FACILITY-BASED PREVIEW LIVE DEMO AND OFFICE HOURS SESSIONThursday, April 18, 2019

Disclaimers

This presentation was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services.

This publication is a general summary that explains certain aspects of the Medicare Program, but is not a legal document. The official Medicare Program provisions are contained in the relevant laws, regulations, and rulings. Medicare policy changes frequently, and links to the source documents have been provided within the document for your reference.

The Centers for Medicare & Medicaid Services (CMS) employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this guide.

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Topics

• Overview of the Merit-based Incentive Payment System (MIPS) in Year 3

• Facility-based Measurement

- Overview

- Eligibility

- Data Submission Requirements

- Impact on Quality and Cost Scores

• Facility-based Preview Live Demonstration

• Resources and Technical Assistance

• Office Hours

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MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)Overview

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Quality Payment Program

The Quality Payment Program consists of two participation tracks for clinicians:

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Merit-based Incentive Payment System (MIPS)Quick Overview

MIPS Performance Categories

• Comprised of four performance categories

• So What? The points from each performance category are added together to give you a MIPS Final Score

• The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment

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Merit-based Incentive Payment System (MIPS)Terms and Timelines

Key Terms to Know…

• TIN - Tax Identification Number

- Used by the Internal Revenue Service to identify an entity, such as a group medical practice, that is subject to federal taxes

• NPI – National Provider Identifier

- 10-digit numeric identifier for individual clinicians

• TIN/NPI

- Identifies the individual clinician and the entity/group practice through which the clinician bills services to CMS

Year Also Referred to as… Corresponding Payment YearCorresponding

Adjustment

2017 2017 “Transition” Year 2019 Up to +4%

2018 2018 Performance Year 2020 Up to +5%

2019 2019 Performance Year 2021 Up to +7%

FACILITY-BASED MEASUREMENT

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Overview

Facility-based Measurement

What is it?

• Facility-based scoring is an option for clinicians that meet certain criteria beginning with the 2019 performance period:

- CMS finalized this policy for the 2019 performance period in the 2018 Final Rule.

- Facility-based scoring allows for certain clinicians to have their Quality and Cost performance category scores based on the performance of the hospitals at which they work.

• Facility-based measurement will apply for the 2019 MIPS performance year, which will affect payments in 2021.

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Facility-based Measurement Eligibility Determination: Individual

Individuals:

To be eligible for facility-based measurement, you must:

• Be a MIPS eligible clinician type

• Furnish 75% or more of your covered professional services in an inpatient hospital (Place of Service code 21), on-campus outpatient hospital (POS 22), or emergency room (POS 23)*

• Have at least a single service billed with POS code used for inpatient hospital or emergency room

• Can be attributed to a facility with a Hospital Value-based Purchasing (HVBP) Program score

* Determinations for the 2019 performance year are based on a claims period of October 1, 2017 through September 30, 2018 (including a 30-day claims run out). This historic look-back period is the only timeframe used for determining eligibility in 2019.

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Facility-based Measurement Eligibility Determination: Group/Virtual Group

Groups/Virtual Groups:

• CMS identifies facility-based groups and virtual groups based on the following criteria:

- 75% or more of the MIPS eligible clinicians (NPIs) in a group or virtual group (NPIs billing under the group’s TIN) are deemed facility-based

- We will attribute clinicians in groups and virtual groups to the hospital at which the plurality of clinicians in the group or virtual group were attributed as individuals

• Facility-based measurement is not applicable to MIPS APM participants at this time

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Attribution

Facility-based Measurement

• Facility-based clinician would be attributed to hospital where they provide services to the most patients

• Facility-based group would be attributed to hospital where most facility-based clinicians are attributed

• If CMS is unable to identify a facility with the HVBP score to attribute a clinician’s performance, that clinician would not be eligible for facility-based measurement and would have to participate in MIPS via other methods

How does CMS attribute the facility-based score to a TIN in the situation where the TIN is an independent group contracted by the hospital?

• CMS uses the CMS Certification Number (CCN) supplied in the subcontracted group’s claims to attach the subcontracted group’s TIN to the hospital(s) they serve

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Attribution

Facility-based Measurement

How do I identify the hospital to which I’ve been attributed?

• The QPP Participation Status Look-up Tool on qpp.cms.gov will identify:

1. Whether you are facility-based

2. The attributed facility

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Election

Facility-based Measurement

Do I have to submit anything?

• CMS will automatically apply facility-based measurement to the Quality and Cost performance category scores for individual MIPS eligible clinicians, groups, and virtual groups that are determined to be facility-based

• There are no additional submission requirements for individual clinicians in facility-based measurement

• Groups need to submit data for the Improvement Activities or Promoting Interoperability performance categories in order to indicate their intent to be measured as a facility-based group

• Clinicians in a virtual group would have already formed and elected to participate in MIPS prior to the 2019 MIPS performance period

- If a virtual group is eligible for facility-based measurement, there are no additional data submission requirements

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Facility-based Measurement Measurement and Benchmarks

Measurement

• To calculate the Quality and Cost performance category scores for those who are determined to be facility-based, CMS will incorporate all measures used in the Hospital VBP Program for the specified program year

• CMS will calculate the facility-based Quality and Cost scores based on the Total Performance Score calculated under the Hospital VBP Program during FY 2020. Those scores will be mapped to QPP data from the 2019 performance period

Benchmarks

• Benchmarks for facility-based measurement are those that are adopted under the hospital VBP Program of the facility for the year specified

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Quality and Cost Scoring

Facility-based Measurement

Since the Total Performance Score is calculated for the Hospital VBP Program, it will be translated into a MIPS program-specific score where the Quality and Cost performance scores are comparable to others participating in MIPS:

• Step 1: Establish percentile performance compared to hospitals participating in the Hospital VBP Program

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Quality and Cost Scoring

Facility-based Measurement

• Step 2: Calculate the performance score for the MIPS Quality and Cost performance categories

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Special Rules

Facility-based Measurement

• Some hospitals do not receive a Total Performance Score in a given year in the Hospital VBP Program, whether due to insufficient quality measure data, failure to meet requirements under the Hospital In-patient Quality Reporting (IQR) Program, or other reasons

• In these cases, we would be unable to calculate a facility-based score based on the hospital’s performance, and facility-based clinicians would be required to participate in MIPS via another method

FACILITY-BASED PREVIEW LIVE DEMONSTRATION

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RESOURCES AND TECHNICAL ASSISTANCE

Resources

• Facility-based Measurement Resources:

- 2019 Facility-based Measurement Fact Sheet (includes TPS measures)

- 2019 Facility-based Preview FAQs

• General Resources:

- Final Rule Overview Fact Sheet

- Quality Payment Program website – qpp.cms.gov

- QPP Participation Status Look-up Tool

- QPP Resource Library

- QPP Webinar Library

- QPP Help and Support Page

- QPP Listserv – available on the Quality Payment Program website

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Technical AssistanceAvailable Resources

CMS has no cost resources and organizations on the ground to provide help to clinicians who are participating in the Quality Payment Program:

Learn more about technical assistance: https://qpp.cms.gov/about/help-and-support#technical-assistance

OFFICE HOURS

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Q&A Session

To ask a question, please dial:

1-866-452-7887

If prompted, use passcode: 2957188

Press *1 to be added to the question queue.

You may also submit questions via the chat box.

Speakers will answer as many questions as time allows.

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