MACRA and MIPS Preparation for your Small Group Practice...Jun 21, 2017 · MACRA and MIPS ....
Transcript of MACRA and MIPS Preparation for your Small Group Practice...Jun 21, 2017 · MACRA and MIPS ....
MACRA and MIPS Preparation for your Small Group Practice
Beth HickersonLead Quality Improvement Advisor
June 21, 2017
Value Driven. Health Care. Solutions.
MACRA Jumpstart – Navigating the Quality Payment Program
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There are many questions surrounding MACRA, but the bottom line is if you participate in Medicare you will be impacted by MACRA and the Quality Payment Program (QPP)
MIPS or APM? Today we’ll help you determine which track to participate in
If you’re MIPS eligible, what is your readiness level?
MACRA Jumpstart – Using Free CMS Resources for MIPS Success
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At the close of our MACRA Jumpstart presentation you should have a better idea of which track to participate in and we will share free CMS Resources for MIPS support
– QPP Resource Center– www.qppresourcecenter.com
– Medical Advantage Group’s MACRA Jumpstart– www.medicaladvantagegroup.com/macra
jumpstart/– [email protected]
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)
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Repealed the Sustainable Growth Rate (SGR) methodology– Supported by organized medicine– Passed with over 90 percent
support in both the House and Senate; bi-partisan legislation
Created Quality Payment Program which moves Medicare into value-based payments– Alternative Payment Model (APM)– Merit-based Incentive Payment
System (MIPS)
Quality Payment Program (QPP)
January 1, 2017 – physicians enter the MIPS track or the APM trackFor the first few years of the QPP, majority of clinicians in MIPS
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Quality Payment Program (QPP)
Merit-based Incentive Payment System (MIPS)
Alternative Payment Model (APM)
Advanced APM MIPS APM
ALTERNATIVE PAYMENT MODELS (APMS)
What are APMs?
Payment approach that incentivizes clinicians to provide high-quality, cost-effective careStructured models that promote coordination and cooperation among providersFull list of 2017 APMs at https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf
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APM vs Advanced APM
Alternative Payment Model – Participation requirements
unique to each APM model– Participants must still
report MIPS, but have a modified scoring system that takes their APM activities into account
Advanced Alternative Payment Model (AAPM)– More stringent participation
requirements, usually involve some level of risk
– Qualifying Participants (QPs) are exempt from MIPS and receive 0.5% bonus payment
– Partial Qualifying Participants (Partial QPs) can opt out of MIPS without penalty
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2017 Advanced APMs
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MSSP Track 2 MSSP Track 3Comprehensive
Primary Care Plus (CPC+)
Next Generation ACO
Comprehensive ESRD Care Model
Oncology Care Model-Two sided
QPs and Partial QPs for AAPMs
Qualifying Participants (QPs)– Exempt from MIPS– Earn an annual lump sum payment of 5 percent of the MPFS
from 2019-2024CMS predicts that approximately 100% of eligible clinicians in Advanced APMs will be QPs in performance year 2017
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Performance Year 2017 2018 2019 2020 2021 2022 and later
Percentage of Medicare payments through an Advanced APM
Percentage of Medicare patients through an Advanced APM
25%
20% 35% 35% 50% 50%20%
50% 50% 75% 75%25%
QPs and Partial QPs for AAPMs
Partial Qualifying Participants (Partial QPs)– Can opt out of MIPS without penalty– Can report MIPS for possible incentive
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Performance Year 2017 2018 2019 2020 2021 2022 and later
Percentage of Medicare payments through an Advanced APM
Percentage of Medicare patients through an Advanced APM
20%
10% 25% 25% 35% 35%10%
40% 40% 50% 50%20%
MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)
Overview
Impact on the MPFS
Instead of a 21 percent payment cut – No increase in MPFS (January – June 2015)– Increase 0.5 percent (July 2015 – December 2015)– Increase 0.5 percent per year (2016 – 2019)– No increase (January 2020 – December 2025)– 2026 and beyond:
– APM participants –0.75 percent annual increase
– MIPS participants –0.25 percent annual increase
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0
0.2
0.4
0.6
0.8
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
MIPS Impact on Current Programs
– PQRS Quality– VM Cost– EHR Advancing
Care Information
– Improvement Activities is a new measure in MIPS
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CMS legacy programs become measures in the MIPS program
MIPS Overview
Provides both upside and downside adjustments to the MPFS Maximum adjustments: – 2019: 4 percent– 2020: 5 percent– 2021: 7 percent– 2022 & beyond: 9 percentFirst MIPS performance year-2017First MIPS payment year-2019
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Threshold
4x% 5x% 7x% 9x%
-4x% -5x% -7x% -9x%2019 2020 2021 2022
MIPS Eligible Providers
Years 1 and 2 Medicare Part B clinicians:
Physicians MD, DOPodiatristsOptometristsChiropractorsDentistsPhysician AssistantsNurse PractitionersClinical Nurse SpecialistsCertified Registered Nurse Anesthetists
Year 3+ Medicare Part B clinicians:
Occupational TherapistsPhysical TherapistsSpeech TherapistsAudiologistsNurse MidwivesClinical Social WorkersDietitians
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Who is Exempt from MIPS?
3 groups of clinicians:
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First year of Medicare Part B
participation
Below low patient volume threshold
Qualified Participants in
ADVANCEDAlternative
Payment Models100 or fewer Part B patients
OR billing no more than $30k/year
NOTE: MIPS does not apply to hospitals or facilities
MIPS Category Measures Over Time
A score of 0-100 developed for each eligible clinician based on performance in four categories:
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QualityAdvancing Care
InformationImprovement
Activities CostReplaces PQRS Replaces MU New (PCMH) Replaces VBM
2017 60% 25% 15% 0%
2018 50% 25% 15% 10%
2019+ 30% 25% 15% 30%
Three MIPS Options to Participate in 2017
To avoid a negative adjustment in 2019, submit to CMS one of the following in 2017:
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1Quality
Measure
1Improvement
Activity
5Required Advancing Care
Information Measures
OR OR
Reporting
Individual – defined as a single NPI tied to a single TIN– CEHR– Registry– Qualified clinical data registryGroup – must share a common TIN– CEHR– Registry– Qualified clinical data registry– CMS web interface – must register by June 30, 2017
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Quality – 60%
Select 6 measures to report on from about 300 quality measuresOr select from a set of specialty specific measuresFull list of measures at https://qpp.cms.gov/measures/quality
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Must report for at least 90 days to be eligible for a positive adjustment
3-10 points per measure based on performance against a benchmark 60 possible pointsBonus points for high-priority and EHR reporting
60Points
Advancing Care Information – 25%
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Choose between 2 lists of Advancing Care Information (ACI) Objectives ad Measures
ACI Objectives and Measures 2017 ACI Transition Objectives and Measures
5 required base measures 4 required base measures9 optional performance measures 7 optional performance measures2015 Certified EHR 2014 Certified EHRStage 3 Meaningful Use standards Modified Stage 2 Meaningful Use
standards
Advancing Care Information Performance Category Fact Sheet available athttps://qpp.cms.gov/resources/education
Advancing Care Information – 25%
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– Security risk analysis– e-Prescribing– Provide patient access– Health Information
Exchange
– 5 percent for public health/clinical data registry reporting
– 10 percent for improvement activity alignment
– Provide patient access– Health information
exchange– View, Download, or
Transmit– Patient-specific education– Secure messaging– Medication Reconciliation– Immunization Registry
reporting
Required base score*
Optional performance score*
Bonus score
50 90 15
*2017 ACI Transition Objectives and Measures
Improvement Activities – 15%
Attest to completing activities that improve clinical practice for at least 90 days during the year92 activities in 9 categoriesAccumulate 40 points for maximum category scoring– Medium-weighted activities
(10 points)– High-weighted activities (20
points)Points are doubled for small, rural, and health professional shortage area practices
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1. Expanded PracticeAccess
2. Population Management
3. Care Coordination
4. Beneficiary Engagement
5. Patient Safety and
Practice Assessment
6. Participation in an APM
7. Achieving Health Equity
8. Integrating Behavioral and Mental Health
9. Emergency Preparedness and Response
Improvement Activities – 15%
Full credit for clinicians in CPC+, in a PCMH, or in similar specialist practice– PCMH certifications for MIPS include: a national program,
a regional or state program, a private payer, or other body that certifies at least 500 practices
Partial or full credit for participation in an APMFull list of Improvement Activities, with details on action required and suggested documentation, available at https://qpp.cms.gov/resources/education under MIPS Data Validation Criteria
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Cost – 0%
Clinicians are not required to submit cost data to CMS– CMS assesses clinicians based on Medicare claims data CMS compares resources used to treat similar care episodes and clinical condition groups across practicesCost measures adjusted for geographic payment rates and beneficiary risk factorsECs earn a maximum of 10 points per episode cost measure
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MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)
Reporting Requirements and Scoring
Pick Your Pace Options
Three options to participate in MIPS in 2017:
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Don’t submit
Pick Your Pace Options
Four options to participate in MIPS in 2017:
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No Participation
Minimum Participation
Partial Participation
Full Participation
• Report nothing
• -4% penalty
• Report 1 Quality measure
Or 1 Improvement
ActivityOr
4/5 Required Advancing Care
Information measures
• 0% adjustment
• Report more than minimum for at least 90 days
• Small incentive
• Report all categories for at least 90 days (preferably one full year)
• Up to 4% incentive
• Possible bonus if ≥ 70 points
Scoring Basics
Each provider/practice will receive a final score for each MIPS category based on performanceCategory scores will be calculated (based on category weighting) to produce a total score between 1-100
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Payment Adjustment Basics
CMS will publish a “performance threshold” score at the start of each year Each Eligible Clinician’s (EC’s) final score is compared to the performance threshold score ECs with a score exactly at threshold will receive no MIPS adjustmentECs with a score below threshold will receive a negative payment adjustmentECs with a score above threshold will receive a positive payment adjustment factorAdjustment percentages are variable based on EC score compared to threshold score
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2017 Final Scores and Adjustments
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Final Score Payment Adjustment
≥70 points – Positive adjustment– Eligible for exceptional performance bonus – minimum of
additional 0.5%4-69 points – Positive adjustment
– Not eligible for exceptional performance bonus3 points – Neutral payment adjustment
0 points – Negative payment adjustment of -4%– 0 points = does not participate
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Budget Neutrality
>> Amounts accrued from penalties assessed against ECs with scores below the threshold will fund payments for ECs with scores above the threshold
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Additional Incentive Payments and Support
For 2019-2024, maximum of $500 million per year in additional incentive payments may be available to distribute to ECs who have “exceptional performance”– Final score of 70 or higher qualifies for an additional payment in
2017 (2019 payment year)– Not budget neutral Technical support for small and rural practices– QPP Small, Underserved, and Rural
Support (QPP SURS)
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Example of MIPS Negative Adjustment
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MPFSReimbursement
2017 data/2019 payment
2018 data/ 2020 payment
2019 data/ 2021payment
2020 data/ 2022 payment
Maximum Loss 4% 5% 7% 9%
$50,000 $2,000 $2,500 $3,500 $4,500
$100,000 $4,000 $5,000 $7,000 $9,000
$400,000 $16,000 $20,000 $28,000 $36,000
Example of MIPS Positive Adjustment
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MPFSReimbursement
2017 data/2019 payment
2018 data/ 2020 payment
2019 data/ 2021 payment
2020 data/ 2022 payment
Plus or Minus 4% 5% 7% 9%
Bonus 10% 10% 10% 10% 10%
$50,000 $7,000 $7,500 $8,500 $9,500
$100,000 $14,000 $15,000 $17,000 $19,000
$400,000 $56,000 $60,000 $68,000 $76,000
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Physician Compare Website
Shows MIPS composite scores and individual performance category scores Patients can see health care providers rated on a scale of 0 to 100 and how physician compares to peers nationally
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PREPARING FOR MIPS 2017
Based on your practice’s capabilities
Pick Your Pace - Minimum and Ideal
Good - Submit data on at least one quality measure, one improvement activity or four advancing care information transition measures to avoid a 4% negative adjustmentBetter - Submit more than the required data in 1 or more categories for least 90 days to possibly earn a modest positive adjustmentBest - Submit full data in all 3 categories for at least 90 days (one full year preferred) to possibly earn the maximum positive adjustment
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If you previously reported PQRS
1. Review the list of 2017 Quality measures to verify that your previous measures are still available https://qpp.cms.gov/measures/qualityMeasures Group reporting is no longer an option!
2. If reporting Quality via Claims, continue adding the appropriate codes to Medicare claims
3. If reporting Quality via EHR or registry, review your quality measure reports for accuracy, and
contact your vendor if there are obvious issues4. Begin improving performance on quality measures
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If you previously reported Meaningful Use
1. Review the list of 2017 ACI Transition Objectives and Measures https://qpp.cms.gov/measures/aci
2. Print your 2017 Year-to-Date ACI or MU report3. Verify that you are able to meet all required base
measures (especially the Health Information Exchange measure)
4. Begin improving on your optional performance measures
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If you do have an EHR & have not reported
1. Choose an improvement activity that you can complete for 90 days, and begin implementationReview the list at https://qpp.cms.gov/measures/ia
2. Contact your EHR vendor for guidance on MIPS reportingDo you need a software upgrade?How do you review Quality and ACI reports?How much is MIPS reporting per provider?
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If you do not have EHR & have not reported
1. Choose an improvement activity that you can complete for 90 days, and begin implementationReview the list at https://qpp.cms.gov/measures/ia
2. Begin learning how to submit quality information via claims Contact your billing company to see if they can assist Begin educating yourself at
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2016PQRS_Claims_CodingRpgPrinc.pdf
3. Begin exploring EHR options
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TYING IT ALL TOGETHER
Start Working on QPP Activities now
Next Steps – Using Free CMS Resources for MIPS Success
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Determine your eligibility – MIPS or APMIf you’re MIPS eligible, and your practice is under 15 physicians, rural, or underserved, you likely qualify for FREE support through the QPP Resource CenterHow to Sign Up: visit the www.qppresourcecenter.com – click the “Join Now” button at the top, answer a few short questions about your practice and you’re on your way! Questions: Contact Us - 800.264.7221 or [email protected]
Next Webinar – July 12
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Visit Medical Advantage Group’s MACRA Jumpstart Page:– www.medicaladvantagegroup.com/mac
rajumpstart/
Register for our July 12 webinar: – MACRA Jumpstart: Preparing Your
Small Practice for MIPS Success
Questions?
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Beth [email protected]
Value Driven. Health Care. Solutions.