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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 2
Faculty
Martie Ross, JD
Principal| Pershing Yoakley & Associates
Degree: Juris Doctorate: University of Kansas School
of Law
Lawrence, KS
Contact: [email protected]
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 3
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.
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 4
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.
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 5
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.
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 6
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 9
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)
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 10
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 11
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 12
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 13
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)
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 14
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)
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 15
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 16
2017 CPS Components
Quality - 50%
Resource Use - 10%
Advancing CareInformation - 25%
Clinical PracticeImprovement Activities -15%
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 17
2018 CPS Components
Quality - 45%
Resource Use - 15%
Advancing CareInformation - 25%
Clinical PracticeImprovement Activities -15%
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 18
2019 CPS Components
Quality - 30%
Resource Use - 30%
Advancing CareInformation - 25%
Clinical PracticeImprovement Activities -15%
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 19
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 20
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 21
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 22
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
(No submission required)
Administrative Claims (No submission required)
Quality
Resource Use
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 23
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
(No submission required)
Attestation QCDR Qualified Registry EHR Vendors CMS Web Interface (groups of
25+)
Attestation QCDR Qualified Registry EHR Vendors Administrative Claims
(No submission required)
Advancing care
information
CPIA
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 24
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 25
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 26
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 27
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 28
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)
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 29
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 31
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 32
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 33
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
Webinar | The March to MIPS: Implementing Medicare’s New Merit-Based Incentive Payment System Page 34
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?
Top Related