MIPS IN 2017: A DEEP DIVE

Presented by: James Christina, DPM 301-581-9265 jrchristina@apma.org

SGR

MACRA (The Medicare Access and CHIP Reauthorization Act of 2015)

Quality Payment Program

MIPS APM

Highest total of 100

EPs will receive either a positive or negative payment adjustment to Medicare part B fee schedule based on MIPS score

Almost all podiatrists will report through MIPS first year

MIPS Score

Thresholds

CMS set the Performance Threshold at 3 and the Exceptional Performance Threshold at 70, meaning that any clinician with a score of at least 3—which can be accomplished by submitting, for example, just one Quality measure—will avoid a negative adjustment, and those earning a score of at least 70 will be eligible for an Exceptional Performance Adjustment from the annual $500 million pool.

2019: -4% to +4% (based on 2017 score) 2020: -5% to +5% (based on 2018 score) 2021: -7% to +7% (based on 2019 score) 2022 : -9% to +9% (based on 2020 score)

MIPS Adjustments

Mostly budget neutral

Penalty no more than 4%

Most positive adjustments no more than 4% …positive moved based on budget neutrality

“Exceptional Performance” (MIPS Score of 70 or higher—access to additional $500 million bonus pool)

MIPS Year 1

CMS proposes to define MIPS eligible clinicians or groups who do not exceed the low-volume threshold as an individual MIPS eligible clinician or group who, during the performance period, has Medicare billing charges less than or equal to $30,000 or provides care for 100 or fewer Part B-enrolled Medicare beneficiaries.

Newly Medicare-enrolled eligible clinicians Qualifying APM Participants (QPs) Certain Partial Qualifying APM Participants (Partial

QPs)

Exclusions:

Two determination period options to meet 2017 low volume threshold:

9/1/2015 - 8/31/2016 or 9/1/2016 - 8/31/2017

MIPS

MIPS Participation Status Letter

The Centers for Medicare & Medicaid Services is reviewing claims and letting practices know which clinicians need to take part in MIPS, the Merit-based Incentive Payment System. MIPS is an important part of the new Quality Payment Program. In late April through May, practices will get a letter from the Medicare Administrative Contractor that processes Medicare Part B claims. This letter will tell the participation status of each MIPS clinician associated with the Taxpayer Identification Number or TIN in a practice.

Clinicians should participate in MIPS for the 2017 transition year if they bill more than $30,000 in Medicare Part B allowed charges a year AND provide care for more than 100 Part B-enrolled Medicare beneficiaries a year.

The Quality Payment Program intends to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for their overall work in delivering the best care for patients. It replaces the Sustainable Growth Rate formula and streamlines the “Legacy Programs” Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM), and the Medicare Electronic Health Records (EHR) Incentive Program. During this first year of the program CMS is committed to diligently working with you to streamline the process as much as possible. Our goal is to further reduce burdensome requirements so that you can deliver the best possible care to patients.

MIPS Participation Status Letter

MIPS reporting not limited to Medicare patients* (but some quality measures do have age ranges in their denominators so pay attention to them) *Reporting Quality Component by Claims method is exception

MIPS

Quality 60%

ACI 25%

Clinical PracticeImprovement Activities15%Cost 0%

MIPS Score Performance Year 2017

Three options with regards to MIPS

CHOSE YOUR COURSE OF PARTICIPATION

Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment.

MAXIMUM MIPS

Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment

and to possibly receive a positive MIPS payment adjustment.

MODERATE MIPS

Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative payment adjustment.

MINIMUM MIPS

For the 2017 transition year, if the measure is submitted but is unable to be scored because it does not meet the required case minimum (20), does not have a benchmark, or does not meet the data completeness requirement (at least 50% reporting rate), the measure will receive a score of 3 points

MINIMUM SCORE OF 3

Four percent payment reduction on Medicare Part B Fee For Service

Payments in 2019

WHAT ABOUT NO MIPS?

-4%

Choose 6 MIPS Quality measures One must be an outcome measure (or if no outcome

available then a high priority measure)

All 6 must be reported by the same method

MIPS Quality (60%)

Claims 50% or more of Medicare Part B patients

Registry 50% or more of all patients

EHR 50% of all patients

CMS Web Interface (groups of 25+)

ALL SIX MUST BE SUBMITTED BY SAME MECHANISM

Quality Measures Submission Methods

QPP.CMS.GOV

QPP.CMS.GOV

QPP.CMS.GOV

QPP.CMS.GOV

QPP.CMS.GOV

1. Documentation of Current Meds in the Medical Record*

2. Diabetes: Hemoglobin A1c (HbA1c) Poor Control - Intermediate Outcome

3. Pain Assessment and Follow-Up 4. Pneumococcal Vaccination Status for Older Adults 5. BMI Screening and Follow Up Plan 6. Influenza Immunization 7. Screening for High Blood Pressure and Follow Up 8. Tobacco Screening and Cessation Intervention

QUALITY MEASURES Claims Reporting

*High priority measure

1. Documentation of Current Meds in the Medical Record*

2. Pneumococcal Vaccination Status for Older Adults 3. BMI Screening and Follow Up Plan 4. Influenza Immunization 5. Screening for High Blood Pressure and Follow Up 6. Tobacco Screening and Cessation Intervention

Six Recommended Measures to Report by Claims (Medicare Part B Patients Only)

How Points for Measures are Assigned (Claims Decile)

Documentation of Current Medications in Medical Record*

Pneumococcal Vaccination Status for Older Adults

BMI Screening and Follow Up Plan

Influenza Immunization

Screening for High Blood Pressure and Follow Up

Tobacco Screening and Cessation Intervention

You are submitting by claims method so must be a Medicare Part B Fee for Service patient (not Medicare Advantage, Medicare HMO, etc.)

You must be seeing them for one of the denominator designated codes (essentially an E/M service)

You must place the quality measure code on the claim form under item 24

KEY POINTS

1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control

- Intermediate Outcome 2. Diabetes: Medical Attention for Nephropathy 3. Diabetic Foot and Ankle Care, Peripheral Neuropathy

– Neurologic Exam 4. Diabetic Foot and Ankle Care, Ulcer Prevention –

Examination of Footwear 5. Documentation of Current Meds in the Medical Record 6. Immunizations for Adolescents

QUALITY MEASURES

Registry Reporting

7. Functional Status Change for Patients with Foot or Ankle

Impairments – Outcome 8. Pain Assessment and Follow-Up 9. Pneumococcal Vaccination Status for Older Adults 10. Preventive Care & Screening: Body Mass Index (BMI)

Screening & Follow-Up Plan 11. Preventive Care and Screening: Influenza Immunization 12. Screening for High Blood Pressure and Follow Up 13. Preventive Care and Screening: Tobacco Use: Screening and

Cessation Intervention 14. Preventive Care and Screening: Unhealthy Alcohol Use:

Screening & Brief Counseling

QUALITY MEASURES Registry Reporting

1. Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam

2. Diabetic Foot and Ankle Care, Ulcer Prevention – Examination of Footwear

3. Documentation of Current Meds in the Medical Record*

4. Screening for High Blood Pressure and Follow Up 5. Preventive Care and Screening: Tobacco Use:

Screening and Cessation Intervention 6. Preventive Care & Screening: Body Mass Index (BMI)

Screening & Follow-Up Plan

Six Recommended Registry Measures (All patients)

1. Diabetes: Foot Exam 2. Diabetes: Hemoglobin A1c (HbA1c) Poor Control

(>9%) – Intermediate Outcome 3. Diabetes: Medical Attention for Nephropathy 4. Documentation of Current Medications in the Medical

Record* 5. Falls: Screening for Future Fall Risk* 6. Pneumococcal Vaccination Status for Older Adults 7. Preventive Care and Screening: Body Mass Index

(BMI) Screening and Follow-Up Plan

QUALITY MEASURES

EHR Reporting

8. Preventive Care and Screening: Influenza

Immunization 9. Preventive Care and Screening: Screening for High

Blood Pressure and Follow-Up Documented 10. Preventive Care and Screening: Tobacco Use:

Screening and Cessation Intervention

QUALITY MEASURES

EHR Reporting

When choosing quality measures check minimum case requirements!

Most minimum case requirements listed as 20

QUALITY MEASURES

In 2017, there are two measure set options for reporting. The option you use to submit your data is based on your electronic health record edition. Option 1: Advancing Care Information Objectives and Measures Option 2: 2017 Advancing Care Information Transition Objectives and Measures

You can report the Advancing Care Information Objectives and Measures (Option 1):

If you have technology certified to the 2015 Edition; or If you have a combination of technologies from 2014 and 2015 Editions that

support these measures.

You can report the 2017 Advancing Care Information Transition Objectives and Measures (Option 2): If you have technology certified to the 2015 Edition; or If you have technology certified to the 2014 Edition; or If you have a combination of technologies from 2014 and 2015 Editions.

Advancing Care Information (Think Meaningful Use)

4 Measures if using 2014 ONC Certified EHR

(Transition—Option 2)

Advancing Care Information (25%)

40% credit just for reporting the for base measures

Other 60% depends on performance and bonus measures

No more clinical decision support rule No more CPOE

Advancing Care Information (25%)

Base Score + Performance Score + Bonus Points

Total ACI Score

Base score: 10 points for reporting a measure Base Score: Max 40 Need numerator to be ≥ 1 for each

ACI Base Score

Protect Patient Health Information (yes/no) MUST BE A “YES” OR ZERO FOR ACI Electronic Prescribing At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology. Provide Patient Electronic Access Health Information For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient's health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programing Interface (API) in the MIPS eligible clinician's certified EHR technology Send A Summary of Care For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider-(1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record.

MIPS ACI Base 4 Measures (Transition)

Performance Score: Receive 1-10 points for each measure reported based on performance of that measure

Performance Score: Max 70 points

ACI Performance Score

5 Bonus Points for reporting to any additional public health or clinical data registry

10 Bonus Points for achieving one Improvement Activity via CEHRT

ACI Bonus Points

1. Provide Patient Electronic Access (additional 10%) 2. Health Information Exchange (additional 10%) 3. View, Download, or Transmit (VDT) (up to 10%) 4. Provide Patient-Specific Education (up to 10%) 5. Secure Messaging (up to 10%) 6. Medication Reconciliation (up to 10%) 7. Immunization Registry Reporting (0 or 10%) 8. Syndromic Surveillance Reporting (5% bonus) 9. Specialized Registry Reporting (5% bonus)

ACI Performance and Bonus Measures

Score 100 or above on ACI = full 25 MIPS points

ACI

Reporting Score + Performance Score + Bonuses = Total ACI Score

If earn 100 (or more), get the full 25 MIPS score

If earn less than 100, declines proportionately. It is

not all or nothing! 50 ACI points means 12.5 MIPS points

ACI Total Score

List of more than 90 options

Choose up to 4 activities if in a group of more than 15 clinicians

Choose up to 2 activities if in a group of 15 or fewer clinicians

Clinical Practice Improvement Activities (15%)

Medium weight = 10 points High weight = 20 points Activities double weighted if group of less than

15

Score Needed for full CPIA credit—40 CPIA points

means 15 MIPS points

Clinical Practice Improvement Activities (15%)

QPP.CMS.GOV

1. Registration in your state’s prescription drug monitoring program - Medium

2. Implement Fall Screening & Assessment Program - Medium 3. Provide 24/7 access to clinician who has real-time access

to patient’s medical record - High 4. Assess patient experience of care through surveys,

advisory councils and/or other mechanisms - Medium 5. Use decision support and standardized treatment protocols

- Medium 6. Program to send reports back to referring clinician -

Medium

Clinical Practice Improvement Activities (15%)

7. Collection and follow-up on patient experience and satisfaction data on beneficiary engagement - High

8. Collection and use of patient experience and satisfaction data on access - Medium

9. Consultation of the Prescription Drug Monitoring program - High

10. Engagement of community for health status improvement - Medium

11. Engagement of patients, family and caregivers in developing a plan of care - Medium

Clinical Practice Improvement Activities (15%)

12. Engagement of patients through implementation of improvements in patient portal – Medium

13. Implementation of condition-specific chronic disease self-management support programs - Medium

14. Implementation of use of specialist reports back to referring clinician or group to close referral loop - Medium

15. Improved practices that disseminate appropriate self-management materials - Medium

16. Use of decision support and standardized treatment protocols - Medium

Clinical Practice Improvement Activities (15%)

Calculated by claims review so no additional reporting

Higher points for more efficient resource use

Not implemented in 2017 but CMS is supposed to give providers this analysis so they can anticipate 2018

Cost (0% in 2017)

Exempt from MIPS payment adjustments

Successful participation = 5% bonus and no MIPS adjustment

Have to receive certain amount of payments or see certain number of patients through APM

APMs

Advanced APMs are those in which clinicians accept risk for providing coordinated, high- quality care.

APMs

APMA.org/MACRA

MACRA Made Easy Webinar Series

MIPS in 2017 • Advancing Care Information Quality Performance Category • Improvement

Activities Performance Category For other MACRA-related Resources, visit

APMA.org/MACRA

APMA.org/MacraWebinars

Resources For more information on Quality measures: https://qpp.cms.gov/measures/quality For more information on CPIA: https://qpp.cms.gov/measures/ia For more information on Advancing Care: https://qpp.cms.gov/measures/aci Quality Payment Program (CMS Web Page): https://qpp.cms.gov/

QUESTIONS