The March to MIPS - Flagler...

IMPLEMENTING MEDICARE’S NEW MERIT-BASED INCENTIVE PAYMENT

SYSTEM

The March to MIPS

Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 1

The March to MIPS

Release Date: June 29, 2016

Expiration Date: June 28, 2017

Target Audience: For the education of physicians and other

healthcare professionals to understand the details and prepare

for the practice impact of the merit-based incentive payment

system (MIPS) implemented by CMS.

Disclosures: Commercial support: NONE

Speaker has financial interest: NONE

Investigational products/products not labeled for use: NONE

CME Committee of Flagler Hospital: No relevant financial disclosures


Faculty

Martie Ross, JD

Principal| Pershing Yoakley & Associates

Degree: Juris Doctorate: University of Kansas School

of Law

Lawrence, KS

Contact: [email protected]


Objectives

At the conclusion of this presentation, participants will be able

to:

1. Introduce the Medicare Merit-Based Incentive Payment System.

2. Discuss the four components of the MIPS Composite Score.

3. Address the penalties and bonuses associated with the MIPS

Composite Score.

4. Highlight the reputational impact of the publicly-reported MIPS

Composite Score.


How to Obtain AMA PRA Category 1 CreditTM

1.Listen to The March to MIPS audio presentation and review the

power point slides.

2. Complete the CME post-test with a passing score of 80% and

evaluation form via the following SuveyMonkey® link:

https://www.surveymonkey.com/r/MARCHTOMIPS

3. Once post-test has been graded and evaluation verified, CME

credits will be reported to CE Broker and certificate sent via inter-office

mail or mailed to address noted on evaluation.




Accreditation/Credit Statement

Flagler Hospital is accredited by the Florida Medical Association to provide continuing medical education for physicians. Flagler Hospital designates this educational activity for a maximum of two (2.00) AMA PRA Category 1 Credit(s) TM. Physicians should claim only the credit commensurate with the extent of their participation in the activity.


Disclaimer

The information in this educational activity is provided for general

education purposes only. The viewpoints expressed in this CME activity

are those of the faculty. They do not represent an endorsement by

Flagler Hospital. In no event will Flagler Hospital be liable for any

decision made or action take in reliance upon the information provided

through this CME activity.

VBR Framework

FEE-FOR-SERVICE (FFS) PAYMENTS

POPULATION-BASED APMs

ADJUSTED FFS PAYMENTS

APMs INCORPORATING

FFS PAYMENTS

$$

Bank

A Pay For Reporting

B Pay For Performance

C Pay/Penalty For Performance

A Total Cost of Care Shared Savings

B Total Cost of Care Shared Risk

C Retrospective Bundled Payment

D Prospective Bundled Payment

A Condition-Specific Population- Based Payments

B Primary Care Population- Based Payments

C Comprehensive Population- Based Payments

A Traditional FFS

B Infrastructure Incentives

C Care Management Payments

Medicare Transition To

Value-Based Reimbursement

By 12/31 2016

By 12/31 2018

30% of traditional Medicare payments through APMs

50% of traditional Medicare payments through APMs

85% of Medicare fee-for- service payments tied to scores on quality and efficiency measures.

90% of Medicare fee-for- service payments tied to scores on quality and efficiency measures.

03/03/2016 - Mission Accomplished


MACRA

Medicare Access and CHIP Reauthorization Act of 2015

Repealed Sustainable Growth Rate for Calculating MPFS Rates

Replaced with Merit-Based Incentive Payment System (MIPS)


Transition to MIPS

Through 12/31/2018

• 0.5% annual MPFS update (2016-2019)

• Payment adjustments • 2% PQRS reporting penalty

• 3% EHR meaningful use penalty

• +/- 4% Value-Based Modifier bonus/penalty

Starting 01/01/2019

• Annual MPFS update • 0% in 2020 - 2025

• 0.25% thereafter (0.75% for participants in qualifying APMs)

• Single payment adjustment based on composite performance score (CPS)

• Incentives for participation in APMs


MIPS Timeline

CMS “listening

tour”

Proposed Rule published 04/26/2016

• “Quality Payment Program”

Comments due to CMS

by 06/27/2016

Final rule to be published prior to 11/01/2016

First performance

year commences 01/01/2017

Payment adjustments commence 01/01/2019


MIPS Eligible Clinicians (MECs)

Years 1 and 2 Years 3+

Physicians (MD/DO, DMD/DDS, & DPMs),

PAs, NPs, CNSs, CRNAs

Physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical

psychologists, dieticians/nutritional professionals


Non-MECs

First year of Medicare Part B participation

Below low volume threshold

Medicare billed charges of $10,000 or less and

Provide care for 100 or fewer Medicare beneficiaries

Qualifying Participants (QPs) in Advanced APMs

Note: MIPS does not apply to Part A providers (including hospitals,

rural health clinics, federally qualified health centers)


Advanced APMs

Medicare Shared Savings Program

Tracks 2 & 3 only

Next Generation ACO Model

Comprehensive ESRD Care

Comprehensive Primary Care Plus (CPC+)

Oncology Care Model (OCM)

Two-sided risk track only (available in 2018)


QPs and Partial QPs

Be excluded from MIPS

Minimum % of patients/ payments through Advanced APM

Receive 5% lump sum bonus

Bonus applies in 2019-2024; QPs receive higher MPFS updates starting in 2026

QPs will:

QP Advanced APM Higher threshold

for Partial QPs

Partial QPs not eligible for bonus,

but can opt out of MIPS payment

adjustments


2017 CPS Components

Quality - 50%

Resource Use - 10%

Advancing CareInformation - 25%

Clinical PracticeImprovement Activities -15%


2018 CPS Components

Quality - 45%

Resource Use - 15%




2019 CPS Components

Quality - 30%

Resource Use - 30%




Participation Election

Individual Group

Each NPI who has reassigned to group’s TIN assessed as a group across all four MIPS performance categories.

Each NPI/TIN receives same composite performance score

OR


Hedging Bets

If group (TIN) reports, MIPS eligible clinician (NPI) may

also report individually for the same performance year

In adjustment year, CMS will assign the higher CPS (group or

individual) to NPI’s services billed under that TIN.

If NPI bills under multiple TINs during performance year,

the CPS for that NPI/TIN will apply in the adjustment

year


Musical Chairs

Scenario #1: NPI bills under TIN A in performance year,

bills under TIN B in adjustment year

NPI’s payments based on TIN A CPS (group or individual)

CPS follows the NPI, as opposed to NPI being subject to new

TIN’s CPS

Scenario #2: NPI bills under TIN A and TIN B in

performance year, bills under TIN C in adjustment year

CMS calculates weighted average CPS based on percentage of

allowed charges between TIN A and TIN B


Data Submission Options

Quality and Resource Use

Claims QCDR Qualified Registry EHR Vendors Administrative Claims

(No submission required)

Individual Reporting Group Reporting

Administrative Claims (No submission required)

QCDR Qualified Registry EHR Vendors CMS Web Interface (groups of

25 or more) CAHPS for MIPS Survey Administrative Claims


Administrative Claims (No submission required)

Quality

Resource Use


Data Submission Options

Advancing Care Information and CPIA

Attestation QCDR Qualified Registry EHR Vendors

Individual Reporting Group Reporting

Attestation QCDR Qualified Registry EHR Vendors Administrative Claims


Attestation QCDR Qualified Registry EHR Vendors CMS Web Interface (groups of

25+)

Attestation QCDR Qualified Registry EHR Vendors Administrative Claims


Advancing care

information

CPIA


Quality Component

Report on 6 measures

vs. PQRS - 9 measures with domain requirements

Select from individual measures (300+) or specialty measure sets (23 specialties)

1 cross-cutting measure

except for non-patient-facing MECs, i.e., 25 or fewer patient-facing encounters

1 outcome measure

or add’l high priority measure if no available outcome measure

Population measures calculated from claims data


Resource Use Component

For 2017, two measures calculated by CMS

based on Medicare claims data

Utilize current Value-Based Modifier Program

measures

CMS to develop multiple episode-based

efficiency measures


Clinical Practice Improvement Activity

Component

Minimum selection of one CPIA activity (from 90+

proposed activities) with additional credit for more

activities

Full credit for patient-centered medical home

Minimum half credit for APM participation


Advancing Care Information Component

F/K/A meaningful use

Scoring based on key measures of health IT

interoperability and information exchange.

Flexible scoring for all measures to promote care

coordination for better patient outcomes.

Key changes from meaningful use

Dropped “all or nothing” threshold for measurement

Removed redundant measures to alleviate reporting burden

Eliminated Clinical Provider Order Entry and Clinical Decision

Support objectives

Reduced the number of required public health registries to which

clinicians must report


APM Scoring Standard

Applies to participants in MIPS APMs (other than

QPs)

Advanced APMs

Track 1 MSSP ACO

Oncology Care Model (one-sided model)

Avoid multiple reporting requirements

Applies to all NPIs participating in APM as of last day of

performance period

NPI’s APM CPS trumps all other CPS (group or

individual)


Applying the APM Scoring Standard

Component weighting

50% quality

30% advancing care information

20% clinical practice improvement activities

Quality component score based on APM performance

measures

For ACI and CPIA components, each ACO participant

(TIN) reports as group.

CMS calculates APM’s scores for these components based on

the weighted mean average of TINs’ scores

Weighting based on # of MECs billing under each TIN

Calculating the CPS Category Scoring

Quality

Each measure 1-10 points compared to historical benchmark (if avail) 0 points for non-reported measures Bonus for reporting outcomes, patient experience, appropriate use, patient

safety, and EHR reporting Measures averaged to generate category score

Advancing care information

Base score of 60 points achieved by reporting at least one case for each available measure

Up to 10 additional performance points available per measure Total cap of 100 percentage points

CPIA Each activity worth 10 points Double weight for “high” value activities Sum of activity points compared to a target

Resource Use Similar to quality

1 Converts measures/activities to points

2 MECs know in advance what is required to achieve specific CPS

3 Partial credit available


Performance Threshold

Mean or median of composite performance score for all MECs for period prior to performance period

Score below threshold = penalty

Score above threshold = bonus


Adjustment Factor

Year Penalty Cap Bonus opportunity (subject to scaling factor)

2019 -4% Up to +12%

2020 -5% Up to +15%

2021 -7% Up to +21%

2022 -9% Up to +27%

Exceptional Performance Incentive Payment If meet or beat stretch goal, also receive payment from

annual $500 million incentive bonus pool (not to exceed 10 percent)

By no later than December 2 each year, CMS will make available each MEC’s (TIN/NPI) adjustment factor for upcoming year


Right Around the Corner

2018 2019

No change in payments; MECs report on 2017

performance

MECs receive payments based on 2019

adjustment factor (+ exceptional performance

incentives); MECs report on 2018 performance

CMS calculates MIPS composite performance

score for each MEC based on 2017 performance

CMS calculates MIPS composite performance

score for each MEC based on 2018 performance

CMS calculates and announces mean/median

composite performance score

CMS calculates and announces mean/median

composite performance score

CMS calculates and announces each MEC’s 2019

adjustment factor (based on 2017 performance

compared to mean/median composite

performance score)

CMS calculates and announces each MECs 2020

adjustment factor (based on 2018 performance

compared to mean/median composite

performance score)

CMS calculates and announces 2019 exceptional

performance incentive payments

CMS calculates and announces 2020 exceptional

performance incentive payments


Reputational Impact

▪ Each MEC’s composite and component scores

published on Physician Compare website

▪ MIPS-based decision-making

▪ Individual patients

▪ Provider networks

▪ Medical staff credentialing

▪ Professional liability insurance

▪ Others?

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