2017 Transition Year Flexibility Improvement Activities Category Options

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1 The Physicians Advocacy Institute s Medicare Quality Payment Program (QPP) Physician Education Initiative 2017 Transition Year Flexibility Improvement Activities Category Options 1 P a g e Ad

2 MEDICARE QPP PHYSICIAN EDUCATION INITIATIVE 2017 Transition Year Flexibility Improvement Activities Category Options What is the Quality Payment Program? 2017 serves as a transition year for the MACRA Quality Payment Program (QPP) during which physicians have the flexibility to select the level of participation that best suits their practices. Under the QPP, physicians may choose to participate in an Advanced Alternative Payment Model (APM) or submit data to the Merit-Based Incentive Payment System (MIPS). MIPS is a new program that consolidates and sunsets the previous quality reporting programs, including the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM), and the Electronic Health Records (EHR) Incentive program (Meaningful Use), into one program. In 2017, MIPS has four weighted performance categories: quality (60%), based on PQRS; cost (0%), based on VM; advancing care information (25%), based on Meaningful Use; and improvement activities (15%), new category not based on a previous program Category Weights for MIPS Score ACI 25% Improvement Activities 15% Quality 60% Quality Improvement Activities ACI 2 P a g e

3 This resource provides guidance for the improvement activities category, which is not based on any previous CMS quality reporting programs, but instead, is a new category that rewards physicians and practices for engaging in clinical practice improvement activities. What are improvement activities? The improvement activities category is a new performance category not based on previous Medicare value or quality initiatives. In general, improvement activities are activities that improve clinical practice or care delivery that are likely to result in improved outcomes. In 2017, there are 92 improvement activities to choose from that are eligible for MIPS credit. What are my options for the improvement activities category? Avoid a Negative Payment Adjustment? Eligible for a Positive Payment Adjustment? Length of the Reporting Period No Participation Test Participation Partial Year Participation Full Year Participation No Yes Yes Yes No N/A No N/A Yes (eligible for maximum adjustment) Up to 4 improvement activities for a minimum 90-day reporting period Yes (eligible for maximum adjustment) Up to 4 improvement activities for a minimum 90-day reporting period By selecting test, partial, or full year participation option in 2017, physicians can avoid a -4% payment adjustment of their Medicare Part B fee-for-service (FFS) claims in However, only those physicians who participate using the partial or full year options will also be eligible to receive a positive payment adjustment of their Medicare Part B FFS claims in Test Participation Submit something and avoid a penalty The threshold for avoiding a negative payment adjustment through the Test option is extremely low, and physicians are highly encouraged to at least participate using this option. Physicians who submit just a minimum amount of data will receive a neutral payment adjustment and avoid a negative payment adjustment of their Medicare Part B FFS payments. Under this option, the minimum threshold for the Improvement Activities option is to submit 1 improvement activity regardless of its assigned weight. There are no restrictions on the type of 3 P a g e

4 improvement activity that can be reported, so you may select any of the 92 improvement activities identified by the Centers for Medicare and Medicaid Services (CMS). Partial and Full Year Participation Submit data for at least 90 days to be eligible for a positive payment adjustment With the partial and full year participation option, physicians are required to report that they completed up to four improvement activities for at least 90 consecutive day each within the 2017 calendar year. With both of these options, physicians can avoid the negative payment adjustment and be eligible to receive the maximum positive payment adjustment. The improvement activities category thresholds for the partial year and full year participation options are as follows: For solo practitioners, groups of 15 or fewer eligible clinicians*, nonpatient facing physicians, and/or physicians in a rural area or health professional shortage area (HPSA) For groups more than 15 eligible clinicians* Report any combination of medium and high weight activities to achieve 40 points Report any combination of medium and high weight activities to achieve 40 points Medium weight activities = 20 points each Medium weight activities = 10 points each High weight activities = 40 points each High weight activities = 20 points each Can be reported via: Attestation, qualified clinical data registry (QCDR), qualified registry, electronic health record (EHR) Can be reported via: Attestation, QCDR, qualified registry, EHR, CMS Web Interface (groups of 25 or more eligible clinicians) * For 2017, eligible clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. What improvement activities should I report? 4 Page

5 It is likely that you are already performing at least one improvement activity in your practice but may be calling it by a different name. It is recommended that you review the list of 92 activities and select at least one (for test participation) or more activities (for partial and full year participation) that are already applicable to your practice. There are 9 subcategories of improvement activities: Expanded Practice Access Population Management Care Coordination Beneficiary Engagement Patient Safety and Practice Assessment Achieving Health Equity e.g., same day appoitnments for urgent needs, or after-hours access to advice or services e.g., monitoring health conditions to provide timely interventions, or participation in a QCDR e.g., timely communication of test results or exchange of clinical information to patients e.g., establishing care plans for individual with complex care needs, patient self-management assessment and training e.g., using clinical or surgical checklists and practice assessments related to maintaining certification e.g., achieving high qaulity for underserved populations Emergency Response and Preparedness Behavioral and Mental Health Participate in an APM e.g., participation on Disaster Medical Assistance Team e.g., integrating behavioral health with primary care to address substance use disorders or other health conditions e.g., participating in an ACO We recommend narrowing the list of activities by the subcategories that may be the most applicable to your practice and patient population. However, you are not required to perform activities in each subcategory or select activities from a certain number of subcategories in order to receive the highest possible score. Then, visit the CMS QPP website at 5 P a g e

6 On this page, filter the 92 improvement activities by the subcategory that you are interested in. Note, only apply one subcategory filter at a time to filter the appropriate list of activities. Once you select the subcategory, expand on the specific activity you are interested in to see the weight and description for the activity (see screenshot on next page). 6 P a g e

7 Activity Description For additional information on the activity and type of documentation required for each activity for audit purposes, please see CMS s MIPS Data Validation Criteria 2017 document. This document is available on the Education & Tools Tab 1 of the QPP website P a g e

8 What exactly do I need to report? How and by when? You have several options for reporting the improvement activities category data: If you report the improvement activities category using the attestation option through the CMS portal, you do not need to submit data on the specific activities to CMS, but you will need to attest yes to each activity that you performed. This option is available to you at no cost by CMS. It is recommended that you retain documentation supporting your attestation for at least 10 years for audit purposes. CMS will make information on how to attest using the CMS QPP website in coming months. If you report the improvement activities category using a qualified registry, QCDR, EHR technology, or the CMS Web Interface, these intermediaries may have specific data submission requirements for each activity, and these intermediaries will need to certify to CMS that you performed the activities as indicated. It is recommended that you contact the vendor for the reporting mechanism you elect and ask them about their capabilities and fees for reporting the improvement activities category to CMS on your behalf. Again, it is recommended that you retain documentation supporting your attestation for at least 10 years for audit purposes. The deadline to report your activities for the improvement activities category is March 31, Where can I go for more information? For additional information on the improvement activities category, please see PAI QPP Tutorial #3 on the ACI and improvement activities categories, available on the video library page, and other resources available on PAI s QPP website. Additional information is also available on the CMS QPP website: For a list of improvement activities please visit: A MIPS Improvement Activities Fact Sheet is also available here: 8 P a g e

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