APRIL 20, 2017 The Quality Payment Program: Your Questions Answered
Quality Payment Program Panel BETH HOUCK, MBA Vice President, Client Services SA Ignite MATTHEW BARRON, MBA Director, Advisory Services SA Ignite MATTHEW FUSAN Director, Solutions Consulting SA Ignite
Agenda I. ACI II. MSSP ACO III. Eligibility IV. Measures V. Reporting / Submission VI. Strategy
ACI Category Multi-EHR How can we report ACI if we re on multiple EHRs? What if a provider crosses TINs? Individual vs Group For specialists that may be subject to ACI, can they "piggy back" on the Meaningful Use activities done by their primary care colleagues? Does everyone in the group TIN need to do a security risk audit in order to say yes to that measure? Regulations What happens to the hospital Meaningful Use program? How does Stage 3 Meaningful Use certification fit into MIPS? Is that going to be required to participate in 2018? 4
MSSP ACOs MIPS components and scoring MSSP MIPS APM scoring standard ACI reporting for MSSP ACO participants 5
MIPS Components & Scoring Scoring Model Creates 100-point system to increase and consolidate financial impacts Ranks peers nationally, and reports scores publicly 2017 weightings put 85% in the Quality and ACI categories Resource Use is 0 for 2017, but will be scored in 2018 and beyond 60 25 15 0 POINTS POINTS POINTS POINTS Quality (PQRS/VBM) Advancing Care Information (Meaningful Use) Improvement Activities Cost 6
MSSP MIPS APM Scoring Standard All MSSP ECs will receive the ACO MIPS score and equivalent payment adjustment 50 30 POINTS 20 POINTS 0 POINTS POINTS Quality Advancing Care Information Improvement Activities Cost Submitted via CMS Web Interface for the ACO Submitted via ACO participant TINs ACO receives full credit, no action required 7
ACI Reporting for MSSP ACO Participants For MSSP ACO reporting, EACH participating TIN must submit their own ACI data at the TIN level. The MSSP ACO ACI score is a rollup of the participating TIN ACI scores, with each TIN score weighted by the number of eligible clinicians in that TIN. If one TIN has a significantly higher number of eligible clinicians, its score will contribute more to the ACO score than others with lower eligible clinician counts. Hospital-based MIPS physicians, nurse practitioners, physician assistants, clinical nurse specialists, certified registered nurse anesthetists (CRNAs) can be excluded from reporting ACI data for TINS participating in MSSP ACOs. FQHCs participating in an MSSP ACO may have eligible clinicians if any professional services were billed under Part B. FQHC billing methodology makes this unlikely, but being part of an FQHC in and of itself does not make a clinician exempt from MIPS. 8
Eligibility: Basics 2017 & 2018 2019+ Secretary may broaden eligible clinicians group to include others such as: 9
Eligibility: Basics Ineligible credential First year of Medicare Part B participation Below low patient volume threshold Medicare billing charges less than or equal to $30,000 or provides care for 100 or fewer Medicare patients in one year Certain participants in ADVANCED Alternative Payment Models 10
Eligibility: Clinician Attributes Hospital-based clinicians > 75% of professional services in acute setting Can opt out of ACI, reweight Quality to 85% of score Non-patient-facing clinicians 100 or fewer patient facing encounters Receives full credit for IA by accomplishing only ½ the points Small practices, practices located in rural areas or geographic HPSAs 11
Eligibility: Advanced Individual-Clinician MIPS Exclusion Quality data included? ACI data included? MIPS EC payment adjustment? Ineligible credentials For 2017, credentials other than physicians, PAs, NPs, CNSs, and CRNAs. (QPP p120, 2006) If data submitted, data included in Group scoring Not enrolled in Medicare Part B Optional Optional X Optional Optional X First-year Medicare X Low volume Advanced APM QP or PQP not opting into MIPS X 12
Eligibility: Advanced Individual-Clinician MIPS Exclusion Quality data included? ACI data included? MIPS EC payment adjustment? Hospital-Based Clinician (75%+ of services in POS codes 21, 22 & 23; QPP p174) * Optional ACI: For Group reporting, if only some clinicians are hospital-based, their ACI data can be optionally submitted, but those clinicians and all other clinicians in the group will receive an ACI score based on all the submitted ACI data for the group. The group can include some/none/all of these clinicians. ACI reweighting to 0% occurs only if all clinicians in the group are hospital-based and the group has not submitted any ACI data. (CMS INC0029007). *Exceptions to Quality data inclusion are applicable when clinician charts on multiple certified ambulatory EHRs and is reported via EHR Direct. 13
Eligibility: Advanced Individual-Clinician MIPS Exclusion Quality data included? ACI data included? MIPS EC payment adjustment? Non-patient-facing Clinician Individual clinician <=100 patient-facing encounters, or group >75% of individual clinicians meet above condition; QPP p148 * Optional ACI For Group reporting, if only some clinicians are nonpatient-facing, ACI data can be optionally submitted, but those clinicians and all other clinicians in the group will receive an ACI score based on all submitted ACI data for the group. The group can include some/none/all of these clinicians. ACI reweighting to 0% occurs only if >75% of clinicians in the group are non-patient-facing and the group has not submitted any ACI data *Exceptions to Quality data inclusion are applicable when clinician charts on multiple certified ambulatory EHRs and is reported via EHR Direct. 14
Eligibility: Advanced Individual-Clinician MIPS Exclusion Advanced Practice Providers (APPs) Comprised of PA, NPs, CNSs, CRNAs Quality data included? ACI data included? MIPS EC payment adjustment? * Optional ACI: For Group reporting, if only some clinicians are APPs, their ACI data can be optionally submitted, but those clinicians and all other clinicians in the group will receive an ACI score based on all the submitted ACI data for the group. The group can include some/none/all of these clinicians. ACI reweighting to 0% occurs only if all clinicians in the group are APPs and the group has not submitted any ACI data. *Exceptions to Quality data inclusion are applicable when clinician charts on multiple certified ambulatory EHRs and is reported via EHR Direct. 15
Participation Options Individual Group APM Entity Group NPI A group of clinicians, as defined by taxpayer identification number (TIN), assessed as a group across all MIPS performance categories A collection of entities participating in an Alternative Payment Model Audit Risk: Data is auditable for up to 10 years after submission. 16
Measures Topped-out measures How do you know if a measure is topped out? Is it possible for a measure to be topped out in one reporting method but not in another? When I see a topped-out measures (e.g., Documenting Current Meds), would you recommend against using that measure? Selecting Measures What will you need to consider when you choose which measures to report? Can we just send many measures and then have CMS do the calculation of what are the best 6? Scoring How does scoring for measures work? What if I don t have 6 measures to report? Can I still maximize the Quality category with less than 6? 17
Example Benchmark Scale: Claims Reporting Chronic Obstructive Pulmonary Disease (COPD): Long-Acting Inhaled Bronchodilator Therapy
Measures What s the average performance I need to achieve to get the minimum? Characteristic EHR Direct Registry Claims Measures with a benchmark 44 118 56 Measures requiring >50% performance to achieve 3 Points Average performance threshold to achieve >=3 points 17 68 42 36.6% 56.7% 72.3%
Reporting/Data Submission Submission Method Individual Group EHR Direct Registry Qualified Clinical Data Registry (QCDR) Web Interface Claims 20
Data Completeness Can we have more insight on the 50% of data completeness? How is it calculated for the EHR reporting? Data completeness is calculated for EACH measure and is 50% for year 2017 EHR Direct, although increasing year after year For each measure, there is a denominator eligible population that is defined by the CMS specifications It is required that 50% of that denominator eligible population be submitted to CMS as long as it is from an EHR that has been certified to calculate MIPS ecqms The denominator assumption and 50% requirement would not include data from non-certified EHRs and paper sources 21
Data Completeness Is hospital based clinician data expected to be included in Quality measure data for Group submission? This depends entirely on whether the EHR has been certified to capture the MIPS ecqms, so the answer may be yes for some and no for others. In some cases, you may be able to exclude data from a certified EHR: It represents a small percent of the denominator eligible population and would still allow the Group to meet data completeness without that data. 22
Strategy 6 Successful Steps of a MIPS Journey 1. Understand MIPS 2. Organize the team 3. Analyze the current state 4. Create a roadmap 5. Implement a solution 6. Optimize and improve 23
1. Understand MIPS Eligibility Program participation Categories & scoring Measure selection Reporting periods Reporting methodology 24
2. Organize the Team Organization-wide team Include clinical, finance, IT and operations 25
3. Analyze the Current State Projected MIPS impact Project MIPS score Leverage past performance data to identify areas of excellence as well as improvement 26
4. Create a Roadmap How 2017 will affect future years It doesn t pay to wait Plan to improve year-over-year Capture share of annual exceptional performance pool $500 million 27
5. Implement a Solution Increase efficiency and productivity Reported cost to comply with value-based programs 785 hours per physician $15B annually Complements and enhances existing IT infrastructure 28
6. Optimize & Improve Monitor performance Leverage data to create targeted Quality improvement plans Maximize time and resource ROI 29
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