Registering for PQRS reporting and understanding implications and proposed policies for the Value Based Payment Modifier

Live Webinar 7/24/2013 Registering for PQRS reporting and understanding implications and proposed policies for the Value Based Payment Modifier Presenters: Sabrina Ahmed Sheila Roman Tonya Smith Michael Wroblewski

POLICY STATEMENT ANTITRUST (as approved by the MGMA/MGMA Center for Research/MGMA Realty Corp. Board of Directors February 23, 2007) General Framework Medical Group Management Association ( MGMA ), MGMA Center for Research and MGMA Realty Corp. (collectively the Associations ), continuously seek to advance the management of medical group practices in order to improve the delivery of health care. The Associations neither intend to nor play any role in the competitive behavior or decision-making of their membership, their members groups or the vendors supplying products or services thereto, nor in any way act to restrict competition among such members, groups or vendors. Through conferences, educational presentations and other activities, the Associations bring together their members and a wide variety of other stakeholders in the health care industry. Although the subject matter of such activities is generally technical in nature, and there is no purpose or intent to restrain competition in any manner, the Boards of Directors of the Associations nonetheless recognize the possibility that such activities could be characterized by some as an opportunity for anti-competitive conduct. For this reason, the Associations Boards take the opportunity, through this Policy Statement, to make clear these bodies unequivocal support for the policy of competition embodied in the antitrust laws and the Associations uncompromising intent to comply strictly in all respects with those laws. In addition to the strong commitment of the Associations to these underlying principles of competition, the penalties which may be imposed are so severe that good business judgment demands that every effort be made to avoid such violations. The Boards recognize that certain violations of the Sherman Act, such as price fixing, are felony crimes for which offenders may be imprisoned and/or subjected to substantial fines. In addition, treble damage claims by private parties for antitrust violations are expensive to litigate and can result in judgments of a magnitude which could seriously affect the financial interests of the Associations and their membership. It shall therefore be the obligation of every member affiliated with the Associations and all vendors who may transact or seek to transact business with the Associations or their membership to be guided by this policy mandating strict compliance with the antitrust laws. It shall also be the obligation of the Associations directors, officers and responsible staff members to insure that this policy is known and adhered to in the course of activities pursued under their leadership and guidance. Antitrust Compliance Principles: An Overview To assist the Associations officers, directors and staff in recognizing situations which may raise the appearance of an antitrust issue, the following points may be especially relevant to certain Association activities, and are presented for background information and education. Recognizing that the antitrust laws are complicated and it can be unclear whether particular conduct may unreasonably restrain trade, it may be necessary for the Associations to consult with legal counsel regarding any particular situation. In this vein, the Associations encourage any affected person to contact the Chair of MGMA or the Association s President/CEO if there are questions regarding compliance. Association activities and communications must not be used to promote or arrange for any agreement among competitors regarding sensitive terms such as prices, fees, terms and conditions of sale, discounts and/or allocation of territories or customers. In particular, serious violations of law can result from concerted agreements, whether explicit or indirect, which fix or stabilize medical group prices, fees or reimbursement levels. Association activities and communications must not be used to facilitate agreements regarding whether or not to enter into managed care contracts or the terms of managed care participation, or regarding medical groups basic decision whether or not to transact business with a particular insurance company or health plan. Such collective behavior can subject the participants to serious antitrust liability as a group boycott or otherwise.

Special care should be exercised regarding activity involving the exchange, collection and/or dissemination of data by competitors regarding prices or pricing methodology, as well as the cost of wages paid or other goods or services sold or purchased. As industry leaders in the collection and distribution of important health care information, the Associations have an important interest in assuring that all such activities and communications be conducted properly and lawfully. Particular caution must be exercised in collecting and distributing fee, reimbursement and salary levels to avoid characterization of such activities as an unlawful restraint of trade, especially if the data might be alleged to encourage unlawful concerted activity among competitors. It is very important that a legitimate, pro-active compliance strategy be implemented, based upon consultation with legal counsel, before undertaking such conduct under the rubric of Association business or otherwise. The foregoing points are a non-exhaustive outline of several important areas of antitrust concern for the Associations and their members. A variety of other compliance issues can and do arise from time to time, and must also be addressed on a case-by-case basis to promote adherence to the important legal requirements addressed in this Policy Statement.

About our presenters: Sabrina Ahmed, Health Insurance Specialist, Physician Feedback and Value Based Payment Modifier team Sheila Roman, MD, MPH, Medical Officer, Physician Feedback and Value Based Payment Modifier team Tonya Smith, Health Insurance Specialist, Physician Feedback and Value Based Payment Modifier team Michael Wroblewski, Director, Division of Value Based Purchasing This team focuses on implementation of Performance Based Policy for the Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (DHHS).

Description and Objectives This webinar will walk participants through how to access and navigate the CMS registration system which is called the Physician Value-PQRS Registration System. Implications of PQRS reporting on the Value Based Payment Modifier for 2015 and proposed in these programs for 2016 will also be discussed. Following this 60-minute webinar, you will: 1. Understand how group practices can access and navigate the PV-PQRS registration system in order to select a PQRS reporting mechanism, and if applicable, elect quality tiering to calculate the Value Based Payment Modifier. 2. Understand how eligible professionals can access and navigate the PV-PQRS registration system in order to select the Administrative Claims reporting option. 3. Learn critical connections between the PQRS and Value Based Payment Modifier. 4. Learn about the proposed changes for the expansion of the Value Based Payment Modifier in 2016.

Registering g for PQRS reporting and understanding implications and proposed policies for the Value Based Payment Modifier Presented by: Centers for Medicare and Medicaid Services Performance Based Payment Policy Group Sabrina Ahmed Sheila Roman Tonya Smith Michael Wroblewski July 24, 2013

Presentation Overview Overview of the Value-based Modifier (VM) Obtaining an IACS Account to Access the PV- PQRS Registration System Using the PV-PQRS Registration System to Select Your 2013 PQRS Reporting Mechanism and VM Quality Tiering Q&A 2 2

What is the Value-Based Modifier? VM assesses both quality of care furnished and the cost of that care under the Medicare Physician Fee Schedule. Begin phase-in of VM in 2015, phase-in complete by 2017. Implementation of the VM is based on participation in Physician Quality Reporting System. For CY 2015, we will apply the VM to groups of physicians with 100 or more eligible professionals (EPs). 3 3

PQRS and VM Programs are Linked VM implementation in 2015 is based on PQRS participation in 2013 Groups of physicians with >100 eligible professionals PQRS Participation Groups that register for PQRS GPRO (via web interface, registry or CMS- calculated admin claims ) and meet the minimum reporting requirement Non-PQRS Participation Groups that do not register for PQRS GPRO and do not meet the minimum reporting requirement. Elect quality-tiering calculation Upward, downward, or no adjustment based on performance 0.0% (no adjustment) -1% (downward adjustment) 4 4

Quality-Tiering Methodology Use domains to combine each quality measure into a quality composite and each cost measure into a cost composite Clinical care Patient experience Population/ Community Health Patient safety Care Coordination Quality of Care Composite Score VALUE MODIFIER AMOUNT Efficiency Total overall costs Total costs for beneficiaries with specific conditions Cost Composite Score 5 5

Quality-Tiering Approach for 2015 Each group receives two composite scores (quality of care; cost of care), based on the group s standardized performance (e.g., how far away from the national mean). This approach identifies statistically significant outliers and assigns them to their respective cost and quality tiers. Low cost Average cost High cost High quality +2.0x* 20 +1.0x* 10 +0.0% 00% Average quality +1.0x* +0.0% -0.5% Low quality +0.0% -0.5% -1.0% * *Eligible for an additional +1.0x if : Reporting quality measures via the web based interface or registries AND Average beneficiary risk score in the top 25% of all beneficiary risk scores 6 6

Value Modifier 2015 Policies & 2016 Proposals Value Modifier Components 2015 Finalized Policies Performance 2013 2014 Year Group Size 100+ 10+ 2016 Proposed Policies Available Quality GPRO-Web Interface, CMS GPRO-Web Interface, CMS Reporting Qualified Registries, Qualified Registries, EHRs, and Mechanisms Administrative Claims 70% of EPs reporting individually Outcome All Cause Readmission Same as 2015 Measures Composite of Acute Prevention Quality Indicators: (bacterial pneumonia, urinary tract infection, dehydration) Patient Experience of Care Measures Composite of Chronic Prevention Quality Indicators: (chronic obstructive pulmonary disease (COPD), heart failure, diabetes) N/A PQRS CAHPS: Option for groups of 25+ EPs 7 7

Value Modifier 2015 Policies & 2016 Proposals (continued) Value Modifier Components 2015 Finalized Policies 2016 Proposed Policies Cost Measures Ttl Total per capita costs measure Same as 2015 and (annual payment standardized Medicare Spending Per and risk-adjusted Part A and Part Beneficiary measure (includes Part B costs) A and B costs during the 3 days Total per capita costs for beneficiaries with four chronic conditions: COPD, Heart Failure, Coronary Artery Disease, Diabetes before and 30 days after an inpatient hospitalization) Benchmarks Group Comparison Specialty Adjusted Group Cost Quality Tiering Optional Mandatory Groups of 10-99 EPs receive only the upward adjustment, no downward adjustment Payment at Risk -1.0% -2.0% 8

Timeline for VM that Applies to Payment Starting January 1, 2016 1 st Quarter Complete January 1 submission of VM applied to October 15 2013 physicians in 2013 Registration i information for i f groups of > closes PQRS 100 EPs 1 st Quarter Complete submission of 2014 information i for PQRS January 1 VM applied to physicians in groups of > 100 EPs and to physicians in groups of 10 99 2013 2014 2015 2016 3 rd Quarter Retrieve 2012 Physician Feedback reports (Groups of 25+) May 1 September 30 2014 Registration period 3 rd Quarter Retrieve 2013 Physician Feedback reports (All Groups and Solo Practitioners) 3 rd Quarter Retrieve 2014 reports (All Groups and Solo Practitoners) 9

Actions for Groups of 100+ Eligible Professionals for the 2015 VM 1. Register as a GROUP in the Physician Value-Physician Quality Reporting System (PV-PQRS) Registration System during the period of July 15 - October 15, 2013 2. Select apqrsgproreportingmechanism Web interface CMS-qualified registry Administrative i ti claims Note: Groups whose physicians participate as individuals in PQRS must self nominate as a group and elect administrative claims for the VM 3. Determine whether to elect the quality tiering approach to calculate the VM between July 15 - October 15, 2013 10 10

IACS Introduction An Individuals Authorized Access to the CMS Computer Services (IACS) account is required to access the PV-PQRS PQRS Registration System. Users are limited to 1 account per person. An existing IACS account cannot be transferred to another individual. An account can be associated with multiple group practices (Taxpayer Identification Number (TIN)) or individual EPs (TIN/National Provider Identifier (NPI)). If you have an existing IACS account: Ensure your account is still active Contact the Quality Net Help Desk. Must add a PV-PQRS PQRS Registration System role to your account. You can sign up for a new IACS account or modify an existing IACS account at https://applications.cms.hhs.gov/. 11

IACS Roles for Group Practices Group practices are identified in IACS by their Medicare billing TIN. One authorized representative of a group practice must sign up for an IACS account with the PV-PQRS Group Security Official role and register the group practice as an Organization in IACS Group s primary Security Official. The individual EPs (as identified by their rendering NPI) who bill under the TIN do not have to get an IACS account or register for the PQRS individually. There can be only one primary Group Security Official, but one or more backup Group Security Officials. Primary Group Security Official role requests are approved by CMS within 24 hours after the request is submitted. Backup Group Security Official role requests are approved by CMS after CMS verifies with the primary Group Security Official by phone that the requestor should have the backup Group Security Official role. 12

IACS Roles for Group Practices (Cont d.) Pi Primary or backup Group Security Official i role allows the user to perform the following tasks on behalf of the group practice: 1. Select/change the group practice s PQRS group reporting mechanism for 2013. 2. If the group practice has 100 or more EPs, elect quality-tiering to calculate the Value-Based Payment Modifier in 2015. 3. View the group practice s 2012 Quality and Resource Use Report after September 16, 2013. 4. Approve requests for the PV-PQRS Group Representative role in IACS. PV-PQRS Group Representative roles can be requested after the group practice has an approved primary Group Security Official in IACS. Allows the user to perform tasks 1-3 as listed above. Must be approved by the primary or backup Group Security Official within 12 calendar days after the request is submitted. 13

IACS Roles for Individual EPs Individual EPs are identified in IACS by their Medicare billing TIN and rendering NPI. The individual EP or one authorized representative of the individual EP must sign up for an IACS account with the PV-PQRS Individual role and register the individual EP in IACS Individual EP s primary Individual approver. There can be only one primary Individual approver, but one or more backup Individual approvers. Primary Individual approver role requests are approved by CMS within 24 hours after the request is submitted. Backup Individual approver role requests are approved by CMS after CMS verifies with the primary Individual approver by phone that the requestor should have the backup Individual approver role. 14

IACS Roles for Individual EPs (Cont d.) Primary or backup Individual approver role allows the user to perform the following tasks on behalf of the individual EP: 1. Select the CMS-calculated l administrative i ti claims reporting mechanism in 2013 in order for the individual EP to avoid the PQRS negative payment adjustment in 2015. 2. Approve requests for the PV-PQRS Individual Representative role in IACS. PV-PQRS Individual Representative roles can be requested after the individual EP has an approved primary Individual Approver in IACS. Allows the user to perform task 1 as listed above. Must be approved by the primary or backup Individual approver within 12 calendar days after the request is submitted. 15

Gather, Enter, & Verify Three steps to sign up for an IACS account 1. Gather all of the required information you need to submit your request for an IACS account with a PV-PQRS Registration System role or to modify your existing IACS account to add a PV-PQRS Registration System role. 2. Enter the required information into IACS at https://applications.cms.hhs.gov/. 3. Verify that you entered all of the required information correctly and submit your request. Note: When signing up for an IACS account, use an email address that you monitor regularly. CMS will send emails with your User ID, temporary password, and information about password resets and recertification. 16

Enter: New IACS User (All Roles) Go to https://applications.cms.hhs.govcms hhs and select Enter the CMS Applications Portal. Select Account Management and then select New User Registration. Select PV/PQRS Registration System. (Figure 1) Accept the Terms and Conditions. Figure 1: Selection of the PV/PQRS Registration System 17

Enter: New IACS User (All Roles) - Role Selection Enter the required Professional Contact Information. Select the appropriate IACS role you want to request. Figure 2: IACS Role Selection 18

Enter and Verify: Primary PV-PQRS Group Security Official Role Select Create a new Organization. Enter the group practice s Medicare billing TIN, two unique rendering NPIs for two different individual physicians who bill under the TIN, and their corresponding individual PTANs. (Do not use the group NPI or group PTAN) Enter the remaining required Organization Information. Figure 3: Becoming a Primary Group Security Official 19

Enter and Verify: Backup PV-PQRS Group Security Official Role Select Associate to an Existing Organization. Enter the group practice s Medicare billing TIN, and select Search. (Figure 4) Select the Organization s name from the Organization dropdown menu. (Figure 5) Figure 4: Becoming a Backup Group Security Official Figure 5: Organization Search Result Note: If your Organization cannot be found, then please verify that your group practice has an approved primary Group Security Official and you entered the group practice s TIN correctly. Figure 5: Becoming a Backup Group Security Official 20

Enter and Verify: Primary PV-PQRS Individual Approver Role Select Create a new Individual Eligible Professional. Enter the individual EP s Medicare billing TIN, rendering NPI, and the corresponding individual PTAN. Enter the remaining required Individual Eligible Professional information. Figure 6: Becoming a Primary Individual Approver 21

Enter and Verify: Backup PV-PQRS Individual Approver Role Select Associate to an Existing Individual Eligible Professional, and enter the individual EP s Medicare billing TIN and rendering NPI. Select Search. (Figure 7) Select the individual EP s name from the Individual Eligible Professional dropdown menu. (Figure 8) Figure 7: Becoming a Backup Individual Approver Figure 8: Individual EP Search Result Note: If the individual EP cannot be found, then please verify that there is an approved primary PV-PQRS Individual approver for the individual EP and you entered the individual EP s TIN and NPI correctly. 22

PV-PQRS Registration System The Physician Value-Physician Quality Reporting System (PV-PQRS) Registration System is a new application to serve the Physician Value Modifier and PQRS programs. The PV-PQRS Registration System is open from July 15, 2013 to October 15, 2013 and will allow the following: Group practices (1) Select/change their PQRS group reporting mechanism for 2013. (2) If the group practice has 100 or more eligible professionals, elect quality-tiering tiering to calculate the Value-Based Payment Modifier in 2015. Individual eligible professionals (EPs) - Select the CMScalculated administrative claims reporting mechanism in 2013 in order to avoid the PQRS negative payment adjustment in 2015. 23

Which Group Practices and Individual EPs Do Not Have to Register? Group practices that participate in the Medicare Shared Savings Program Group practices that only provide care to Medicare beneficiaries who are enrolled in a Medicare Advantage plan Group practices that only practice in a Rural Health Clinic Group practices that only practice in a Federally Qualified Health Center Group practices that only practice in a Critical Access Hospital (using method II billing) Individual EPs who want to participate in the PQRS in 2013 using a participating registry, claims, or electronic health records (EHRs) 24

Pioneer ACOs and CPCI Have to register in the PV-PQRS PQRS Registration System Group practices of all sizes (2+ EPs) that include EPs who participate in a Pioneer Accountable Care Organization (ACO), where all of the EPs under the billing TIN have elected to participate in the PQRS as a group Group practices of all sizes (2+ EPs) that include Comprehensive Primary Care (CPC) EPs, where all of the EPs under the billing TIN have elected to participate in the PQRS as a group Non-participating Pioneer ACO EPs, who are part of a TIN that also includes Pioneer ACO EPs, and want to participate in the PQRS as individuals using the CMS-calculated administrative claims reporting mechanism Non- participating CPC EPs, who are part of a TIN that also includes CPC EPs, and the participating CPC EPs have elected to receive credit for the PQRS reporting via a CPC waiver Do not have to register Individual EPs who are part of a TIN that participates in a Pioneer ACO or the CPCI, but are non-participating Pioneer ACO or CPC EPs, and want to participate in the PQRS as individuals using a participating registry, claims, or EHRs Individual EPs who are part of a TIN that participates in a Pioneer ACO or the CPCI AND are participating Pioneer ACO or CPC EPs, and want to participate in the PQRS as individuals using a participating registry, claims, or EHRs CPC Practice Site EPs who have elected to obtain credit for their PQRS reporting by meeting all CPC Clinical Quality Measure (CQM) reporting requirements successfully Note: Group practices are identified in IACS by their Medicare billing TIN. Individual EPs are identified in IACS by their Medicare billing TIN and rendering NPI. 25

Gather, Enter, & Verify Three steps to register in the PV-PQRS Registration System 1. Gather all of the required information you need to submit your PV-PQRS PQRS Registration. 2. Enter the required information into PV-PQRS Registration System at https://portal.cms.gov. 3. Verify that t you entered all of the required information correctly and submit your registration. 26 26

Enter: PV-PQRS Registration System Go to https://portal.cms.gov and select Login to CMS Secure Portal. (Figure 9) Accept the Terms and Conditions. Figure 9: Login to CMS Secure Portal 27

Enter: PV-PQRS Registration System Enter the User ID & the Password on the Login screen and click Login. (Figure 10) Figure 10: Login Screen 28

Select: Registration Select the Registration i hyperlink from the PV-PQRS PQRS dropdown. d (Figure 11) Figure 11: Landing Screen 29

New Registration: Group Practice Select the Register link. (Figure 12) Figure 12: New Registration Group Practice 30

Enter: Group Practice Information Enter the required organization information and requestor information. (Figure 13) Select the appropriate Group Practice Size, Quality Tiering Election, and the Reporting Mechanism and click Save & Continue. (Figure 13) Note: If a Group Practice Size of 2-24 Individual eligible professionals is selected, the group practice will be allowed to select CMS Calculated claims or registry reporting. The Quality Tiering Election option will only be available if the Group Practice size of 100 or more Individual Eligible Professional is selected. Figure 13: Group Practice Organization Information 31

Enter: Group Practice Contact Information Enter the required Program Contact Information and the Technical Contact Information. (Figure 14) Click Save & Continue. (Figure 14) Figure 14: Group Practice Contact Information 32

Verify: Group Practice Information Verify the Information and Select Submit to continue with the submission. (Figure 15) Figure 15: Group Practice Summary Page. 33

Confirmation Message: Group Practice Retain the Registration Identification Number provided in the confirmation message. (Figure 16) Click Home to go back to the Welcome Screen. (Figure 16) Figure 16: Confirmation Message 34

Self-nominated Group Practices Group ppractices that self-nominated during December 1, 2012 to January 31, 2013 do not need to register again in the PV-PQRS Registration System, UNLESS the group wants to: change its 2013 PQRS reporting mechanism select the CMS-calculated administrative claims reporting mechanism elect quality tiering to calculate the Value-based payment modifier (groups of 100+). 35

Next Steps Get a new IACS account or modify an existing account as soon as possible after at https://applications.cms.hhs.gov/. July 15, 2013 October 15, 2013: The PV- PQRS Registration System will be open and can be accessed at https://portal.cms.gov using your IACS User ID and password. September 16, 2013: 2012 Quality and Resource Use Reports will be available for group practices with 25 or more EPs. 36

Technical Assistance Information For assistance with the IACS sign up process or role selection, please contact the QualityNet Help Desk: Monday Friday: 8:00 am 8:00 pm EST Phone: (866) 288-8912 (TTY 1-877-715-6222) Fax: (888) 329-7377 Email: qnetsupport@sdps.org Quick reference guides for obtaining PV-PQRS Registration System roles in IACS: http://www.cms.gov/medicare/medicare gov/medicare/medicare-fee-for-service- Payment/PhysicianFeedbackProgram/Self-Nomination-Registration.html PQRS Program: http://www.cms.gov/medicare/quality-initiatives-patient-assessment- Instruments/PQRS/index.html Group Practice Reporting Options: http://www.cms.gov/medicare/quality-initiatives-patient- Assessment-Instruments/PQRS/Group_Practice_Reporting_Option.html Value-based Payment Modifier and Quality-tiering: http://www.cms.gov/medicare/medicare-fee-for-service- Payment/PhysicianFeedbackProgram/ValueBasedPaymentModifier.html 37 37

Thank You Centers for Medicare and Medicaid Services Performance Based Payment Policy Group Sabrina Ahmed Sheila Roman Tonya Smith Michael Wroblewski Questions? Please contact the QualityNet Help Desk: Monday Friday: 8:00 am 8:00 pm EST Phone: (866) 288-8912 (TTY 1-877-715-6222) Fax: (888) 329-7377 Email: qnetsupport@sdps.org 38

Thank You Questions? MGMA Government Affairs govaff@mgma.com 877.257.6462 x1370

Continuing Education Credit Submission Guide Instructions Calculate your credit hours with the attached Calculation Worksheet and submit your hours online with the following instructions: Go to mgma.com. Log in by using your member ID # and password. Under the Welcome message, select My Account. Choose My Transcript from the choices in the left column. Select Add New Credits. Follow the on-screen instructions. You will need the title of the conference/seminar, the number of credit hours earned and the end date of the program. Allow 24-48 hours for credit-hour submissions to be reflected on your transcript. You do not need to mail or fax any paperwork. Retain a copy of your calculation worksheet and any other continuing education documentation. ACMPE reserves the right to audit online entries randomly. ACMPE membership information: ACMPE, MGMA-ACMPE s standard-setting and certification body, grants nationally recognized certification and Fellowship designations to medical practice executives and leaders. If you are not a member of ACMPE and apply for admission within 30 days of this program, you might receive credit for attending this program upon acceptance into ACMPE.

Continuing Education Credit Submission Guide Calculation Worksheet Wednesday, 7/24/2013 Time 11:00 AM - 12:00 PM MT Session Registering for PQRS reporting and understanding implications and proposed policies for the Value Based Payment Modifier 1.0 Hours Earned Total Maximum hours assigned* 1.0 (AUD7242013) *ACMPE has granted credit hours for this continuing education program based on a review of a program description submitted by the sponsoring organization. The review is intended to verify the content relevance and number of instructional contact hours only. Please submit hours online at mgma.com. Keep this worksheet for your records. Do not fax or mail.