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MACRA, QPP, MIPS and APMs Rules of the Game
Make effective use of the 2017 and 2018 Transition Years
eyecareleaders.com
About Your Speaker
Mike E.C. Schmidt
Director of Certification and Client Success at Eye Care Leaders
Mike leads the teams at Eye Care Leaders which focus on client success with MIPS and the related ONC Health IT Certification program. He brings more than 30 years of experience from the medical device software and healthcare IT field, including general management, marketing, software management, and software development positions in the ophthalmology, oncology and radiology fields, including at Carl Zeiss Meditec, Varian Associates, Siemens Medical Systems and Pacsgear. Mike also owned and led SES, a turnkey software development company focusing on high-risk applications.
With the increased regulation, Mike has focused on MACRA, MIPS, Meaningful Use and other EHR related regulatory concerns. He has spoken at national conferences including at the User Group Conferences for Medflow, Integrity, Management Plus MD Office.
Mike received his bachelor’s degree in mathematics from the University of California at Berkeley and his master’s degree in mathematics from the University of Washington at Seattle.
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Agenda
The MIPS Challenge
Regulatory Update on the 2018 MIPS Proposed Rule
The MIPS 2017 & 2018 Transition Years
The MIPS Composite Performance Score
MIPS ACI Performance
MIPS Improvement Activities Performance
MIPS Quality Performance
MIPS APMs and Advanced APMs
Action Items and Summary
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What is MIPS?
”Merit-Based Incentive Payment System”
1 of 2 “tracks” of the “Quality Payment Program” (QPP)
”Alternate Payment Models” (APMs) represent the other track
Created by MACRA, a law passed with bi-partisan support in 2015, nothing to do with the Affordable Care Act, and not going away
”MIPS” is the most widely recognized acronym and is often misused to refer to the program as a whole
MIPS and specifically APMs are intended to rein in rising Medicare costs
MIPS represents a historic transition from the classic Fee-For-Service model to a “value-based” reimbursement model
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MIPS shifts power to the payer
Instead of the provider specifying the fee to be paid…
… the payer will pay what they determine the services are worth!
The payer measures several categories of provider performance such as quality of care and cost of care
value-based reimbursement amounts are calculated in terms of payment adjustments relative to the FFS schedule, which will continue to exist
MACRA requires MIPS and its payment adjustments to be budget neutral
Congressional hopes for containing Medicare costs lie primarily with the APMs, which put increasing financial risk on the health care delivery organizations
Over time, Congress hopes to move increasing numbers of physicians from MIPS to APMs
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Practice Size Physicians with Negative Payment
Adjustment
Physicians with Positive Payment Adjustment
Solo 87% 12.9%
2-9 69.9% 29.8%
10-24 59.4% 40.3%
25-99 44.9% 54.5%
100+ 18.3% 81.3%
Proposed Rule Table 64, CMS estimatees based on 2014 data
The Challenge of MIPS
Adjustments by Practice Size
Small practices lack economy of scale to manage MIPS performance effectively
MIPS has disproportional effects on ambulatory specialties such as ophthalmology
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Regulatory Update:CMS June, 2017 Proposed Rule for 2018 MIPS(1 of 3)
90-day reporting for 2018 MIPS EHR and Improvement Activities
➢But keeps 2018 MIPS Quality reporting period at the full calendar year
Allows old 2014 Edition CEHRT for one more year
➢But awards 10 MIPS ACI bonus points for 2015 Edition CEHRT in 2018
❖We recommend the upgrade to 2015 Edition CEHRT in 2017 as soon as it is available
Broadens the MIPS exclusion, from $30,000 to $90,000 Medicare reimbursements per provider per year
➢Dramatically affects optometrists: AOA estimates that all but 4000 optometrists nationwide will be able to exclude from MIPS
Declares 2018 as 2nd and final “transition year” easier MIPS scoring than later years
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Regulatory Update:CMS June, 2017 Proposed Rule for 2018 MIPS(2 of 3)
Adds a 5-point small practice bonus, starting in 2018➢ group TIN with no more than 15 individual NPI numbers
➢ intended to counteract the “Table 64 issue”
➢ Larger practices should re-assess their group TIN structure
Reinstates critically missing EHR workflow exclusions, retroactive to 2017
➢ Exclude from eRx measure if writing fewer than 100 prescriptions
➢ Exclude from “send summary of care” measure if referring / transitioning fewer than 100 patients
➢ Exclude from new “receive summary of care” measure in case of fewer than 100 new patients in the reporting period
➢ But Direct messaging capability is still part of the definition of “Base EHR” and required for CEHRT!
➢With increased CMS auditing scrutiny, the practice must purchase a HISP license!
Reinstates hardship exclusion for use of CEHRT available only to small practices, no more than 15 eligible
clinicians (or to ones in rural or HPSA locations)
❖We do not recommend to plan a priori to take advantage of this, but it is a welcome safety valve in case of CEHRT implementation issues
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Regulatory Update:CMS June, 2017 Proposed Rule for 2018 MIPS(3 of 3)
Delays MIPS Cost of Care scoring until 2019
Extends transition year MIPS quality scoring rules➢3-point floor for MIPS quality measure scores
➢Small practices earn the 3 points even if the data threshold is not met
Introduces “Improvement” component to MIPS Quality scoring
➢Nothing to do with Improvement Activities
Adds 11 new Improvement Activities all eligible for EHR bonus points
➢Sadly, none appear attractive for eye care
Modified scoring with more points for public health reporting measures
➢Eye care practices should sign up for syndromic surveillance reporting if their state PHA allows it
“Virtual Group” option for solo and small practices to cooperate for a joint MIPS submission and score
➢Contact Eye Care Leaders if you may be interested in having us facilitate this option for you
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The MIPS
Transition
Years:
2017 & 2018
• 2017 & 2018 MIPS transition years will be far easier than 2016 MMU2 / PQRS / VM
• CMS estimated that for 2017 MIPS:
➢ “At least 90% of MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment (for) the transition year, and that
➢ “at least 80% of clinicians in small and solo practices with 1-9 clinicians will receive a positive payment adjustment.”
• If you do nothing, you will be penalized the full amount
➢ 4% for 2017; 5% for 2018
• To avoid a penalty, only need to report a single performance category
• Quality, or
• Improvement Activities, or
• ACI (formerly called “Meaningful Use of Certified EHR Technology”)
• Don’t let the easy rules lull you into a false sense of security
➢ If you only target 2017 and 2018, the gap with very large practices will only grow
➢ You would fail in later years
➢ It is time to plan and implement your long-term MIPS strategy now
➢ Take proper advantage of the Transition Years
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Limited Positive Payment Adjustments
• MACRA requires payment adjustments to be budget-neutral➢ Positive adjustments are subject to a “Scaling Factor” based on
available funds from negative payment adjustments
➢ With over 90% of physicians expected to receive positive or neutral payment adjustments for 2017, the funds from negative payment adjustments are expected to be very small
➢ Physicians who will not bother with MIPS will be those planning to retire by 2019 or those who receive relatively low total Medicare reimbursements, further limiting the available funds
➢ Expect positive adjustments earned for the 2017 performance year to be very small – maximum possible may be less than +0.8%
➢ Expect positive adjustments tfor the 2018 performance year not to be much larger – maximum possible may be less than +1%
• Main positive incentive will be for an “exceptional performance bonus”➢ Allocated from a $500M / Year fund not required to be budget-
neutral
➢ Shared by all eligible clinicians who exceed a MIPS score above an exceptional performance threshold
➢ A MIPS score of 70+ in the transition years will earn this bonus
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2017 2018 2019 2020
Quality Reporting 90 days Full year Full year Full year
ACI & CPIA Reporting 90 days 90 days TBD Full year
CEHRT Edition Required 2014 2015 for higher score
2015 2015
MIPS Performance Threshold
3 15 Mean Mean
Exceptional Performance Threshold
70 70 Derived from PT
Derived from PT
Floor for MIPS Quality measures
3 3 0 0
Quality Weighting 60% 60% 30% 30%
Cost Weighting 0% 0% 30% 30%
Max. Negative Adjustment
-4% -5% -7% -9%
Max. Positive Adjustment(Estimated)
+0.8% +1% +7% +9%
MIPSPhase-In
MIPS Payment Adjustments in the First 4 Years
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You have to learn the rules of the game. And
then you have to play better
than anyone else.Albert Einstein
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The MIPS Composite Performance Score
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Diagram Legend
PT – Performance Threshold
The mean or median of all MIPS composite
scores for the performance year nationwide
APT – Additional Performance Threshold
The 1st quartile of MIPS composite scores
above the PT or
the MIPS composite score corresponding to
the 1st quartile of participants above the PT
25% of PT
1st quartile of MIPS composite scores below
the PT
SF – Scaling Factor
A factor calculated to ensure that MIPS
payment adjustments stay budget neutral
AAF – Additional Adjustment Factor
Used to calculate the exceptional
performance bonus budgeted for $500M
total nationwide per year
Participant “Grades”
A – meets or exceeds the APT; receives a positive adjustment proportional to score plus an exceptional performance bonus
B – exceeds the PT but is below the APT; receives a positive adjustment proportional to score, no exceptional performance bonus
C – exactly at the PT; receives zero payment adjustment
D – below the PT but above 25% of PT; receives a negative payment adjustment proportional to score
F – in bottom 25% below PT; receives maximum negative payment adjustment
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Participant “Grades”
A – meets or exceeds the APT; receives a positive adjustment proportional to score plus an exceptional performance bonus
B – exceeds the PT but is below the APT; receives a positive adjustment proportional to score, no exceptional performance bonus
C – exactly at the PT; receives zero payment adjustment
D – below the PT but above 25% of PT; receives a negative payment adjustment proportional to score
F – in bottom 25% below PT; receives maximum negative payment adjustment
Diagram Legend
PT – Performance Threshold
The mean or median of all MIPS composite
scores for the performance year nationwide
APT – Additional Performance Threshold
The 1st quartile of MIPS composite scores
above the PT or
the MIPS composite score corresponding to
the 1st quartile of participants above the PT
25% of PT
1st quartile of MIPS composite scores below
the PT
SF – Scaling Factor
A factor calculated to ensure that MIPS
payment adjustments stay budget neutral
AAF – Additional Adjustment Factor
Used to calculate the exceptional performance
bonus budgeted for $500M total nationwide
per year
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MIPS Reimbursement:
Every Performance Point Will Count
Year 2016 (VM) 2017 & 2018
MIPS Transition
Year
MIPS in 2019 &
Later Years
Description · Top 5% of Quality
and/or Cost get +
payment adjustment
· Bottom 5% get -
payment adjustment
Minimum reporting
for one of:
1. Quality (PQRS)
2. Improvement
Activities
3. ACI
Payment adjustments
depend linearly on
performance:
1. Quality
2. Cost
3. Improvement
Activities
4. ACI
Most Providers Get no payment
adjustment
Will avoid a negative
payment adjustment
Will get a payment
adjustment
Payment
Adjustment +
Very few Very small
Depends on
performancePayment
Adjustment -
Very few Very few
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MIPS ACI(Advancing Care Information) Performance
