Agenda. Surviving the New Program Requirements and the Financial Penalties Under MIPS 9/9/2016. Steps to take to prepare for MIPS

Transcription

1 Surviving the New Program Requirements and the Financial Penalties Under MIPS September 2016 Selena Hood Agenda Steps to take to prepare for MIPS Introduction and Evaluation of the Merit-Based Incentive Payment System (MIPS) Quality Category Resource Category Clinical Practice Improvement Activities Category Advancing Care Information Category Data Submission Payment Adjustment Surviving the payment penalties under MIPS 2 1

2 Survival Guide Things to think about NOW 3 Steps to take to prepare for MIPS: 1. Check your Medicare PQRS feedback reports. 2. Check your Medicare QRUR reports 3. Review proposed rule s list of Clinical Practice Improvement Activities (CPIA) 4. Review your place in the EHR Incentive program Do you have a CEHRT, were you exempt last program year? 5. General Considerations Determine your Medicare status, do you plan to report as an individual or group, are you a non-patient facing EC? 6. Alternative Payment Models Confirm whether you are participating in an APM. If not, check with your specialty society to see if there's and opportunity. 7. How do you plan to submit data? 8. Make sure you submit data! If you do not submit data, the law requires CMS to give a zero performance score and a negative payment adjustment (-4% for 2019) 9. Understand the Proposed Rule. 4 2

3 New Payment Tracks For Provider Groups: The Merit-Based Incentive Payment System (MIPS) 5 Introduction to MIPS MIPS is a new program Streamlines three currently independent programs to work as one and to ease clinician burden Adds a fourth component to promote improvement and innovation to clinical activities MIPS provides clinicians the flexibility to choose the activities and measure that are most meaningful to their practice to demonstrate performance 6 3

4 Who Will Participate in MIPS MIPS eligible clinicians replaces the previous use of Eligible Professional (EP) Years 1 and 2 Physicians (MD/DO and DMD/DDS), PAs, NPs, Clinical nurse specialists, Certified registered nurse anesthetists. Years 3+ Physical or occupational therapists, Speech-language pathologists, Audiologists, Nurse midwives, Clinical social workers, Clinical psychologists, Dietitians/Nutritional professionals. 7 Who will NOT Participate in MIPS FIRST year of Medicare Part B participation Below low patient volume threshold Certain participants in ADVANCED Alternative Payment Models Medicare billing charges less than or equal to $10,000 and provides care for 100 or fewer Medicare patients in one year. Note: MIPS does not apply to hospitals or facilities 8 4

5 MIPS: Eligible Clinicians Eligible Clinicians can participate in MIPS as an: Individual Group An individual is a define as a unique NPI or TIN. (Same as before) A group is 2 or more, as defined by taxpayer identification number (TIN), would be assessed across all four MIPS performance categories. Virtual groups will not be implemented in year 1 of MIPS. 9 MIPS Period All MIPS performance categories are aligned to a performance period of one full calendar year. Goes into effect Jan. 1, 2017 (2017 performance period, 2019 payment year) Period Payment Year 10 5

6 MIPS Categories A single MIPS composite performance score will factor in 4 weighted performance categories on a point scale MIPS Composite Score (CPS) 11 Year 1 Category Weights for MIPS Resource Use 10% Clinical Practice Improvement activities 15% Quality 50% Advancing Care Information 25% 12 6

7 MIPS: Category Scoring 13 MIPS: Quality Category 14 7

8 MIPS: Quality Category Summary: Selection of 6 measures 1 cross-cutting measure and 1 outcome measure, or another high priority measure if outcome is unavailable Select from individual measures or a specialty measure set Population measures automatically calculated Year 1 weight: 50% 15 Key Changes from Current Program (PQRS) Scoring Base Score PQRS Quality Category Report all required measures to Report all required measures. avoid payment adjustment Credit received for those Bonus Points Composite measures that meet the data Score completeness Score threshold Data Submission Criteria Required 9 measures across 3 NQS domains Face-to-face Encounter Consumer Assessment of Healthcare Providers and Systems (CAHPS) Requirement 1 encounter required for the cross-cutting measure requirement CAHPS required for groups with 100 or more EPs Requires 6 measures; no NQS domain requirement 25 or less encounters required for cross-cutting requirement CAHPS no longer required for groups of 100 or more, bonus points for submitting survey MAV Secondary outcome to determine successful reporting Yet to be determined. Open for comments. 16 8

9 Assigning Points Based on Deciles 0% 7% 16% 23% 36% 41% 62% 69% 79% 85% 100% 17 Assigning Points Based on Deciles Benchmark Deciles Benchmark Ranges Points Scored (Hypothetical) 1 0% 6.9% % 15.9% % 22.9% % 35.9% % 40.9% % 61.9% % 68.9% % 78.9% % 84.9% % 100% McKesson Corporation Confidential and Proprietary 9

10 Converting Measure to Points Based on Deciles Eligible clinicians with performance in the top decile will receive the maximum 10 points. Eligible clinicians who do not report enough measures will receive 0 points for each measure not reported, unless they could not report these measures due to insufficient applicable measures. 19 Quality Category Score: Bonus Points Up to 10% extra credit total in bonus points. Additional high priority measure (up to 5% of possible total) 2 bonus points award for additional outcome/patient experience 1 bonus point for the other high priority measures CEHRT Bonus (up to 5% of possible total) 1 bonus point for each measure reported using CEHRT for end-to-end electronic reporting Not available for claims 20 10

11 Scoring: Quality Category Each measure is converted to points (1-10) Zero points for a measure that is not reported Bonus for reporting additional outcomes, patient experience, appropriate use, patient safety Bonus for EHR reporting Total points Total points Total possible points Quality Category Score 21 MIPS: Resource Use Category 22 11

12 MIPS: Resource Use Category Summary: Assessment under all available resource use measure, as applicable to the clinician CMS calculates based on claims so there are no reporting requirements for clinicians Key changes from Current Program (Value-Based Payment Modifier): Adding 40+ episode specific measures to address specialty concerns Year 1 Weight: 10 points Note: No additional submission requirements 23 Key Changes from Current Program (Value Modifier) Value Modifier 6 measures: Base Score Score Total per capita costs for all attributed beneficiaries, Proposed MIPS Resource Use Category 2 of Bonus the 6 Points VM measures: Composite Score Total per capita costs for all attributed beneficiaries, 24 Medicare Spending per Beneficiary (MSPB), Total per capita cost measures for the four condition-specific groups (chronic obstructive pulmonary disease, congestive heart failure, coronary artery disease, and diabetes mellitus). Attribution to the group practice (TIN) Medicare Spending per Beneficiary (MSPB), Removes total per capita cost measures for the four condition-specific groups. Attribution to group (TIN) or individual (TIN/NPI) Proposes up to 41 other episode based measures 12

13 Proposed Clinical Episode Groups 25 Scoring: Resource Use Category Example Each measure is converted to points (1-10)) Minimum Case Volume (20 including for MSPB) Total Points Total Points Total Possible points Quality Category Score 26 13

14 MIPS: Clinical Practice Improvement Activity (CPIA) Category 27 MIPS: Clinical Practice Improvement Activity Category Summary: Minimum selection of one CPIA activity (from 90+ proposed activities) with additional credit for more activities Full credit for patient-centered medical home Minimum of half credit for APM participation Key changes from current program: Not applicable (new category) Year 1 weight: 15 points The more activities completed, the more points are rewarded to the clinician Examples: care coordination, safety checklist, and after hours care 28 14

15 CPIA Category 29 Subcategories of Clinical Practice Improvement Activities Base Score Score Bonus Points Composite Score 30 Subcategories are specified in MACRA Three additional subcategories are proposed in the NPRM 15

16 CPIA Scoring Overview In general: Each activity in the CPIA activity list is worth a certain number of points Most are worth 10 points (medium weight) Some activities have high weight, and are worth 20 points To get maximum credit, must achieve 60 points Can be achieved by selecting any combination of activities: High-and medium-weight All high-weight All medium-weight activities Special scoring considerations for specific types of eligible clinicians and groups are discussed later. 31 Scoring: CPIA Category Example Total points for high-weight activities Total points for medium-weight activities Total CPIA Points Total CPIA Points Total Possible points CPIA Category Score 32 16

17 MIPS: Advancing Care Information Category 33 MIPS: Advancing Care Information Category Summary: CEHRT required Key changes from current program (EHR Incentive): Eliminated Clinical Provider Order Entry and Clinical Decision Support objectives Reduced the number of required public health registries to which clinicians must report Year 1 Weight: 25 points 34 17

18 Changes from EHR Incentive Program to Advancing Care Information 35 Past Requirements fro the Medicare EHR Incentive Program One-size-fits-all-every objective reported and weighed equally Requires across-the-board levels of achievement or thresholds, regardless of practice or experience Measurements emphasizing process Disjointed and redundant with other Medicare reporting programs No exemptions for reporting New Proposal for Advancing Care Information Category Customizable clinicians can choose which categories to emphasize in their scoring Flexible. Allows for diverse reporting that matches clinician s practice and experience. Measurement emphasizing patient engagement and interoperability Aligned with other Medicare reporting programs. No need to report redundant quality measures. Exemptions for reporting for clinicians. Advanced alternative payment model First year with Medicare Have low Medicare volumes Who can participate Similar exclusions will carry over from EHR incentive. Hardship exceptions

19 MIPS: Advancing Care Information Category CMS Proposes six objectives and their measures that would require reporting for the base score: 37 MIPS Advancing Care Information Category Base Score: The base score accounts for 50 points of the total Advancing Care Information category score. To receive the base score, physicians and other clinicians must simply provide the numerator/denominator or yes/no for each objective and measure

20 MIPS: Advancing Care Information Category Score: The performance score accounts for up to 80 points towards the total Advancing Care Information category score. Physicians select the measures that best fit their practice from the following objectives, which emphasize patient care and information access: 39 Advancing Care Information Break Down The performance category score is capped at 100 percentage points (out of a possible 131 percentage points). 50 percentage points for the base score, which consists of: Reporting privacy and security Reporting a numerator/denominator or yes/no statement for each measure as required Note: for numerator/denominator measures, ECs must report at least a one in the numerator; for yes/no statement measures, ECs must report a yes for credit. 80 percentage points for the performance score, which is determined based on achievement above the base score requirements for three objectives: Patient Electronic Access, Coordination of Care Through Patient Engagement, Health Information Exchange 1 bonus percentage point for Public Health and Clinical Data Registry Reporting 40 20

21 MIPS: Advancing Care Information Category Example Scoring: Base Score + + = Score Bonus Points Composite Score Account for 50 points of the total Advancing Care Information Category Score Account for 80 points of the total Advancing Care Information Category Score Up to 1 point of the total Advancing Care Information category score Earn 100+ pts receive Full 25 points in the Advancing Care Information Category of MIPS composite score The overall Advancing Care Information score would be made up of a base score and a performance score for a maximum score of 100 points. 41 Scoring: Advancing Care Information Category Base Score 50 points Privacy and Security Score 80 points Electronic Access, Care Coordination, Health Information Exchange Bonus for Public Health and Clinical Data Registry Reporting Total Points Total Points Total Possible points Advancing Care Category Score 42 21

22 MIPS: Data Submission Options McKesson Corporation Confidential and Proprietary 22

23 MIPS: Payment Adjustment 45 How much can MIPS adjust payments? Based on a CPS, clinicians will receive +/- or neutral adjustment up to the percentage below. MIPS will be a budget-neutral program. Total upward adjustment could reach 3x the potential adjustment

24 Composite Score In review 47 This is a test Footer Unified Scoring Principles 10 point scoring system Actionable and transparent data. Eligible clinicians will know in advance what they need to do to perform well. Moves away from all-or-nothing scoring Receive scores for submitted information. at any level would help improve the CPS Zero scores for any required items that are not submitted No improvement scoring for year

25 Scoring Rules for each category 49 Relationship between CPS and Payment 50 25

26 Example Threshold = Scoring: Quality Category Each measure is converted to points (1-10) Zero points for a measure that is not reported Bonus for reporting additional outcomes, patient experience, appropriate use, pt safety Bonus for EHR reporting Total Points Dr. Smith has 40.2 points based on performance She qualifies for 1 bonus point for reporting an additional high priority measure She gets 1 bonus points for using their EHR to report quality She gets 42.2 total points Total Points Total Possible points Quality Category Score 42.2 Total points 80 total possible points 52.8% Quality Score 52 26

27 Scoring: Resource Use Category Example Each measure is converted to points (1-10) Minimum Case Volume (20 including for MSPB) Total Points Dr. Smith has 16.3 points based on performance 4 measures with minimum case volume She gets 16.3 total points Total Points Total Possible points Quality Category Score 16.3 Total points 40 total possible points 40.8% RU Score 53 Scoring: CPIA Category Example Total points for high weight activities Total points for medium weight activities Total CPIA Points Dr. Smith completes 1 high weight activities (earning her 20 points) She also completes 2 medium weight activities (earning her 20 points) She gets 40 total points Total CPIA Points Total Possible points CPIA Category Score 40 Total points 60 total possible points 66.7% CPIA Score 54 27

28 Scoring: Advancing Care Information Category Base Score 50 points Privacy and Security Score 80 points Electronic Access, Care Coordination, Health Information Exchange Bonus for Public Health and Clinical Data Registry Reporting Total Points Dr. Smith has 36.2 points for her base score An additional 40 points for performance She gets 1 bonus point She gets 77.2 total points Total Points Total Possible points Advancing Care Category Score 77.2 Total points 100 total possible points 77.2% ACP Score 55 CPS Calculations The final Score 56 28

29 Composite Score Score Weight Weighted Score Category Quality 52.8% 50% % x 50% = 26.4 Resource Use 40.8% 10% % x 10% = 4.1 CPIA 66.7% 15% % x 15% = 10 Advancing Care 77.2% 25% 19.3 Information 77.2% x 25% = 19.3 Composite Score (Subtotal x100) 59.8 points 57 Survival Guide Things to think about AFTER 58 29

30 Value-Based Reimbursements 1. Explore the requirements for qualifying as a patient-centered medical home. 2. Look at partnerships and collaboration 3. Work to ensure that incentives align with quality rather than quantity. 4. Review and understand your failures. 5. Enlist QR or QCDR reporting 6. Optimize clinical practice and care delivery 7. Reduce Waste 8. Revenue enhancements 9. Technology 59 Thank You 60 30

31 Appendix 1. CMS Quality Payment Program Assessment-Instruments/Value-Based-Programs/MACRA-MIPSand-APMs/Quality-Payment-Program.html 2. AMA (American Medical Association) MACRA Checklist: Steps You Can Take Now to Prepare 3. Health Catalyst Why you Need to Understand Value-Based Reimbursements and How to Survive it 4. MGMA Value-Based Payment Modifier Resource Center 61 McKesson Corporation Confidential and Proprietary 31