Quality Payment Program

Quality Payment Program - 2018 Lauren O Kipney Transformation Support Services Manager CORHIO Courtnay Ryan Sr. Quality Improvement Facilitator Telligen

CQPPC Mission Increase QPP awareness among Colorado health care providers using common messaging Organize education efforts Coordinate effective and efficient technical assistance for physician practices Web Page: http://www.cms.org/coqpp/ Follow Us on LinkedIn Search Colorado Quality Payment Program Coalition Five Fast Facts in Five Minutes

Learning Objectives Introduction to Quality Payment Program s two components: Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM), including eligibility and timelines. Deep dive into MIPS performance categories, including weights, category requirements and tips for success in using your EHR for reporting.

QPP Lingo MACRA = Medicare Access and CHIP Reauthorization Act This is not a part of the Affordable Care Act QPP = Quality Payment Program Advanced APM = Advanced Alternative Payment Model MIPS = Merit-Based Incentive Payment System

The Quality Payment Program Clinicians have two tracks to choose from: OR Advanced Alternative Payment Models (APMs) The Merit-based Incentive Payment System (MIPS) Source: Centers for Medicare and Medicaid Services (CMS)

What is the Merit-based Incentive Payment System? Combines legacy programs into single, improved reporting program PQRS VM EHR

Eligible Clinicians Physicians Physician Assistants Nurse Practitioners Clinical Nurse Specialists Certified Registered Nurse Anesthetists Medicare Part B Clinicians: Billing more than $90,000 a year AND Providing care for more than 200 Medicare patients a year Source: Centers for Medicare and Medicaid Services (CMS)

Who is excluded from MIPS? Newly enrolled in Medicare Below the lowvolume threshold Significantly participating in Advanced APMs Source: Centers for Medicare and Medicaid Services (CMS)

CMS Quality Payment Program Clinician Eligibility Tool For MIPS: www.qpp.cms.gov For Advanced APM: https://data.cms.gov/qplookup Source: Centers for Medicare and Medicaid Services (CMS)

QPP: Budget Neutral Competing against your peers **Adjustments affect base rate of pay** --Your gain will be another's loss and vice versa MACRA is here to stay Source: Centers for Medicare and Medicaid Services (CMS)

MIPS 2018 Timeline Performance year submit Feedback available adjustment 2018 Performance Year March 31, 2019 Data Submission Feedback January 1, 2020 Payment Adjustment Source: Centers for Medicare and Medicaid Services (CMS)

QPP Eligibility Example Example: Primary care clinician, Dr. A, bills $100,000 with 300 Medicare Part B Beneficiaries, in his second year of practice Does not participate in an APM Eligible for MIPS

The Merit-based Incentive Payment System Performance Categories Source: Centers for Medicare and Medicaid Services (CMS)

Performance Category Weights Weights assigned to each category based on a 1 to 100 point scale 25% + + + Quality 50 Cost 10 Improvement Activities 15 Promoting Interoperability 25 Note: These are defaults weights; the weights can be adjusted in certain circumstances Source: Centers for Medicare and Medicaid Services (CMS)

How did you perform in MIPS 2017? Did you report? How did you perform?

Performance Category: Quality Category Requirements Replaces PQRS and Quality portion of the value modifier Clinical Quality Measures (CQMs) Specialty measure sets available Over 300 measures to choose from Choose 6 measures (different if reporting GPRO) One high-priority/outcome measure CMS Benchmarks for CQMs

CQM Benchmarks Benchmarks vary based on reporting mechanisms. All Reporters (individuals and groups, regardless of practice or specialty size) use only one benchmark.

Registry/ QCDR Process EHR Process Claims Process Submission Method Measure Type Decile_3 Decile_4 Decile_5 Decile_6 Decile_7 Decile_8 Decile_9 Decile_10 TOPPED OUT Quality Example Measure: Controlling High Blood Pressure Measure ID: 236 58.02-63.90 63.91-68.36 68.37-72.91 72.92-76.91 76.92-81.65 81.66-86.95 86.96-94.06 >= 94.07 No 51.10-56.51 56.52-60.77 60.78-64.28 64.29-67.46 67.47-70.93 70.94-74.88 74.89-80.42 >= 80.43 No 56.36-62.91 62.92-67.53 67.54-70.68 70.69-73.78 73.79-77.45 77.46-82.12 82.13-88.58 >= 88.59 No

Where to Start Look at what clinical quality measures are available in your EHR/Registry Select 6 Measures Understand Workflow and Measure Pull Baseline Data Perform Data Validation

Quality Measures: Things to Consider Topped out measures Measures that have consistently high performance Very difficult to get full credit Specialist specific measures Recommend responding to CMS Call for Measures Measures that are topped out for two consecutive years can only earn up to 7 points Improvement bonus Bonus points for reporting an improved score compared to the following year

How to Improve Quality Set goals for each measure and create plan for improvement Share goals with staff Review and post data/progress at least monthly Share data in meaningful way

Quality Category Summary Quality is 50 points of your final score Select up to 6 measures Worth up to 10 points each Work to the top of license Dr. A submits for full year via EHR: Tobacco Screening Performance rate: 90%, Points Earned: 5.9 Depression Screening Performance rate: 60%, Points Earned: 8.5 High Blood Pressure Screening Performance rate: 50%, Points Earned: 10 BMI Screening Performance rate: 30%, Points Earned: 3.8 Closing the Referral Loop Performance rate: 50%, Points Earned: 6.6 Breast Cancer Screening Performance rate: 50%, Points Earned: 6.2 41/60 = 68.33% of 50 = 34.17 final points

Improvement Activities New Category: Attest to participation in activities that improve clinical practice Similar efforts to Maintenance of Certification (MOC) Part IV Examples: Shared decision-making, patient safety, coordinating care, increasing access, use of PDMP, TCPi

Improvement Activities Scoring Activity Weights Medium = 10 points High = 20 points 15% of Final MIPS score Maximum Points Available = 40

MIPS Scoring: Improvement Activities Maximum Points Available= 40 Points Full credit for clinicians in a patient-centered medical home (PCMH), Medical Home Model, or similar specialty practice model

Example: Improvement Activities Source: Centers for Medicare and Medicaid Services (CMS)

Improvement Activities Summary Activities to improve patient care and safety Similar to Maintenance of Certification Dr. A is part of a large practice, so no special consideration. Registered for Prescription Drug Monitoring Program (PDMP) Medium Weight Activity 10 points Consult the PDMP High Weight Activity 20 points Earned 30/40 points (75%) 75% of 15 final category points =11.25

Performance Category: Promoting Interoperability Ends and replaces the Medicare EHR Incentive Program (also known as Medicare Meaningful Use) Previously called Advancing Care Information category in 2017 Greater flexibility in choosing measures In 2018, there are 2 measure sets for reporting based on EHR edition: Promoting Interoperability Measures Transition Promoting Interoperability Measures Source: Centers for Medicare and Medicaid Services (CMS)

2015 CEHRT Upgrade Coming Practices need to contact vendor and ask when 2015 CEHRT is expected to be released Plan your reporting period around 2015 CEHRT upgrade You CAN report using 2014 CEHRT but.. Be aware many QPP measures will not be available until CEHRT upgrade

Performance Category: Promoting Interoperability Clinicians must use certified EHR technology to report EHR Certified to 2015 Edition ACI Objectives and Measures EHR Certified to 2014 Edition ACI Transition Objectives and Measures

Promoting Interoperability 2018 Transition Measure Set Base Measures (at least a 1 in numerator or yes) Security Risk Analysis e-prescribing Provide Patient Access (Patient Portal) Health Information Exchange

Promoting Interoperability 2018 Transition Measure Set Optional Measures Patient Portal View, Download, Transmit (VDT) Patient-Specific Education Secure Messaging Medication Reconciliation Immunization Registry Specialized Registry (bonus point) Syndromic Surveillance (bonus point)

Promoting Interoperability 25% of Final Score in Transition Year Earn up to 165% maximum score, which will be capped at 100% Promoting Interoperability category score includes: Required Base score (50%) Performance score (up to 90%) Bonus score (up to 25%) Keep in mind: You need to fulfill the Base score or you will get a zero in Promoting Interoperability Source: Centers for Medicare and Medicaid Services (CMS)

Promoting Interoperability Hardship Available (2018 ONLY) A MIPS-eligible clinician or group may submit a QPP Hardship Exception Application for specified reasons for review and approval. MIPS-eligible clinicians and groups may qualify for a reweighting of their advancing care information performance category score to 0 percent of the final score if they meet the criteria for hardship. For more information: https://qpp.cms.gov/mips/advancing-careinformation/hardship-exception

Promoting Interoperability Summary If you were already reporting for Meaningful Use, these are the same measures Earn base measures Hardship available Dr. A earns 50 base points Earns additional points for: Patient education (10) Medication Reconciliation (10) Patient Portal Use (5+5=10) Earns bonus points for: Reporting to Cancer Registry (5) Earns total of 85 points 85/100 points = 85% 85% of 25 final category points = 21.25 points

Cost Category 10% of final score in 2018 Clinicians assessed on Medicare claims data Previously assessed in Value Modifier Program and updated for MIPS Understand how the practice is performing? Quality Resource and Use Report Available from 2016 Feedback report for 2017 available July 1, 2018

Attribution Methodology Who is a patient attributed to? Primary Care Clinician More than one primary care clinician: Attributed to the primary care clinician that was seen the most or if equal, the clinician who billed the most No primary care visit Specialist with most number of billed visits or if equal, the specialist who billed the most Patient can only be attributed to one TIN

Cost Measures Medicare Spending Per Beneficiary (MSPB) Measure Based on episodes of care Episode = Hospitalization of attributed patient Includes 3 days prior to admission, hospitalization and 30 days post discharge 35 episodes required for reporting

Cost Measures Total Per Capita Cost (TPCC) Measure All Medicare Part A and Part B costs during the MIPS performance period for all attributed patients Measure considerations: Payment-standardized Annualized risk-adjusted Specialty-adjusted 20 episodes required for reporting

Cost Scoring Dr. A Score: Step 1: Get cost score TPCC Score: 8/10 MSPB Score: 6/10 Step 2: Combine scores and divide by possible points 8+6 = 14/20 = 0.7 = 70% Step 3: Convert to MIPS points 70% X 10 = 7 points

Bonuses Source: Centers for Medicare and Medicaid Services (CMS)

Bonuses Source: Centers for Medicare and Medicaid Services (CMS)

Performance Periods Promoting Interoperability Source: Centers for Medicare and Medicaid Services (CMS)

Creating a 2018 Reporting Plan

Dr. A Scoring Example Quality = 34.17 points Earn 41 of 60 points = 68.33% 50 points x 0.6833 = 34.17 points Cost = 7 points Earn 14 of 20 points = 70% 10 points x 0.70 = 7 points Improvement Activities = 11.25 points Earn 30 of 40 points = 75% 15 total points X 0.75 = 11.25 points Final Score = 73.67 = 21.25 points Promoting Interoperability Earn base 50 points and earn an additional 35 points for 85 points total Earn 85 of 100 points =85% 25 total points X 0.85 = 21.25 points

The Magic Number Source: Centers for Medicare and Medicaid Services (CMS)

How Can I achieve 15 Points? Report all required Improvement Activities. Meet theadvancing Care Information base score and submit 1 Quality measure that meets data completeness. Meet the Advancing Care Information base score, by reporting the 5 base measures, and submit one medium-weighted Improvement Activity. Submit 6 Quality measures that meet data completeness criteria.

Scoring Summary It s complicated Tools available to help with calculation Final adjustments and bonuses will be based on your peers performance Do what s right for you and your practice Remember your performance will be made available to the public

Ever-changing Requirements The Quality Payment Program changes frequently The information provided today is current Be aware of changes QPP requirements will increase over time, as well as the competition for the incentive Remember the program is budget neutral, so you will be compared to your peers

Lessons Learned from MIPS 2017 Enterprise Identity Data Management (EIDM) Accounts CMS Portal Invalid Files QRDA3 from EHR Do NOT wait until last minute

What Now? QPP Team Who will be responsible for all of this information and reporting? Work to the top of license, team effort Plan for reporting 2018 Know the facts Prepare

Tips Stay Informed Check the QPP Website Sign-Up for the CMS Newsletter Regularly review your data Include regular data validation You could be audited, expect it

Resources CMS Quality Payment Program Website https://qpp.cms.gov/ Information Videos (scroll to the bottom) https://www.cms.gov/medicare/quality-initiatives-patient- Assessment-Instruments/Value-Based-Programs/MACRA- MIPS-and-APMs/Quality-Payment-Program-Events.html CORHIO Transformation Support Services team offers MACRA/MIPS/QPP/APM assistance Medicaid EHR Incentive Program coordinator available for program assistance Email to info@corhio.org or go to www.corhio.org

Additional Support Resources

Open Discussion & Questions

Thank You! Lauren OKipney Transformation Support Services Manager CORHIO Colorado Regional Health Information Organization Cell: 315-396-8509 LOKipney@CORHIO.org Courtnay Ryan Sr. Quality Improvement Facilitator Telligen QIN-QIO Cell 720-612-3111 Courtnay.ryan@area-d.hcqis.org