2020%20MIPS%20Exception%20Applications%20Fact%20Sheet.pdf
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Example of PI Hardship Reweighting
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Options for MIPS 2020 ReportingWhich option is right for YOU?
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Report data for ALL Categories [Quality, Promoting Interoperability, Improvement Activities]
Report Some Categories & Will NOT apply for hardship
Apply for hardship AND report SOME categories
Apply for hardship AND may not report ANYcategories.
Do Nothing (no hardship application/no reporting)
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Report Data for ALL Categories [Quality, Promoting Interoperability, Improvement Activities]
WHOClinicians who have been recording and reporting data all or most of the year and meet all the requirements for PI. Especially good option for those with complex patients or special status bonuses.
WHY• Potentially higher incentives
available.
• Staying on track for future yearsUnderstanding the Proposed 2021 Quality Payment RuleBY: HITECHANSWERS.NET AND SPHANALYTICS.COM
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Report SOME Categories & Will NOT Apply for Hardship
WHOClinicians who have been recording and reporting high quality data, but don’t want to report all categories. (COVID-19 impact, etc.)
WHY NOT• Meeting threshold to avoid penalty is more
challenging than previous years.
• Leaving points “on the table” for categories not reported.
• No additional financial incentive compared to applying for hardship and reporting.
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Apply for Hardship AND Report SOME Categories
POTENTIAL PROS• The hardship can prevent categories not reported
from lowering your score.
• Categories reported might score high and combined with bonus points might result in a positive payment adjustment.
POTENTIAL CONS• “All eggs in one basket”
CONSIDERThis choice is a CALCULATED RISK. Check preliminary score before committing to this plan.
WHOClinicians who have been recording and reporting high quality data and want to report some categories or may qualify for special status or complex patient bonuses.
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Apply for Hardship AND May Not Report ANY Categories.
WHOClinicians who have not started collecting data for MIPS or who have been significantly impacted by COVID (or other circumstances) in collecting data for 2020.
WHY• Avoid penalties for 2020.• Get on track for future years• You always have the option to report
categories if it benefits you.
PRO TIP: This is the perfect time to start preparing for 2021 MIPS. Take some time to set your MIPS goals and begin preparations for 2021.
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Do Nothing (no hardship application/no reporting)
WHOClinicians who automatically quality for the hardship and do not (or cannot) report any information.
RECOMMENDATION• Be certain the hardship has been
applied.
• Begin planning for 2021
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1. Log in to QPP: https://qpp.cms.gov/login
2. Click Exceptions Application
3. Then Add New Exception
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How do I apply for a hardship exception?
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4. Select the Exception Type
5. Select the Application Type and enter the appropriate NPI or TIN as indicated
6. Complete the submitter information fields.
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Complete the details for your request
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Verify your status by logging into QPP
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MIPS To Do List Review your 2019 Feedback
Check / Monitor the Provider’s Status Using QPP Provider Lookup: https://qpp.cms.gov/participation-lookup Logging into QPP Account: https://qpp.cms.gov/login
Weigh your options and decide the best plan for 2020
Apply for hardship (if appropriate for your plan)
Continue working on 2020 measures
Consider a MIPS Assessment
Plan for 2021 and begin collecting data where possible
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(877) 243-8881
Looking Ahead: MIPS in 2021
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T2021 Proposed Rule Overview Fact Sheet:https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1100/2021%20QPP%20Proposed%20Rule%20Fact%20Sheet.pdf
2021 Quality Payment Program Proposed Rule:https://www.federalregister.gov/documents/2020/08/17/2020-17127/medicare-program-cy-2021-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other
2021 MIPS Payment Adjustment Fact Sheet: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1110/2021%20MIPS%20Payment%20Adjustment%20Fact%20Sheet.pdf
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Industry News – EPCS MANDATES
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13 – States with mandates already in effect
13 – States with mandates beginning 1/1/2021
2 – States with mandates coming during 2021 *Kansas-7/1/2021 & *Michigan -10/1/2021
3 – States with mandates beginning 1/1/2022 (CA, UT & MD)
6 – States with proposed legislation for mandates (WV, NJ, NH, NE, MT, MS)
ALL states – including those without mandates proposed WILL be impacted by the FEDERAL MANDATE in effect JAN. 1, 2020
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FEDERAL MANDATE:Every Prescription Conveyed Securely Act
H.R. 3528“… The Every Prescription Conveyed Securely Act would require prescriptions for controlled substances covered under Medicare Part D to be transmitted electronically, starting on January 1, 2021.”
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https://www.cbo.gov/publication/53967#:~:text=piece%20of%20legislation.-,H.R.,starting%20on%20January%201%2C%202021.
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Subscribe or Check the Blog Often forthe Most Up to Date Industry News
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https://www.azcomp.com/blog/
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How can AZCOMP help you from here?
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MIPS TRAINING & CONSULTING AVAILABLE
MIPS Assessment
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FREEConsulting Services MIPS EHR EDI IT Services
For our New and Existing EHR Customers
A $499 value
Email [email protected] to request your MIPS assessment and for more information on our other services.
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RELIABLE RESOURCES
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The QPP website: https://qpp.cms.gov/
The QPP Resource Library: https://qpp.cms.gov/about/resource-library
Contacting CMSBy Phone: 1-866-288-8292 (TRS: 711)Monday - Friday 8 a.m - 8 p.m ET
By Email: [email protected]
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HELPFUL LINKS
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Check Provider Eligibility for MIPS: https://qpp.cms.gov/participation-lookup
Individual vs Group Participation: https://qpp.cms.gov/mips/individual-or-group-participation
2020 Improvement Activities Performance Category Quick Start Guide: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/818/2020%20Improvement%20Activities%20Quick%20Start%20Guide.pdf
2020 Promoting Interoperability Performance Category Quick Start Guide: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/822/2020%20Promoting%20Interoperability%20Quick%20Start%20Guide.pdf
2020 Quality Measures Requirements: https://qpp.cms.gov/mips/quality-measures
2020 Quality Payment Program (QPP) Exception Applications Fact Sheet: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1054/2020%20MIPS%20Exception%20Applications%20Fact%20Sheet.pdf
QPP Access User Guide – (includes instructions to register for QPP login, appoint staff as representatives):https://qpp-cm-prod-content.s3.amazonaws.com/uploads/335/QPP%2BAccess%2BUser%2BGuide.zip
Highly Recommend MIPS 2020 Quick Start Guide: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/819/2020%20MIPS%20Quick%20Start%20Guide.pdf
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That’s all, folks!
Give us a call (877) 243-8881
Or visit us at: www.azcomp.com
Or email us at: [email protected]
Interested in another webinar?
Check out: www.azcomp.com/events
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