MACRAJason Felts, MS

HIT Practice Advisor

2

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Mission of OFMQOFMQ is a not-for-profit, consulting company

dedicated to advancing healthcare quality. Since 1972, we’ve been a trusted resource through

collaborative partnerships and hands-on support to healthcare communities.

OFMQ Areas of Expertise• Analytics

• Case Review

• Education

• HIPAA

• IT Consulting

• Health Information Technology

• National Quality Measures

• Quality Improvement

HIT Service Lines

• HIPAA/Meaningful Use Security Risk Assessment -Level 1, 2, and 3

• Meaningful Use Assistance

• Meaningful Use Audit Support

• Risk Management Consulting and Development

• Staff HIPAA Security Training

• Website Development & Secure Email

• IT Consulting

Jason Felts, MS

• Jason Felts has more than eight years of experience in healthcare and currently works as a Health Information Technology (HIT) Practice Advisor. Throughout his time with OFMQ Jason has worked on multiple Health IT and quality improvement projects through the Office of the National Coordinator for Health IT, the Centers for Medicare and Medicaid Services, the Agency for Healthcare Research and Quality, and the Oklahoma State Department of Health. Jason works as a consultant to multiple physician practices and hospitals throughout the state on EHR incentive programs, workflow redesign, privacy & security, and many other healthcare related matters.

Overview of the MACRA

• What is MACRA?

• Who’s eligible?

• When does it take effect?

• Participation options

• Next steps…

MACRA

• Medicare Access & CHIP Reauthorization Act of 2015– Bipartisan legislation signed into law April 16, 2015

– Notice of Proposed Rule Making released April 27, 2016

– Repeals the Sustainable Growth Rate (SGR) formula• Factor in reimbursement rates

– New framework to reward clinicians for the value and quality of care they provide• “Quality Payment Program” (QPP)

Quality Payment Program

• The new QPP will include 2 pathways:

Merit-based Incentive Payment

System (MIPS)

Advanced Alternative

Payment Models (APMs)

MIPS Eligibility

• MIPS eligible clinicians include:– Physicians (MD/DO)

– PAs

– Nurse practitioners

– Clinical nurse specialists

– Certified registered nurse anesthetists

• Plans to include other clinicians in the future (physicals therapists, occupational therapists, registered dieticians, etc.)

MIPS Eligible Clinicians

ECs can participate in MIPS as an individual or a group

Individual vs. Group

• A group, defined by TIN, would be evaluated as a group practice across all 4 MIPS performance categories

MIPS Exemptions

• Newly Medicare-enrolled ECs– First year of Part B participation

• Clinicians below low patient volume threshold– Medicare charges ≤ $10,000 and fewer than 100

Medicare patients in one year

• Certain participants in Advanced APMs

• MIPS does not apply to hospitals or facilities (i.e. FQHCs, RHCs, Skilled Nursing)

Proposed MIPS Timeline

2017

• Performance Period (Jan-Dec)

• 1st Feedback Report (July)

2018

• Reporting and Data Collection

• 2nd Feedback Report (July)

2019

• MIPS Adjustments in Effect

Payment Adjustments

2019 +/- 4%

2020 +/- 5%

2021 +/- 6%

2022 onward +/- 9%

Based on a MIPS Composite Performance Score, clinicians will receive a +/- or neutral adjustment

APMs

• Give CMS new ways to pay health care providers for the care they give

• QP – Qualifying APM Participant• Examples include:

– Accountable Care Organizations (ACOs)• Groups of providers that voluntarily come together to

provide coordinated care

– Patient Centered Medical Homes (PCMH)– Bundled payment models

• Bundle payments for multiple services during one episode of care

Advanced APMs

• Models or programs in which clinicians accept both risk and reward for providing coordinated, high-quality, and efficient care.

• These models must meet criteria for payment based on quality measurement and the use of EHRs.

• There are specific criteria for determining what qualifies as an Advanced APM

Advanced APMs

• Clinicians who participate to a certain extent would be exempt from MIPS payment adjustments and qualify for a 5% Medicare Part B incentive payment.

• To qualify for incentive payments, clinicians must receive enough of their payments or see enough patients through the Advanced APM.

List of Advanced APMs

• CMS would update this list annually to add new payment models

Comprehensive ESRD Care Model (Large

Dialysis Organization arrangement)

Medicare Shared Savings Program –

Track 3

ComprhensivePrimary Care Plus

(CPC+)

Next Generation ACO Model

Medicare Shared Savings Program –

Track 2

Oncology Care Model Two-Sided Risk Arrangement

(available 2018)

PERFORMANCE CATEGORIES & SCORING

MIPS

• 4 Performance Categories:

– Quality

– Cost (Resource Use)

– Clinical Practice Improvement Activities

– Advancing Care Information

• Weight given to each section may change depending on performance and CMS focus

Quality50%Advancing Care

Information25%

Clinical Practice Improvement

Activities 15%

Cost10%

MIPS Composite Performance Score

Quality

• 50% of total MIPS score in year 1

• Replaces PQRS

• ECs will select 6 measures– 1 cross-cutting measure and 1 outcome measure

– Select from individual measures or a specialty measure set

• Proposed quality measures available in the NPRM (Measures will be posted to the Federal Register no later than November of each year).

Cost

• 10% of total MIPS score in year 1

• Also known as “resource use”

• Replaces the cost component of the value modifier program

• Based on Medicare claims (i.e. no reporting requirements)

• 40 episode-specific measures to account for different specialties

Clinical Practice Improvement Activities

• 15% of total MIPS score in year 1• ECs rewarded for different activities such as:

– Care coordination, beneficiary engagement, and patient safety

• Big Quality Improvement (QI) component• ECs may select from a list of more than 90

options– Minimum of 1 CPIA activity to not receive a zero score

• Clinicians can receive credit in this category for participation in APMs or PCMH

Advancing Care Information

• 25% of total MIPS score in year 1

• The new Meaningful Use

• EHR reporting, aligns with proposed stage 3 MU

• *For clinicians whom the objectives are not applicable (i.e. hospital-

based), CMS proposes to reweight the other MIPs categories

Meaningful Use Advancing Care Information

• More focused on outcomes, promoting innovation and prioritizing interoperability1. Reward providers for outcomes technology helps

them achieve with patients

2. Allow flexibility to customize health IT

3. Level technology playing field (open APIs and low barriers to entry)

4. Prioritize interoperability – focus on “real-world” applications

Advancing Care Information - Scoring

Base

Score

Performance Score

Bonus

Point

Composite Score

Base Score = 50 pointsPerformance Score = 80 pointsBonus Point = 1 point

Composite Score = earn 100 or more points and receive full 25 points in the ACI category of MIPS Composite Score(*131 total available points)

Base Score

• Accounts for 50 points of the total ACI score.

• Provide numerator/denominator or yes/no for each objective and measure.

• 6 proposed objectives– Proposed rule would no longer require reporting

on Clinical Decision Support and the Computerized Provider Order Entry objectives

– Only requires reporting to public health immunization registry

Objectives

Protect Patient Health Information

Electronic Prescribing

Patient Electronic Access

Coordination of Care Through

Patient Engagement

Health Information Exchange

Public Health and Clinical Data

Registry Reporting

Performance Score

• Accounts for up to 80 points

• Select measures from objectives that emphasize patient care and information access

Patient Electronic Access

Coordination of Care Through

Patient Engagement

Health Information Exchange

Advancing Care Information Objectives & Measures

Objective Measure

Protect Patient Health Information Security Risk Analysis

Electronic Prescribing eRx

Patient Electronic Access Patient Access

Patient Education

Coordination of Care Through Patient Engagement

View, Download, Transmit (VDT)

Secure Messaging

Patient-Generated Health Data

Health Information Exchange Exchange Information with other Clinicians

Exchange Information with Patients

Clinical Information Reconciliation

Public Health Reporting Immunization Registry (*Required)

Syndromic Surveillance, Electronic Case Reporting, Public Health Registries, Clinical Data Registries

When do the ACI objectives start?

• Your reporting period will begin January 1, 2017.

• The objectives you attest to will depend on the version of Certified EHR Technology you are using.

• 2014 vs. 2015 Edition certification criteria

– This will determine whether you attest to modified stage 2 or stage 3 criteria

• 2015 CEHRT required for all clinicians in 2018

What about 2016?

• Continue with full year Meaningful Use reporting period

– Modified Stage 2 objectives

– CMS.gov – 2016 Program Requirements

• MACRA/MIPS requirements don’t begin until January 2017

Comments

• MACRA Notice of Proposed Rule Making (NPRM) was released on April 27, 2016.

– Mandatory 60-day comment period

– Comments must be received no later than 5 p.m. on June 27, 2016.

– http://www.regulations.gov

We Are Here To Help!

Email: ofmqhit@ofmq.comjfelts@ofmq.com

Call: (877) 963-6744Visit: www.OFMQ.com

Questions?

Upcoming WebEx Events

Register at www.ofmq.com/hit-webex

Monthly HIT Educational WebEx |Wed, July 20| 12:15pm“The Future of Technology in Long-Term Care”

Monthly HIT Educational WebEx | Wed, June 15| 12:15pm“Improving Your Practice or Hospital through Healthy Hearts for Your Patients”

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