By Elizabeth W. Woodcock, MBA, FACMPE, CPC

Transcription

1 By Elizabeth W. Woodcock, MBA, FACMPE, CPC

2 Elizabeth W. Woodcock, MBA, FACMPE, CPC Speaker, Author, Trainer MBA, Wharton School of Business, University of Pennsylvania BA, Duke University Fellow, American College of Medical Practice Executives Certified Professional Coder Author, 16 textbooks and more than 500 Articles Founder and Principal, Woodcock & Associates Former Consultant, Medical Group Management Association; Group Practice Services Administrator, University of Virginia Health Services Foundation; Former Senior Associate, Health Care Advisory Board 2

3 By Elizabeth W. Woodcock, MBA, FACMPE, CPC

4 Merit-based Incentive Payment System Advancing Care Information Clinical Practice Improvement Activity 4

5 Medicare Access to Care and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program Merit-based Incentive Payment System Advancing Care Information Clinical Practice Improvement Activities Conclusion Q&A Period 5

6 CMS Proposed Rule May 9, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models 6

7 DocFix Replaced the Flawed SGR Formula with Small, Flat Increases Merit-based Incentive Payment System 7

8 0.50% (0.51%) (0.01%) Law Actual Exception Q1 had a 0.5% rate increase 8

9 CO104 Managed Care Withholding CO237 Legislated Regulatory Penalty CARC CO253 Adjustment code for mandated Federal, State or Local law/regulation CARC=Claim adjustment reason code 9

10 DocFix Replaced the Flawed SGR Formula with Small, Flat Increases Merit-based Incentive Payment System 10

11 CONSOLIDATION OF CURRENT LAW PERFORMANCE PROGRAMS [MU, PQRS, VBPM] 1. Develop a methodology for assessing the total performance of each MIPS eligible professional according to performance standards 2. Using such methodology, provide for a composite performance for each such professional 3. Use such composite performance score of the MIPS eligible professional determine and apply a MIPS adjustment factor MIPS eligible professional does not include an eligible professional who is a qualifying APM participant. 11

12 1 Quality 2 Resource Use 3 Meaningful use 4 Clinical Practice Improvement Activities Composite Score 12

13 Adjusted Medicare Part B Payment to Clinician [ based on a MIPS Composite Performance Score ] +4% +5% +7% +9% Potential for 3x Adjustment -4% -5% -7% -9% 13

14 2015 Performance Year erx PQRS EHR VBPM+ Total % % % % % % % -1.0% -1.0% -5.5% % -2.0% -2.0% -8.0% % -3.0% -4.0% -9.0% % up to -5% -4.0% up to -11% 14 Applied to all Medicare reimbursement +\Table reports maximum penalty. 14

15 CMS Proposed Rule May 9, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models 15

16 1. Advanced Alternative Payment Model (APM) Participant 2. Everyone Else Merit-based Incentive Payment System 16

17 1. Shared Savings Program (Tracks 2 and 3) 2. Next Generation ACO Model 3. Comprehensive ESRD Care (CEC) (large dialysis organization arrangement) 4. Comprehensive Primary Care Plus (CPC+) 5. Oncology Care Model (OCM) (two-sided risk track available in 2018) 17

18 First Year Medicare Participant Low Medicare Volume during the performance period, have Medicare billing charges less than or equal to $10,000 and provide care for 100 or fewer Part B-enrolled Medicare beneficiaries. - CMS 18

19 Will replace PQRS, VBPM and MU! Every eligible clinician will be assigned a composite score Category Yr 1 (2019) Yr 2 (2020) Quality 50% 45% 30% Meaningful Use* 25% 25% 25% Resource Use 10% 15% 30% Clinical Practice Improvement 15% 15% 15% *MU weight can decrease to 15% if adoption reaches 75%; the weight would then be redistributed to another category. 19

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21 2-Year 21

22 Performance Category Quality: Clinicians choose 6 measures to report to CMS that best reflect their practice. One of these measures must be an outcome measure or a high-value measure and one must be a crosscutting measure. Clinicians also can choose to report a specialty measure set. Advancing Care Information: Clinicians will report key measures of interoperability and information exchange. Clinicians are rewarded for their performance on measures that matter most to them. Clinical Practice Improvement Activities: Clinicians can choose the activities best suited for their practice; the rule proposes over 90 activities from which to choose. Resource Use: CMS will calculate these measures based on claims and availability of sufficient volume. Clinicians do not need to report anything. Maximum Possible Points per Performance Category 80 to 90 points, depending on group size Percentage of Overall MIPS Score (Performance Year ) 50% 100 points 25% 60 points 15% Average score of all cost measures that can be attributed 10% 22

23 All MIPS Eligible Clinicians Optional for 2017 Nurse Practitioners, Physician Assistants, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists If a group is submitting information collectively, then it must be measured collectively for all four MIPS performance categories. - CMS 23

24 90% or more in inpatient (21) or emergency department (23) place of service (POS) 24

25 Insufficient Internet Connectivity Extreme and Uncontrollable Circumstances Lack of Control over the Availability of certified EHR technology Lack of Face-to-Face Patient Interaction 25

26 Base Score 50 Points Performance Score 80 Points Bonus Point 1 point 100+ points = the full 25 points for ACI 26

27 Security Risk Analysis Required Patient Electronic Access Coordination of Care through Patient Engagement Public Health; Clinical Data Registry Health Information Exchange erx - Base Score 50 pts - 27

28 Does not reflect alternate proposal. 28

29 - Performance Score 80 pts - Patient Electronic Access Coordination of Care through Patient Engagement Health Information Exchange - Bonus Point 1 pt - Public Health; Clinical Data Registry 29

30 Maximum = 80% 30

31 Full Credit for ACI Category 31

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33 Clinical Decision Support Computerized Provider Order Entry CQM = Clinical Quality Measures 33

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35 High 20 Points Medium 10 Points 35

36 1. Expanding practice access 2. Population management 3. Care coordination 4. Beneficiary engagement 5. Patient safety and practice assessment 6. Achieving health equity 7. Integrated behavioral and mental health 8. Emergency preparedness and response 36

37 Collection of patient experience data on access to care and development of an improvement plan... Performance of regular practices that include providing specialist reports back to the referring clinician to close the referral loop Timely communication of test results defined as timely identification of abnormal test results with timely follow-up. Implementation of regular care coordination training. Track patients referred to specialist through the entire process. Access to an enhanced patient portal that provides up to date [clinical] information and includes interactive features allowing patients to enter health information and/or enables bidirectional communication about medication changes and adherence. 37

38 20 points: Evening and weekend hours 10 points: Participation in a registry 10 points: Reminders to alert and educate patients about services due 10 points: Timely communication of test results points 38

39 Full Credit for CPIA Category 39

40 A Few More 20 points: Seeing new and follow-up Medicaid patients 10 points: Referral communication management 10 points: Regular care coordination training 10 points: Implementation of fall screening 10 points: Regular assessment of patient experience (surveys) 40

41 No minimum hours the activity must be performed for at least 90 days during the performance period to receive credit 41

42 Activities, if 15 or less MIPS eligible clinicians Rural or HPSA Non-patient facing 42

43 Patient-Centered Medical Home Patient-Centered Specialty Practice (or any Official Designated Medical Home) % Credit for ACO Participation 43

44 ACI Maintain efforts to report MU in 2017, recognizing switch to 365 days CPIA Review list; choose 8 to 10 activities get started 44

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46 Question & Answer Session 46

47 Elizabeth W. Woodcock, MBA, FACMPE, CPC Woodcock & Associates Speaker, Trainer, Author Atlanta, Georgia These handouts may not be reproduced without the written consent of the speaker. 47

48 Appendix: Clinical Practice Improvement Activities Source: Provided by Woodcock & Associates Page 1

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