2017 MACRA Final Rule Detailed Analysis - Advisory · 2016-11-30 · 2017 MACRA Final Rule Detailed Analysis Your Guide to the Transition Year . 6 2 3 4 1 ... House vote in 392-37

research technology consulting

Health Care IT Advisor

Ye Hoffman, MS, CPHIMS

Senior Analyst

November 29, 2016

2017 MACRA Final Rule

Detailed Analysis Your Guide to the Transition Year

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2

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1

Road Map

©2016 Advisory Board • All Rights Reserved • advisory.com

MACRA Essentials

Advanced Alternative Payment Models (Advanced APM)

Merit-Based Incentive Payment System (MIPS)

Your Guide to the Transition Year…and Beyond

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©2016 Advisory Board • All Rights Reserved • advisory.com • 34064

Advisory Board MACRA Webconferences

Overview and Detailed Analysis for All Members

MACRA: How the Final Rule Impacts

Providers

Available On Demand

• The basic framework CMS plans to use to

implement MACRA in 2017

• The most important changes in the final rule

• Next steps for provider organizations in

response to MACRA

2017 MACRA Final Rule Detailed Analysis:

Your Guide to the Transition Year

Today

• The details of 2017 MIPS/APM

requirements

• Action items on reporting and program

management

• Important areas for public comment

For More Advisory Board Resources on MACRA

https://www.advisory.com/macra

Source: Advisory Board research and analysis.

https://www.advisory.com/research/health-care-advisory-board/events/webconferences/2016/macra-how-the-final-rule-impacts-providers


https://www.advisory.com/Research/Health-Care-IT-Advisor/Events/Webconferences/2016/2017-MACRA-Final-Rule-Detailed-Analysis


https://www.advisory.com/macra

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MACRA Kicks Off in 2017, Affects 2019 Payments

Sources: CMS; Advisory Board research and analysis.

1) MIPS = Merit-Based Incentive Payment System.

2) APM = Alternative Payment Model.

3) CMS = Centers for Medicare & Medicaid Services.

Medicare Access and Children’s Health Insurance Program (CHIP)

Reauthorization Act of 2015 (MACRA) Implementation Timeline

October 14, 2016

CMS3 released final

rule with comment

period

April 27, 2016

CMS released proposed rule with

details for MIPS1 and APM2 tracks

and call for comments

January 2017

Performance period begins that

will determine applicable MIPS

or APM track; additional

performance periods offered

June 27, 2016

Comment period on proposed

rule closes

January 2019

First year of physician

payment adjustment

under MIPS or APM

April 16, 2015

MACRA signed into law

• Legislation passed in April 2015 that repealed the Sustainable Growth Rate (SGR)

• Locks Medicare Part B payment rates at near zero growth: 0.5% increase from

2015–2019, 0.0% increase from 2020–2025, 0.25% increase from 2026 and on for

MIPS participants

• Extra $500M for exceptional performers under MIPS; APM bonuses range from

$146M to $429M

MACRA in Brief

9


From Standalone Programs to an Integrated Initiative


1) Based on -2% PQRS, -4% VBPM, -3% MU.

MACRA Reduced Total Maximum

Penalties for Near-Term

-4%

Prior to MACRA, maximum penalty rate among

separate quality programs1

-9%

Under MACRA, 2019 maximum penalty rate

based on 2017 MIPS performance

MACRA Consolidates Previous Quality Reporting Programs

for Medicare Clinicians

2015 2024 2019

Physician Quality Reporting System

(PQRS)

MACRA:

MIPS/APM

Future Years 2011 2007

EHR Incentive Programs

(aka Meaningful Use)

Value-Based Payment Modifier

(VBPM)

MACRA Legislation Received

Strong Bipartisan Support

92-8 Senate vote in

favor of MACRA

House vote in

favor of MACRA 392-37

10


MACRA Creates CMS Quality Payment Program

Advanced Alternative Payment

Models (Advanced APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives: 5% annual bonus

in 2019–2024, and 0.75% annual payment

increase from 2026 on

Payment adjustments reach

-9% / +27% by 2022

Performance based on 4 categories:

Quality, Cost,1 IA,2 and ACI3

MACRA Does Not Impact MU4 for

Hospitals, Medicaid EPs5

MU as defined by Modified Stage 2 and

Stage 3 regulation and subsequently

modified under the 2017 OPPS6 rule,

continues on for hospitals and Medicaid EPs

1) Previously referred to as the Resource Use category; 2) Previously referred to as the Clinical Practice Improvement Activities

category; 3) ACI = Advancing Care Information; 4) MU = Meaningful use; 5) EPs = Eligible professionals; 6) OPPS = Hospital

Outpatient Prospective Payment System.

CMS Quality Payment Program

Sources: CMS, “Medicare Program; Merit-Based Incentive Payment System (MIPS)

and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule,

and Criteria for Physician-Focused Payment Models,” 81 FR 77008, November 4, 2016,

https://www.federalregister.gov/d/2016-25240; Advisory Board research and analysis.

Upcoming Webconference on

December 13, 2016 at 1pm ET

Register for our webconference on

“2016-2018 Meaningful Use Modifications:

Highlights from the Hospital Outpatient

Prospective Payment System Final Rule”

https://www.federalregister.gov/d/2016-25240



https://www.advisory.com/Research/Health-Care-IT-Advisor/Events/Webconferences/2016/2016-2018-Meaningful-Use-Modifications








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A Sweeping Impact Across Providers

Yet Awareness and Appreciation of MACRA’s Impact Is Low

Sources: CMS; Deloitte, 2016 US Survey of Physicians, available at

deloitte.com; Advisory Board research and analysis.

1) PAs = Physician assistants.

2) NPs = Nurse practitioners.

3) We note that additional provider types are included for APM track qualification: certified nurse-midwives, clinical social workers, clinical

psychologists, registered dietitians or nutrition professionals, physical or occupational therapists, qualified speech-language pathologists, and

qualified audiologists; and a group that includes these professionals.

Included

Medicare Part B payments

(i.e., clinician professional

payments)

Clinicians, groups that fall under

low volume threshold:

• $30,000 or less in Medicare

charges OR

• 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians, PAs,1 NPs,2

Clinical Nurse Specialists,

Certified Registered Nurse

Anesthetists3

Groups that include any of

the above clinicians

Excluded

Medicare Part A (i.e., inpatient,

outpatient technical hospital

payments)

Clinicians impacted by

MACRA per CMS estimate

712K Additional excluded

clinicians per Final Rule

124K Physicians surveyed

unaware of MACRA

50%

http://www2.deloitte.com/us/en/pages/life-sciences-and-health-care/articles/macra.html

12


Important Not to Crawl in MIPS

Aim To Run in MIPS; Non-Reporters Face Stiff Penalty


1) Projections based on CMS’s estimates included in Table 64 of the MIPS/APM

proposed rule: MIPS Proposed Rule Estimated Impact On Total Allowed Charges By

Practice Size.

“Crawl” Option

“Walk” Option

“Run” Option

1 2 3

• Submit minimum data for

a single category

• Avoid a negative payment

adjustment

• Submit more than minimum

data for at least 90 days

• May qualify for nominal

positive payment adjustment

• Submit all required data for

at least 90 days

• May qualify for modest

positive payment adjustment

• “Pick your pace” reporting options in 2017

• Increased exclusion thresholds for “low-

volume” providers

• All clinicians should be well poised to

avoid downward payment adjustments

! 2019 MIPS Potential Penalties1

$116K Small Practice

(20 providers)

Large Practice

(100 providers)

Medium Practice

(50 providers) $240K

$321K

Requirements Eased in Final Rule,

But Only for Short Term

13


Which Track Do I Qualify For?

Participate

in an

Advanced APM?

Meet

QP1

Threshold?

Meet

Partial QP

Threshold?

NO

YES

NO YES

APM

1

4

Must Know First Whether Payment Model Is an Advanced APM


1) QP = Qualifying participant.

MIPS Participate

in a

MIPS APM?

3

MIPS APM

Scoring

Standard

2

Exempt

from

MIPS

Optionally

Choose

MIPS?

YES

NO

NO

NO

YES

YES

14




ear up, get ready for MACRA “sea change”

nflect performance to improve MIPS standing

nderstand MACRA requirements

ngage with CMS to submit public comment

evelop your MACRA strategy

G

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Road Map


MACRA Essentials




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APM Payment Track Looks Enticing


0%

1%

2%

3%

4%

5%

6%

2015 2020 2025

2015–2019

0.5% annual

update

2020–2025

Frozen

payment rates Alternative Payment Model

Track: 2026 and on 0.75%

annual update

The Merit-Based Incentive

System: 2026 and on 0.25%

annual update

Baseline Payment Adjustments Under Each Track

2019–2024

APM track participants

receive 5% annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019–2024

to clinicians who qualify

for the APM track

5%

17


Two Requirements to Qualify for the APM Track

Must Be in an Advanced APM, and Be a Qualifying Participant


Participate

in an

Advanced APM?

Meet

QP

Threshold?

Meet

Partial QP

Threshold?

NO

YES

NO YES

APM

1

4 MIPS Participate

in a

MIPS APM?

3

MIPS APM

Scoring

Standard

2

Exempt

from

MIPS

Optionally

Choose

MIPS?

YES

NO

NO

NO

YES

YES

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Strict Advanced APM Eligibility Requirements

Sources: CMS, “Alternative Payment Models in the Quality Payment Program,”

https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf, October 14, 2016;

Advisory Board research and analysis.

Advanced APM Criteria

Advanced APMs Confirmed for 2017

Meet revenue-based

standard (average of at least

8% of revenues at risk for

participating APMs) or

Meet benchmark-based

standard (maximum possible

loss must be at least 3% of

spending target)

Certified EHR use

Quality requirements

comparable to MIPS

1) ESRD = End-stage renal disease.

2) LDO = Large dialysis organization.

3) CPC+ = Comprehensive Primary Care Plus.

4) MSSP = Medicare Shared Savings Program.

5) ACO = Accountable care organization.

Fin

an

cia

l R

isk C

rite

ria

2017 Medicare

Advanced APMs

Comprehensive ESRD1 Care LDO2

Arrangement

Comprehensive ESRD Care non-LDO

Arrangement (two-sided risk)

CPC+3

MSSP4 Track 2 and Track 3

Next Generation ACO5

Oncology Care Model (OCM, two-sided risk

arrangement)

2017 Medicare Advanced APMs

https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf

https://qpp.cms.gov/docs/QPP_Advanced_APMs_in_2017.pdf

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More Opportunity to Participate in Advanced APMs

CMS to Expand List of Qualifying Programs in 2018 and Beyond


1) CMMI = Center for Medicare and Medicaid Innovation.

2) BPCI = Bundled Payments for Care Improvement.

3) CJR = Comprehensive Care for Joint Replacement.

4) CEHRT = Certified electronic health record technology.

5) EPM = Episode Payment Model.

Anticipated Additions to Advanced APM List for 2018 Program Year

MSSP Track 1+

Two-sided risk track with less upside

reward but also less downside risk

than Track 2 and Track 3; expected

to begin in 2018

Voluntary Bundled Payment Model

CMMI1 considering a new

voluntary bundled payment model

for 2018; would build on BPCI2

CJR3 Payment Model (CEHRT4 Track)

Proposed rule allows for qualification as

an Advanced APM if participating

hospitals are using CEHRT

EPM5 Track 1 (CEHRT Track)

Proposed rule creates two tracks;

participants required to use CEHRT in

Track 1 of each EPM to qualify as

Advanced APM

Creation of Qualifying New Models Inclusion of Existing Models

Vermont Medicare ACO Initiative

CMS expects the Vermont Medicare ACO

program (part of Vermont’s new All-Payer

ACO Model) to be an Advanced APM

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APM Entity Must Meet Qualifying Participant Status

1) TIN = Tax identification number.

Variation in Volume Can Make or Break APM Track Determination

Clinicians currently projected by CMS to qualify

for APM track in 2019 payment year 10%–16%

APM Entities Must Meet Percent of

Payments or Patient Counts

25% 25%

50% 50%

75% 75%

20% 20%

35% 35%

50% 50%

2019 2020 2021 2022 2023 2024+

Payments through Advanced APMs

Patients in Advanced APMs

May Include Non-Medicare

Advanced APM

APM Entity 2

Payments = 33%

Example of 2019 Payment Qualification

APM Entity 1

Payments = 21%

TIN1 1 = X%

TIN 2 = Y%

TIN 3 = Z%


TIN 1 = X%

TIN 2 = Y%

TIN 3 = Z%

21


Almost, But Not Quite Qualifying for the APM Track

Some Groups Fall Just Below the QP Threshold, Can Choose MIPS


Participate

in an

Advanced APM?

Meet

QP

Threshold?

Meet

Partial QP

Threshold?

NO

YES

NO YES

APM

1

4 MIPS Participate

in a

MIPS APM?

3

MIPS APM

Scoring

Standard

2

Exempt

from

MIPS

Optionally

Choose

MIPS?

YES

NO

NO

NO

YES

YES

22


Lower Thresholds Set for Partial Qualifying Participants

Defining Partial QPs

• Clinicians who don’t meet QP thresholds but meet slightly lower thresholds

• Partial QPs do not qualify for APM track (5% participation bonus and 0.75% annual

update after 2026), but they do not have to participate in MIPS

• Partial QPs can choose whether to participate in MIPS track; if they decide against

MIPS, they will have no payment adjustment for that year

Minimum QP Threshold Minimum Partial QP Threshold

20%

40% 50%

25%

50%

75%

2019–2020 2021–2022 2023 and on

Payment, Patient Count Requirements for QPs, Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10%

25%

35% 20%

35%

50%

2019–2020 2021–2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment: Patient Count:


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Rolling Schedule to Determine APM Track Status

Three 2017 Determination Periods


1) Approximate date.

Determination

Period #1 • Designate whether QP or PQP

• Incorporate 60 days of claims

run-out in analysis

• Add QPs/PQPs; never reverse

previous designation

!

JAN 1 MAR 31 AUG 1

Determination

Period #2

JAN 1 JUN 30 NOV 1

Determination

Period #3

JAN 1 AUG 31 JAN 1, 2018

Participant List

Snapshot

Participant List

Snapshot

Participant List

Snapshot

Claims Data

Claims Data

Notice

Sent1

Notice

Sent1

Notice

Sent1

Track Assignment Notices

Claims Data

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Road Map


MACRA Essentials




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Several Paths Toward MIPS

Majority Will Participate in MIPS; Some Receive Preferential Scoring


Participate

in an

Advanced APM?

Meet

QP

Threshold?

Meet

Partial QP

Threshold?

NO

YES

NO YES

APM

1

4 MIPS Participate

in a

MIPS APM?

3

MIPS APM

Scoring

Standard

2

Exempt

from

MIPS

Optionally

Choose

MIPS?

YES

NO

NO

NO

YES

YES

26


2017 MIPS Performance Categories Executive Summary

Category Key Components Scoring & Weight1

• Over 200 measures to choose from, 80% of which are tailored

to specialists

• Providers required to report six measures, including one

outcome measure; in addition, all-cause readmissions will be

calculated based on claims for certain providers

Based on peer

benchmarks

• Not a component of MIPS performance in program year 2017

• CMS will include this category beginning 2018

• Over 90 activities to choose from; offers flexibility for many

provider types

• Preferential scoring for small practices, MIPS APM participants,

and PCMH2

Based on EC’s own

performance

• Applies to additional clinicians,3 unlike previous Medicare

Eligible Professional MU requirements (which applied only to

physicians)

• No longer requires “all-or-nothing” measure threshold reporting;

clinicians scored on participation and performance

Based on EC’s own

performance

1) Different weights apply to MIPS APM scoring standard.

2) PCMH = Patient-Centered Medical Homes.

3) MIPS eligible clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups that

include such clinicians. In 2017, Advancing Care Information (ACI) category may be reweighted to zero for non-physician clinicians.


Quality

(Previously

PQRS)

Cost

(Previously VBPM

cost component)

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

Clinicians currently projected by CMS subject

to the MIPS track for the 2019 payment year 621K

60%

25%

15%

0%

27


“Crawl, Walk, or Run” Approach to MIPS in 2017

Reporting Requirements and Financial Implications

Sources: CMS; CMS, “Quality Payment Program Overview,” https://www.cms.gov/Medicare/Quality-Initiatives-

Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-Quality-Payment-

Program-webinar-slides-10-26-16.pdf; Advisory Board research and analysis.

1) Additional pool of $500M available for exceptional performers that have a Composite

Performance Score (CPS) of 70 or higher in 2017.

Pick Your

Pace

Options

Reporting

Period

Performance

Category

Minimum Reporting

Requirements

Financial

Implications in

2019

“Crawl” • No required

reporting period

• Less than 90 days

permitted

Any:

• Quality, or

• IA, or

• ACI

Any:

• One Quality measure

• One IA

• “Base” ACI measures

• Avoid penalty

“Walk” • Minimum 90

continuous days

Any:

• Quality, or

• IA, or

• ACI

Any:

• ≥ 2 Quality measures

• ≥ 2 IAs

• “Base” and ≥ 1 “performance”

ACI measure(s)

• Avoid penalty

• Possible nominal

incentives

“Run” • Minimum 90

continuous days

• A full year is NOT

required

All Three

Categories:

• Quality, and

• IA, and

• ACI

Achieve Highest Points

Possible:

• 6 Quality measures,

• IAs sufficient for full credit

• “Base” and “performance” ACI

measures for full credit

• Avoid penalty

• Possible modest

incentives

• Possible exceptional

performance1

incentives

“A full year gives you the most measures to pick from. But if you report for 90 days,

you could still earn the max adjustment.” CMS

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-Quality-Payment-Program-webinar-slides-10-26-16.pdf




































28


ABCs of Submission Mechanisms in MIPS

Sources: CMS; Advisory Board research and analysis. ;

1) CAHPS = Consumer Assessment of Health Providers and Systems.

CMS Web Interface

Group practice reporting option via

CMS’ QualityNet web site

For more: see QualityNet

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more: certified EHRs available

Attestation or

Claims

Attestation: TBD; CMS may utilize

existing MU attestation portal

Claims: Coded data inputted

through claims

CAHPS1 Vendor

CMS-certified vendor used for

combined CAHPS and

MIPS reporting

For more: see currently approved

vendors

Qualified Clinical Data

Registry (QCDR)

Meets specific CMS qualifications

but scope of registry is not limited to

MIPS measures

For more: MIPS QCDR Self-

Nomination Fact Sheet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

MIPS measures

For more: MIPS Qualified Registry

Self-Nomination Fact Sheet

https://www.qualitynet.org/portal/server.pt/community/pqri_home/212

https://chpl.healthit.gov/#/search

http://www.pqrscahps.org/en/approved-vendor-list/

http://www.pqrscahps.org/en/approved-vendor-list/

https://qpp.cms.gov/docs/QPP_QCDR_Self-Nomination_Fact_Sheet.pdf



https://qpp.cms.gov/docs/QPP_Qualified_Registry_Self-Nomination_Fact_Sheet.pdf




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MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity


Note: the dark box denotes submission methods that allow reporting alignment opportunity.

1) Available for groups of 25 or more only.

2) Available for individual reporting only.

3) For groups only; must be a CMS-approved survey vendor for MIPS.

Submission

Methods

Qualified

Registry QCDR EHR

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

Improvement

Activities

ACI

MIPS Data Submission Mechanisms: Report Individually or as a Group

• Capability to report

measures for all MIPS

performance categories

• Ongoing compliance with

CMS vendor audits

• Record data in CEHRT

• Export and transmit data

electronically

• Option to use third-party

intermediary with automated

software

Vendor

Readiness End-to-End

Electronic

Reporting

Reporting Alignment Quality Bonus Points

30


REPORTING MECHANISM BENEFITS DRAWBACKS

Qualified

Registry

• Can consolidate data from different

sources

• May assist with performance monitoring

and practice improvement

• Subject to annual review and approval

• Measures limited to MIPS measures,

and what vendor can report

QCDR

• Same as Qualified Registry (see above)

• Non-MIPS Quality measures available;

may benefit specialists

• May earn IA credit for certain activities

• Subject to annual review and approval

• Measures may be limited in scope

EHR

• Ability to monitor and report eCQMs1

• May include analytics to track

performance across MIPS categories

• Quality measures must be certified by

vendor

• Must ensure compliance with the

required annual electronic specification

version

CMS Web

Interface

• Same measures required for MSSP and

Next Generation ACO; can serve as on-

ramp into the APM track

• Report only Medicare Quality data

• Groups measured against MSSP and

Next Generation ACO participants

• Must report all required Quality

measures for a full year

Pros and Cons of Reporting Mechanisms

Focus on Four Aligned Mechanisms


Access the Meaningful Use Registry List (MURL), a catalog of specialty society

clinical data registries; available on advisory.com (November 2015)

Related Tool

1) eCQMs = Electronic Clinical Quality Measures.

http://www.advisory.com/Research/Health-Care-IT-Advisor/Tools/2015/MU-Registry-List

31


Key Considerations Individual (TIN/NPI1) Reporting Consider this option if your group:

Group (TIN) Reporting Consider this option if your group:

Performance

across categories

Includes a mix of providers, with

some that would otherwise be excluded

from MIPS,2 or are eligible for certain

categories to be reweighted to zero3

Includes a majority of high

performers that can boost a few

low performers

Administrative

complexity

Can support the administrative

resources to monitor and report

performance individually (e.g., specific

quality measures for each EC)

Supports a large number of ECs

and/or aims to reduce

administrative complexity (e.g.,

reduce reporting burden, and

receive the same score for all ECs)

Technical capability

Deploys a heterogeneous IT

environment (e.g., multiple practice

locations with different EHRs)

Deploys a homogenous IT

environment (e.g., a system-wide

EHR with high adoption rates

across all ECs)

Experience with

CMS programs

Used individual reporting to submit

quality measures for PQRS (e.g.,

through claims)

Used group reporting to submit

quality measures for PQRS

MIPS Individual v. Group (or Both?) Reporting Choices


1) NPI = National Provider Identifier.

2) For example, low-patient volume, new Medicare-enrolled providers, APM track participants are excluded from MIPS payment adjustments.

3) For example, the ACI category may be reweighted to zero for hospitalists, non-patient facing ECs, and advanced practitioners.

Decision Must Be Applied Across All MIPS Categories Reported

32


“Special” MIPS APM1 Scoring in MIPS


Different Category Weights for ECs Without QP Status or in MIPS APMs

2017 Medicare

Advanced APMs

2017

MIPS APMs

Comprehensive ESRD1

Care LDO Arrangement

Comprehensive ESRD

Care non-LDO

Arrangements (one-

sided risk)

Comprehensive ESRD

Care non-LDO

Arrangement (two-

sided risk)

MSSP Track 1

CPC+ OCM (one-sided risk

arrangement)

MSSP Tracks 2 and 3

Next Generation ACO

OCM (two-sided risk

arrangement)

1) CMS defines a MIPS APM as an APM that meets the following criteria: (1) APM Entities

participate in the APM under an agreement with CMS or by law or regulation; (2) the APM

requires that APM Entities include at least one MIPS eligible clinician on a Participation List; and

(3) the APM bases payment incentives on performance (either at the APM Entity or eligible

clinician level) on cost/utilization and quality measures.

2) Participant list snapshots taken on March 31, June 30, August 31, 2017. Each snapshot adds

participants, never reverses previous designation.

Below QP Volume

Threshold in Advanced

APM

Any Volume

in MIPS APM

Applies2 to Two MIPS EC Scenarios Comparison Between MIPS and MIPS

APM Category Weights in 2017

25% 30% 30%

75% 15%

20% 20%

25%

60% 50% 50%

MIPS MSSP Next Gen Other APMs

Quality

Cost

Improvement Activities (IAs)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

33


MIPS Payment Adjustments: 3 Is the “Magic Number”


1) Payment adjustment size corresponds with how far the score deviates from the PT.

2) Additional pool of $500M available for exceptional performers to receive additional

incentive of up to 10% for MIPS-eligible providers that exceed the 25th percentile above

the PT.

-10%

0%

10%

20%

30%

Maximum EC Penalties and Bonuses

2019 2020 2021 2022+

4%

-4%

5%

-5%

7%

-7%

9%

-9%

12%

15%

21%

27%

Budget

neutrality

adjustment:

Scaling factor

up to 3x may

be applied to

upward

adjustment to

ensure payout

pool equals

penalty pool Pa

ym

en

t a

dju

stm

en

t

Payment Adjustment Determination

1

2

3

Dashed light gray line

reflects up to 10%

additional incentive2 for

exceptional performers

ECs assigned score of

0–100 based on performance

across three categories

Score compared to CMS-set

performance threshold (PT);

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment; a

score below PT results in a

downward adjustment1

Year

Strong Performers Benefit at Expense of Non-Reporters

Non-reporting

participants given

lowest score

2019 PT Established per Final Rule

CMS set the PT to 3 to avoid a negative payment

adjustment, and 70 to earn exceptional

performance bonus.

!

22%

25%

31%

37%

40%

34

2

3

4

1

Road Map


MACRA Essentials




35




ear up, get ready for MACRA “sea change”

nflect performance to improve MIPS standing

nderstand MACRA requirements

ngage with CMS to submit public comment

evelop your MACRA strategy

G

U

I

D

E

36


MACRA Part of Public Payer “Sea Change”

1) Gear up, get ready for MACRA “sea change”


Chosen Method: Medicare-

Led Payment Reform

• FFS1 cuts

• New payment models

• Intent to catalyze broader

commercial market change

1 2 3

Chosen Method: Incentives and

Transparency

• IT mandates

• Pay-for-performance programs

• Market-facing transparency

Chosen Method: Expansion

of Existing System

• Insurance market regulation

• Expanded public coverage

• Market-based exchanges

Replace Costly Fee-for-

Service Incentive Structures

Improve Health

Care Quality

Achieve Universal,

Affordable Coverage

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Major Health Care Reform Goals

1) FFS = Fee for service.

37


Public Payer Data Important to Private Payers

No Provider Can Ignore Quality Reporting

1) Gear up, get ready for MACRA “sea change”

Sources: Blue Cross Blue Shield of Illinois; Advisory Board research and analysis.

1) NCQA = National Committee for Quality Assurance.

What I See on My Provider’s Profile Today

Currently shows awards and recognitions in CMS

and other quality reporting programs. In this real-

world example: NCQA1; Bridges to Excellence;

CMS EHR Incentive Programs.

Implications for Providers

• Commercial payers use publically reported

data to help inform plan participants’ about

provider performance

• Information may influence consumer choice

• Publically reported performance data may also

be used to set provider rates and/or whether

they are considered a preferred provider

• APM and MIPS performance indicators will be

published on Physician Compare, and may be

used by commercial payers in the future

!

38


Quality Reporting Resources to Support You

Webconferences Tools Research

• MACRA: How the Final Rule

Impacts Providers

• 2017 MACRA Final Rule

Detailed Analysis: Your Guide

to the Transition Year

• 2016-2018 Meaningful Use

Modifications, scheduled

December 13 at 1:00pm

Eastern

• The Implications for Health

Care IT Vendors, scheduled

December 15 at 3:00pm

Eastern

• The No-Regrets Approach to

MACRA: How to Prepare

During Rulemaking

• 2017 Merit-Based Incentive

Payment System Measures

• Your questions about the

MACRA proposed rule–

answered

• Health Care IT Advisor

MACRA Cheat Sheet

• MACRA Cheat Sheet for

Industry

• Build Efficient Quality

Reporting with Streamlined

Quality and IT Efforts

• 5 Steps to Succeed in the

MIPS Quality Category

• Meaningful Use gets a facelift

under MACRA—but is it

better? Here's our view

• 2016 Eligible Professional

Quality Reporting: CMS

Offers More Flexible

Reporting Options, But It’s

Time to Align


2) Understand MACRA requirements

For These and Forthcoming Resources on MACRA https://www.advisory.com/macra















https://www.advisory.com/Research/Health-Care-IT-Advisor/Events/Webconferences/2016/2017-MACRA-Final-Rule-Implications-for-Health-Care-IT-Vendors



https://www.advisory.com/research/physician-practice-roundtable/members/events/webconferences/2016/the-no-regrets-approach-to-macra-how-to-prepare-during-rulemaking/ondemand







https://www.advisory.com/sitecore/content/Home/Research/Health-Care-IT-Advisor/Tools/2016/Final-MIPS-Measure-List




https://www.advisory.com/research/physician-practice-roundtable/members/expert-insights/2016/nine-faqs-on-provider-payment-under-macra






https://www.advisory.com/research/health-care-it-advisor/resources/2014/cheat-sheets/legal-landmarks

https://www.advisory.com/research/health-care-it-advisor/resources/2014/cheat-sheets/legal-landmarks

https://www.advisory.com/Research/Health-Care-Industry-Committee/Members/Resources/Cheat-Sheets/MACRA

https://www.advisory.com/Research/Health-Care-Industry-Committee/Members/Resources/Cheat-Sheets/MACRA

https://www.advisory.com/research/health-care-it-advisor/research-notes/2016/hospital-quality-reporting-build-efficiency



https://www.advisory.com/Research/Health-Care-IT-Advisor/Expert-Insights/2016/5-steps-to-succeed-in-the-MIPS-quality-category

https://www.advisory.com/Research/Health-Care-IT-Advisor/Expert-Insights/2016/5-steps-to-succeed-in-the-MIPS-quality-category

https://www.advisory.com/daily-briefing/2016/04/29/mu-macra







https://www.advisory.com/Research/Health-Care-IT-Advisor/Research-Notes/2016/2016-Eligible-Professional-Quality-Reporting





https://www.advisory.com/topics/strategy/market-trends/macra

https://www.advisory.com/topics/strategy/market-trends/macra

39


Detailed Resources Available in Appendix

Included in Today’s Presentation Slides

2) Understand MACRA requirements

Acronym List

Pocket Guides for MIPS

ACI Measures

APM QP Calculation

Information

MIPS Performance

Category Guides

MIPS Reporting for MSSP

and Next Generation ACOs

Presentation Slides Available at:

https://www.advisory.com/Research/Health-Care-IT-

Advisor/Events/Webconferences/2016/2017-MACRA-Final-

Rule-Detailed-Analysis


















40


Aim for Highest Possible Performance

Most Categories Derive from an Existing CMS Program

3) Inflect performance to improve MIPS standing


1) QRUR = Quality and Resource Use Reports.

Review 2017 Finalized MIPS Measures

See Health Care IT Advisor tool, “2017 MIPS Measures” (November 2016)

Quality

Gauge performance on

PQRS measures, and

consider new MIPS

measures

Cost

Evaluate episode cost

measures on QRUR1 per

VBPM requirements

ACI

Review MU dashboards

and analyze

performance under new

scoring methodology

IA

Assess CMS inventory

to determine which

improvement activities

are currently performed

1 2 3 4


41


MACRA Is a Team Sport

It Takes a Village to Drive MACRA Success

4) Develop your MACRA strategy


Key Players in MACRA Governance Structure

Finance and Health Information

Management

• Understand and forecast MACRA

reimbursement implications

• Optimize coding practices to support

accurate risk adjustment

Policy Experts

• Monitor regulatory changes and

determine strategic and operational

implications

• Educate leadership and front-line

staff on relevant policies

Clinical and Operational Leaders

• Provide input to measure selection

and clinical workflows

• Communicate performance to all

relevant stakeholders

• Develop strategies to improve

performance and drive staff adoption

IT Department

• Implement and configure IT systems

to optimize data collection

• Support data extraction, mapping,

consolidation, and reporting

• Provide technical guidance on

performance reports

42


Which Pace Do You Pick?

Plan Your Approach Based on Experience with Existing CMS Programs

4) Develop your MACRA strategy


1) For example, Qualified Registry or QCDR.

2) Additional pool of $500M available for exceptional performers that

achieve a MIPS Composite Performance Score that exceeds 70 for

the 2017 performance period.

Avoid negative payment

adjustment

• IA. At minimum, report at least

one activity

• Quality. Report at least one

measure, if possible

• ACI. Report ACI minimum

requirements, if technically

feasible

Neither PQRS nor MU Either PQRS or MU Both PQRS and MU

Potentially earn small

positive adjustment

Aim for exceptional

performance2

• IA. Achieve full performance

• Quality. Engage EHR vendor

or registry1 to report, if

feasible, and maximize

performance and bonus points

• ACI. Report minimum ACI

requirements, if feasible, and

maximize performance and

bonus points

• IA. Achieve full performance,

and prioritize reporting

activities that use CEHRT

• Quality. Maximize

performance and bonus points

• ACI. Maximize performance

and bonus points

Report at least 90 days, aim for full year

43


Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

5) Engage with CMS to submit public comment


• Eligible clinician definition. CMS may expand

ECs to include additional types of providers (e.g.,

physical therapists) in year 3 and beyond

• APM track. Non-Medicare APMs’ contribution

toward QP determinations in year 3 and beyond

• Virtual groups. CMS has yet to establish virtual

groups to assist solo and small practices in MIPS

• Facility-based clinicians. Policies to apply a

facility’s performance to a MIPS clinician have yet

to be determined

• MIPS APM scoring. CMS has yet to determine

Quality scoring methodology for non-MSSP,

non-Next Generation ACO payment models

• MIPS Quality category. Maximum score for

topped-out measures may be limited in future

years

• MIPS Cost category. CMS will include new

episode-based measures and potentially Part D

drug costs

!

Key Considerations for Public Comment

November

CMS publishes annual

MIPS/APM Final Rule

January

Performance period starts

2 months after

requirements are finalized

DEC 19

Public comment closes on

December 19, 2016 for the

MIPS/APM final rule with

comment period

Annual MIPS/APM Rulemaking

Expected

https://www.federalregister.gov/documents/2016/11/04/2016-25240/medicare-program-merit-based-incentive-payment-system-and-alternative-payment-model-incentive-under

44


44

Key Takeaways from the 2017 MIPS/APM Final Rule

MACRA Has

Significant Impact

The law fundamentally

changes how Medicare pays

physicians and other

clinicians

Most Providers

Avoid Penalty in 2017

Aim to hit the ground running

in 2017 to get a head start

and avoid penalties in future

years

Plan for Future

Rulemaking and Audits

Providers should submit

annual public comment to help

shape the future of the

program and prepare for audits


MACRA Is the “New Normal”

Forthcoming Audit Checklist in 2017

Clinicians must retain documentation to support both APM and MIPS. For

example, CMS recommends clinicians retain records for 10 years, and audits

may occur for 6 years 3 months, or anytime thereafter if fraud is suspected.

!

1) MIPS-eligible clinicians and groups should retain copies of medical records, charts, reports, and

any electronic data utilized to determine which measures and activities.

45


The Advisory Board’s Suite of MACRA Solutions

Targeted Offerings to Meet Your Organization’s Needs

Organizations that need

foundational understanding of

MACRA across key stakeholder

groups

Organizations that need to assess

readiness and confirm strategic

planning approach

Organizations that need

ongoing strategic guidance

and long-term program

management support

Additional Custom Strategic Support Available

Recommended For:

• Hands-on support to help organizations design and implement large-scale business transformation needed for

health care reform

• Areas of expertise include value-based payment models, physician alignment, and EHR optimization

Research Memberships MACRA Intensive Quality Reporting Roundtable

• Publications, web

conferences, and blog posts

that cover the key

requirements of MACRA and

implications for providers

• On-site policy briefing

available for key stakeholders

• On-site session designed to

identify readiness gaps and

develop implementation strategy

• Three parts: policy education;

performance assessment; and

strategic discussion with

leadership

• Service to help providers

navigate quality reporting

programs requirements,

including MACRA and

Meaningful Use

• On-call experts, policy

monitoring, audit support,

best practices, and

networking opportunities

Quality Reporting

Roundtable

1 4 3

Experts

On-Call

Audit

Support

Successful

Practices

2

Alerts &

Monitoring

5

Networking

6

Strategic

Alignment

MIPS, APM, Meaningful Use, Physician Quality Reporting System (PQRS),

Value-Based Payment Modifier (VBPM), Inpatient Quality Reporting Program (IQR)

Areas of Expertise:

7

Scorecard

Option

49

Appendix 2017 MACRA Final Rule Detailed Analysis

50


50

Commonly Used Acronyms


• MACRA: Medicare Access and Children’s

Health Insurance Program (CHIP)

Reauthorization Act of 2015

• MU: Meaningful Use

• MIPS: Merit-Based Incentive Payment System

• MIPS APM: Special kinds of APMs that qualify

for preferential MIPS scoring

• OPPS: Outpatient Prospective Payment

System Rule

• PQP: Partial Qualifying APM Participant

• PQRS: Physician Quality Reporting System

• QP: Qualifying APM Participant

• VBPM: Value-Based Payment Modifier

• ACI: Advancing Care Information

• APM: Alternative Payment Model

• Advanced APM: APM potentially eligible for

APM track incentives

• APM Entity: Group that participates in an

APM

• CMS: Centers for Medicare & Medicaid

Services

• EC: Eligible clinician, a provider subject to

MACRA

• IA: Improvement Activities, previously Clinical

Practice Improvement Activities (CPIA)

• IPPS: Inpatient Prospective Payment System

Rule

51


The Math Behind APM Track QP Thresholds

1) Medicare Part B-covered professional services; 2) During the performance period; 3) Evaluation and management;

4) CMS will modify this criterion for APMs that do not base attribution on E&M services through further rulemaking or other notification

processes.

Payment threshold

25%

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

20%

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services1,2

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services1,2

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 E&M3 claim

within the APM entity4

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6


52


MIPS Quality Performance Category

Dominant Component in MIPS Score; Significant Flexibility in Measures

Sources: CMS; Advisory Board interviews and analysis.

Scoring Takeaways

• In general, each measure is worth a maximum

of 10 points

• Performance points assigned for a measure based on

performance against peer benchmark

• In 2017, CMS will reward 3 points for any reported

measure, regardless of whether it meets data

completeness, is below case minimum threshold,5 has a

benchmark, has 0% performance, or includes data for less

than 90 days

• Scoring policies and number of CMS Web Interface

measures required differ from other reporting mechanisms

6 Measures 1 Population-Based

Measure4

10 Pts

Outcome

Measure2

10 Pts 10 Pts 10 Pts 3 Pts 10 Pts 10 Pts Category in Brief: Quality

How Scoring Works

All-Cause Readmission

Class 2

Measure3

1) Different data completeness requirements apply to Claims-based and Web Interface reporting.

2) At least one outcome measure is required, or another high priority measure if outcome

measures are not applicable.

3) Defined as measures that do not have an established benchmark and therefore cannot be scored

based on performance. Automatically assigned 3 points regardless of performance.

4) Based on administrative claims, no reporting required.

5) General case requirement is 20 cases. Case requirement for All-Cause Readmissions is 200 cases.

• Nearly 300 measures to choose from,

80% tailored to specialists

• Most ECs required to report six

measures, if applicable

• If reporting as a group of ≥16 ECs, the

All-Cause Readmissions population-

based measure applies based on claims

data

• 50% all-payer data completeness

requirement for 2017, rises to 60% for

nearly all reporting mechanisms1

• No longer requires a cross-cutting

measure

• Two ways to earn bonus points:

additional high-priority measures, and

end-to-end electronic reporting

53


MIPS Cost Performance Category

New Cost Measures; Performance Assessment Based on Claims


Scoring Takeaways

• Measures are equally weighted for a maximum of 10

points each

• A measure is included in the scoring only if minimum

case requirement is met, so the total possible points

can vary between ECs

• Points assigned for a measure based on

performance against peer benchmark

• 2017 cost performance will be provided to ECs for

informational purposes

Category in Brief: Cost

MSPB Up to 10 Episode-based measures

10 Pts N/A 10 Pts 10 Pts 10 Pts N/A

Below Case

Threshold No Attributed

Cases

Total per Capita

How Scoring Works

1) Cost category will be included beginning 2018, but continues to be weighted 0% for

MIPS APM scoring.

2) MSPB = Medicare spending per beneficiary.

• Not included in 2017 MIPS

final score1

• Assesses cost based on:

– Total cost per capita

– MSPB2

– Episode-based measures, as

applicable

• CMS will use data submitted

through administrative claims

to determine performance; no

additional reporting required

• Minimum of 20 cases required

for Total Cost and Episode-

based measures; 35 for MSPB

54


MIPS Improvement Activities Performance Category

Several Paths to Full Credit; Differences in Weighting Provide Flexibility


1) HPSA = Health Professional Shortage Areas.

2) For 2017, CMS afforded full credit for MIPS APM scoring based on assessment of activities required by each payment model,

see https://qpp.cms.gov/docs/QPP_APMs_and_Improvement_Activities.pdf.

Two Measure Types

H High-weighted activity: 20 points

Medium-weighted activity: 10 points

How Scoring Works

Achieve 40 points in 2017 for full credit

• Any combination of high-weighted or medium-

weighted activities

• Small, rural, HPSA1 practices, and non-patient-

facing ECs earn double points per activity

• PCMH earns full credit; MIPS APM earns at least

half credit2

IMPORTANT: Retain Support Documentation

Sample of High-Weight Activities

• Use of a QCDR to generate regular

performance feedback summarizing local

practice patterns, outcomes

• 24/7 access to MIPS eligible clinicians

• Participation in the CMS Transforming

Clinical Practice Initiative (TCPI)

We recommend that medical groups retain documentation supporting that

the IA was performed for at least 90 days during the performance period

M

Example Reported Activities Points

Earned

1 40

2 40

3 40

H H

M M H

M M M M

https://qpp.cms.gov/docs/QPP_APMs_and_Improvement_Activities.pdf

55


MIPS ACI Performance Category

New Name for MU; Rewards Participation and Performance


1) Hospital-based clinicians, non-patient facing clinicians, advanced practitioners, and clinicians that qualify for significant hardship.

2) To earn the Base Score, report “Yes” for Security Risk Analysis, and at least 1 in the numerator for all other required measures.

3) Request/access summary of care is required under Stage 3-equivalent option. This measure is not included for Modified Stage 2-equivalent option.

4) Score based on each measure’s performance rate.

Scoring Components

How Scoring Works: Two Paths to 100 in 2017

Category in Brief: ACI

• Abandons “all-or-nothing”

approach to Meaningful

Use thresholds; offers

measure selection

flexibility

• In 2017 only, option to

report Modified Stage 2-

equivalent ACI measures

with 2014 Edition CEHRT

• Starting 2018, all ECs

must report Stage 3-

equivalent ACI measures

with 2015 Edition CEHRT

• Category may be

reweighted to zero for

certain types of providers1

Performance Score

50 Pts

Possible Points

Base Score

Stage 3-equivalent

• Security risk analysis

• Electronic prescribing

• Provide patient access

• Send a summary of care

• Stage 3-equivalent:

Request/access summary

of care3

10

= 155 Pts

• Stage 3-equivalent:

9 available measures

• Modified Stage 2-equivalent:

7 available measures

Base Score2 Performance Score4

• 10 points for using CEHRT in IA

• 5 points for public health reporting

beyond Immunization Registry

10 10 10 10 10 10 10 10

Modified Stage 2-equivalent

10 10 10 10 10 20 20

Bonus Score

10 5

Bonus Score

- OR -

56


ACI Pocket Guide: Modified Stage 2 MU in 2017 Only

Sources: CMS; Advisory Board research and analysis. Pocket Guide

dated November 29, 2016.

Security Risk

Analysis

Electronic

Prescribing

Provide

Patient

Access1

Health

Information

Exchange

Up to 20% Up to 20%

Note: The red box indicates measures required for the base score (50%). A dark grey box indicates a measure that contributes

toward the performance score.

1) All three functionalities (view, download, and transmit - VDT) must be present and accessible to meet the measure.

2) Providers can earn a 5% bonus if they report any of these public health measures.

3) Providers can earn a 10% bonus in the MIPS ACI category if they report that they use CEHRT to carry out any activity in the

MIPS Improvement Activities category.

Patient-Specific

Education

Secure

Messaging

View, Download,

or Transmit

Medication

Reconciliation

Up to 10% Up to 10% Up to 10% Up to 10%

0% or 10%

Immunization

Registry

5% Bonus2

10% Bonus3

Report

Improvement

Activities Using

CEHRT

Syndromic

Surveillance

Specialized

Registry

Required

57


ACI Pocket Guide: Correlates to Stage 3 MU

Sources: CMS; Advisory Board research and analysis. Pocket Guide

dated November 29, 2016.

Security Risk

Analysis

Electronic

Prescribing

Provide

Patient

Access1

Send a

Summary of

Care

Request/Accept

Summary of

Care

Up to 10% Up to 10% Up to 10%

Note: The red box indicates measures required for the base score (50%). A dark grey box indicates a measure that contributes

toward the performance score.

1) All three functionalities (view, download, and transmit - VDT) and an API must be present and accessible to meet the measure.

2) Providers can earn a 5% bonus if they report any of these public health measures.

3) Providers can earn a 10% bonus in the MIPS ACI category if they report that they use CEHRT to carry out any activity in the

MIPS Improvement Activities category.

View,

Download, or

Transmit

Secure

Messaging

Patient-

Generated

Health Data

Patient-

Specific

Education

Clinical

Information

Reconciliation

Up to 10% Up to 10% Up to 10% Up to 10% Up to 10%

0% or 10%

Immunization

Registry

5% Bonus2

10% Bonus3

Report

Improvement

Activities Using

CEHRT

Syndromic

Surveillance

Electronic Case

Reporting

Clinical Data

Registry

Required

Public Health

Registry

58


2017 MSSP ACO MIPS Reporting

MIPS Scored at APM Entity Level; Report ACI at the Group TIN Level


1) Also applies to PQPs that choose to participate in MIPS.

2) Finalized 2017 CMS Web Interface measures includes a 2-component diabetes composite measure.

3) Scores for Improvement Activities in MIPS APMs in the 2017 Performance Period,

https://qpp.cms.gov/docs/QPP_APMs_and_Improvement_Activities.pdf.

4) MIPS APM participants receive at minimum one half of the total possible points.

• Reporting aligned with

ACO requirements; no

separate reporting

required for MIPS

• Measures submitted

through CMS Web

Interface by ACO on behalf

of MIPS ECs

• CMS Web Interface

reporting contains 14

measures2

Quality

• No additional MIPS

reporting required in 2017

• CMS afforded full category

score3 based on ACO-

required activities

• In future years, additional

reporting may be required

by the ACO if the CMS-

assigned points do not

yield the full category

score4

Improvement Activities

• Additional MIPS reporting

required for this category

independent of the ACO

• Report data through

respective ACO

participant billing TINs

• Scores from all ACO

participant TINs are

aggregated to yield a

weighted average APM

Entity group score

ACI

Applies to All MSSP Track 1 ACOs, and Tracks 2 and 3 ACOs Below QP1 Volume Threshold



59


2017 Next Generation ACO MIPS Reporting

MIPS Scored at APM Entity Level; Report ACI at Individual or Group Level


1) Also applies to PQPs that choose to participate in MIPS.

2) Finalized 2017 CMS Web Interface measures includes a 2-component diabetes composite measure.

3) Scores for Improvement Activities in MIPS APMs in the 2017 Performance Period,

https://qpp.cms.gov/docs/QPP_APMs_and_Improvement_Activities.pdf.

4) MIPS APM participants receive at minimum one half of the total possible points.

5) The score will be the highest attributable score, which may be derived from either group or individual reporting.

Applies to Next Generation ACO Entities Below QP1 Volume Threshold

• Reporting aligned with

ACO requirements; no

separate reporting

required for MIPS

• Measures submitted

through CMS Web

Interface by ACO on behalf

of MIPS ECs

• CMS Web Interface

reporting contains 14

measures2

Quality

• No additional MIPS

reporting required in 2017

• CMS afforded full category

score3 based on ACO-

required activities

• In future years, additional

reporting may be required

by the ACO if the CMS-

assigned points do not

yield the full category

score4

Improvement Activities

• Additional MIPS reporting

required for this category

independent of the ACO

• ECs can report individual

level (NPI/TIN) or group

level (TIN) data

• CMS will attribute one

score4 to each MIPS EC,

and scores for all MIPS

ECs in the APM Entity

group are averaged to

yield a single APM Entity

group score

ACI



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