Preparing for MACRA & CPC+ · 0 or 50 points Performance Score Can report on up to 7-9 additional measures to secure points for “performance” component of score. Up to 90 points

MIPS 101

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AMG MACRA Readiness Webinar Series

February 8, 2017

The information contained within this presentation is provided as

general guidance, and is not intended to be an all-encompassing

set of guidelines. It is not intended to be used as a substitute for

professional or legal advice and may not address practice-

specific circumstances. Please refer directly to CMS publications

for detailed MACRA guidance when necessary.

INTRODUCTION

Agenda

Topic Timing

Goals for Today 5 min

Overview of MIPS Reporting for Performance Year 2017 10 min

MIPS Performance Categories and Ascension FAQs Quality Cost Advancing Care Information Improvement

40 min

Wrap-up 5 min

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Goals for Today

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Goals for Today

Today we will:

Review the requirements of the Merit Based Incentive Program (MIPS)

Address some AMG frequently asked questions

Please feel free to type in questions. If we are able, we’ll work in answers;

otherwise, we’ll address in written FAQs

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The Quality Payment Program

The Quality Payment Program (QPP) aims to:

• Tie Medicare Part B payments to value for over 600,000 clinicians nationwide

• Improve care across the delivery system

Clinicians will participate in the QPP through one of two tracks:

Today’s Discussion Webinar 2: February 28

Source: CMS, “QPP: The Merit-based Incentive Program,” November 29, 2016

MIPS Reporting for Performance Year 2017

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MIPS Reporting Timeline for PY 2017


Performance:

• The first performance period

opens January 1, 2017 and

closes December 31, 2017.

• During 2017, you will record

quality data and how you

used technology to support

your practice.

Send in Performance Data:

• To potentially earn a

positive payment

adjustment under MIPS,

you must submit data

about the care you

provided and how your

practice used technology

in 2017 The submission

deadline is March 31,

2018.

Feedback:

• Medicare gives

you feedback

about your

performance after

you send your

data.

Payment:

• You may earn a

positive MIPS

payment adjustment

to your FFS

Medicare Part B

rates beginning

January 1, 2019, if

you submit 2017 data

by March 31, 2018.

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MIPS Applicability

Source: CMS, “QPP Overview Fact Sheet,” October 14, 2016

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MIPS Decisions: Individual vs. Group

Option 1: Report as an Individual

• Assessed as an individual across

all 4 MIPS performance categories

Option 2: Report as a Group

(= TIN)

• Must have 2 or more

clinicians (NPIs) who have

reassigned their billing

rights to a single TIN

• Assessed as a group across

all 4 MIPS performance

categories

AMG Preference


• When will CMS let MIPS-exempt clinicians know they are exempt for 2017?

• What if we report as a TIN, but one or more individual clinicians within the TIN are exempt from MIPS?

• What if we report as a group and there are changes to the TIN partway through the year, or after the reporting period?

• If a practice is an AMG joint venture or PSA, who is responsible for MIPS reporting?

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MIPS Applicability: FAQs

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MIPS Decisions: Reporting Tracks for PY 2017


• Submit some

data after

January 1, 2017

• Neutral or small

payment

adjustment

• Report for a 90-

day period after

January 1, 2017

• “Small” positive

payment

adjustment

• Fully participate

starting January

1, 2017

• “Modest” positive

payment

adjustment

AMG anticipates all TINs

will report at least 90 days

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MIPS Decisions: Data Submission Approach

You can choose to report

through an approved third-

party intermediary:

Intermediary Approval

Needed

EHR Vendor ONC

QCDR CMS

Qualified Registry CMS

CAHPS Vendor CMS

There are a number of ways to get your data to CMS. Your approach has implications on

which quality measures you may select. Key considerations include:


• Burden

• Cost

• Past Experience

• Ability to report for at least 90 days / full year

• Will our MIPS score actually be higher if we report

quality measures for a full year rather than 90 days?

• Do we have to use the same reporting modality for

each MIPS category?

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Reporting: FAQs

MIPS Performance Categories

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MIPS Performance Categories

+ + + = FINAL SCORE Quality Advancing

Care Information

Improvement Activities (IA)

Cost (2018+)

Each Clinician’s or TIN’s score from each category is aggregated into a

single MIPS Final Score out of 100:


60% 0% 15% 25%

PY 2017 Category Weights

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Quality Performance Category: The Basics


Reporting is at the TIN OR individual clinician level (no other combinations allowed). If

the TIN chooses to report the quality category as a TIN, it must report all the other

categories as a TIN also.

CMS provides a wide range of quality measure options. Each TIN chooses 6 or

more of the ~270 individual measures OR a specialty measure set*:

• 1 measure must be an “outcome” or a “high-priority” measure

• The measures you submit must cover at least 50% of the TIN’s patients that meet

denominator criteria

• You may report on more than the minimum number of measures

CMS rates the TIN on its performance based on deciles. If the TIN reported more than

the required number of measures, CMS counts the best scoring measures.

Resulting quality category score is 60% of the TIN’s MIPS Final Score, which

determines the payment adjustment

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* If the TIN uses the CMS Web Interface to report,

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Quality Performance Category: Specialty Measures


• Allergy/Immunology

• Anesthesiology

• Cardiology

• Dermatology

• Diagnostic Radiology

• Electrophysiology Cardiac

Specialist

• Emergency Medicine

• Gastroenterology

• General Oncology

• General Practice/Family

Medicine

• General Surgery

• Hospitalists

• Internal Medicine

• Interventional Radiology

• Mental/Behavioral Health

• Neurology

• Obstetrics/Gynecology

• Ophthalmology

• Orthopedic Surgery

• Otolaryngology

• Pathology

• Pediatrics

• Physical Medicine

• Plastic Surgery

• Preventive Medicine

• Radiation Oncology

• Rheumatology

• Thoracic Surgery

• Urology

• Vascular Surgery

TINs can fulfil requirements by utilizing one of the specialty measure sets:

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Quality Performance Category: Near-Term Steps

Decide your TIN’s preferred reporting modality

Review available measures on the CMS website: www.QPP.CMS.gov

Identify measures available based on the reporting modality selected

Determine if you will use any specialty-specific measure sets

Review your current QRUR and sQRURs to identify areas for

performance improvement

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http://www.qpp.cms.gov/

• What are the key differences between MIPS Quality

Category and PQRS?

• Do we have to choose measures that apply to all of

our clinicians?

• We have 2 EHRs in use by the TIN: one for the clinic

and one for the hospital. How will we report?

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Quality Category: FAQs

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Cost Performance Category

No reporting required; CMS will assess cost performance using Medicare

claims data

Cost Category has zero weight in PY 2017 MIPS Final Score

Feedback will still be provided for PY 2017, which can help you prepare

for when costs are rolled in to the Final Score in subsequent performance

years

Measures will mirror the QRUR, which can give you a sense of your

performance on cost

Once in effect (PY 2018+), costs measures will build on the Value

Modifier program:

1. Medicare Spending per Beneficiary (MSPB)

2. Total Per-Capita Cost for All Attributed Beneficiaries for 10

Episodes


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Advancing Care Information: The Basics


Score Component Score

Base Score Must report on required objectives and measures

0 or 50 points

Performance Score

Can report on up to 7-9 additional measures to secure points for “performance” component of score.

Up to 90 points

Bonus Points

Reporting one or more additional public health and clinical data registries beyond Immunization Registry Reporting measure

5 points

Reporting improvement activities using CEHRT

10 points

Total Score (%)=

Sum of all points

(capped at 100)

Total possible points (100)

Failure to report on any single base score measure will result in a zero base score and zero score for overall composite score

Measures worth 10 points each are available for reporting

The bonus measures require attestation (Y/N)

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Advancing Care Information: Reporting Options


For PY 2017, there are two measure sets available, based on your EHR edition:

2015 CEHRT 2014 CEHRT

Advancing Care Information and

Objectives and Measures

Combination of the

two measure sets

2017 Advancing Care Information

Transition Objectives and Measures

Base Measures

Security Risk Analysis

e-Prescribing

Provide Patient Access

Send a Summary of Care

Request / Accept a Summary of Care

Performance Measures

Provide Patient Access Send a Summary of Care

Patient-Specific Education Request/Accept Summary of

Care

View, Download & Transmit Clinical Information Reconciliation

Secure Messaging Immunization Registry Reporting

Patient-Generated Health Data

Base Measures

Security Risk Analysis

e-Prescribing

Provide Patient Access

Health Information Exchange

Performance Measures

Provide Patient Access Health Information Exchange

Patient-Specific Education Medication Reconciliation

View, Download & Transmit Immunization Registry Reporting

Most AMG TINs

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Advancing Care Information: Tracks


AMG Expectation

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Advancing Care Information: Flexibility


ACI Reporting is optional for:

Hospital-based MIPS clinicians

Clinicians with lack of face-to-face patient interaction

NP, PA, CRNAs and CNS

If a clinician faces a significant hardship and is unable to report ACI measures,

they can apply to have their ACI performance category weighted to zero for

PY 2017

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Advancing Care Information: Near-Term Steps

Identify your CEHRT level by TIN

Ensure all TINs are ready to report on each base score measure

Assess readiness to report on performance measures associated

with your CEHRT

Plan to use 2015 edition CEHRT by performance year 2018

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• What if our TIN includes some clinicians who are

exempt from ACI because they are hospital-based, but

others who are not exempt?

• Does the ACI category affect Medicaid Meaningful

Use?

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Advancing Care Information: FAQs

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Improvement Activities: The Basics


Improvement Activities measures assess participation in activities that improve clinical

practice

Each TIN will select a subset of 90+ activities to report on, which fall under 9 categories,

and include some “high weighted” activities that offer higher scores:

• Engagement of new Medicaid patients and follow-up*

• Leveraging a QCDR for use of standard questionnaires

• Leveraging a QCDR to promote use of patient-reported outcome

tools

• Leveraging a QCDR to standardize processes for screening

• Depression screening

• Diabetes screening

• EHR enhancements for BH

data capture

• Co-location PCP and MH

services*

• Implementation of integrated

PCBH model*

• MDD prevention and treatment

interventions

• Tobacco use

• Unhealthy alcohol use

* High weighted activities

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Improvement Activities: Tracks


AMG Expectation

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Improvement Activities: Flexibility


Groups with 15 or fewer participants, non-patient facing clinicians, or those

in a rural or health professional shortage area have a preferential minimum

reporting requirement:

May attest that you have completed up to 2 activities for a minimum of 90

days

Participants in certified patient-centered medical homes, comparable

specialty practices, or an APM designated as a Medical Home Model will

automatically earn full IA credit

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Improvement Activities: Near-Term Steps

Review available measures on the CMS website: www.QPP.CMS.gov

Identify those measures that you already engage in, with a focus on

“high weighted” activities

Assess PCMH participation, which has a broad definition for QPP

Expand implementation of improvement activities as reasonable

during PY 2017

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2

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http://www.qpp.cms.gov/

• Does the whole TIN have to be doing the improvement

activity for the TIN to receive credit?

• How will we know if we meet the criteria for the

preferential scoring under the Improvement

Category? Will CMS tell us?

• Which PCMH certification programs are recognized by

CMS to receive full credit under the Improvement

Activity category? Do all practices in the TIN have to

be PCMHs?

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Improvement: FAQs

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MIPS Scoring Methodology

+ + + = FINAL SCORE (OUT OF 100) Quality Advancing

Care Information

Improvement Activities (IA)

Cost (2018+)

Note: Scoring methodology within each category is quite complex. See resources

available at https://qpp.cms.gov/resources/education for more information


60% 0% 15% 25%

PY 2017 Category Weights

https://qpp.cms.gov/resources/education



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MIPS Payment Adjustment

The majority of TINs are likely to

fall into this category and receive a

modest payment adjustment (under

4%)

Total exceptional performance bonus budget set at $500 million nationally

Source: CMS, “Quality Payment Program Overview, Long Version” October 26, 2016

Wrap-up

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Next Steps

Confirm that you will pursue group reporting

Identify your data submission approach and review applicable

measures

Ensure you can meet the minimum expected reporting and

performance requirements across each performance category

Review your September 2016 QRURs against the benchmarks for

2017 Quality Measures:

Identify strong and weak quality areas

Consider taking remedial actions for weak quality areas within 2017

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Complete AMG MACRA Readiness Assessment by March 1, 2017

MACRA Webinar Series

Topic Timing Purpose

TODAY: MIPS 101: Review of all basic requirements

February 8th 1:00 -2:00 PM ET

Review and clarify the requirements for 2017 MIPS

NEXT: All Things APM: Deep dive into how MSSP and CPC+ participants will be assessed under MACRA

February 28th 1:00 -2:00 PM ET

Review how CMS assesses CPC+ practices, MSSP ACOs, and combinations

for MACRA 2017 (presentation will be geared to Ministries participating in

these models)

Using Data for Internal Quality Improvement

TBD TBD

TBD – Seeking input for final webinar topic

TBD TBD

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Questions?

Please send your questions to Angela Eckard:

[email protected]

APPENDICES

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CMS Educational Resources and Files

Measures Available to Download

2017 MIPS Quality Measures

2017 ACI Measures for 2014 CEHRT

2017 ACI Measures for 2015 CERHT

2017 CPIA Activities

The CMS website has been updated to include an Excel file of the measures available at https://qpp.cms.gov/resources/education





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Steps to Access QRURs

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MIPS and Past Medicare Reporting Programs

Source: CMS, “Quality Payment Program Overview, Long Version” October 26, 2016

QPP combines legacy programs into a single, improved reporting program

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MIPS Applicability:

Source: Manatt analysis of HHS Regulatory Impact Analysis (RIA) within MACRA Final Rule

Merit-Based Incentive Payment System (MIPS)

592 - 642,000 clinicians

$699m total upward MIPS adjustment

$199m total downward MIPS adjustments

Clinicians billing Medicare Part B program

1-1.4m clinicians

• Nearly 1/3 of clinicians excluded for 2017

• However, charges made by this group account

for only 5% of all Medicare spend

• The AMG MACRA Readiness Assessment will

screen for exceptions, which include insufficient

Medicare volume / charges Note: Includes

special reporting

requirements for

particular groups,

likely not applicable

to AMG, such as

groups that primarily

consist of non-patient

facing clinicians

“Advanced Alternative Payment

Models” (A-APMs)

70 - 120,000 clinicians

$333m - $571m incentive payments

Other MIPS-excluded clinicians:

300-700,000 clinicians

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AMG Market MIPS Decisions

Note: The following content assumes that no exclusions or special categories apply,

at least 90 day reporting, and that clinicians are reporting through TIN groups.

Each Ascension TIN that does not report through an APM will need to:

Report as an individual or group AMG assumes most markets will

report as TIN-level groups

Determine response “track,” or how

much data you will be reporting

AMG assumes all markets will

report for at least 90 days

Identify their preferred data submission

approach

AMG assumes this will be

ministry-specific

Understand if any clinicians / TINs

are exempt from MIPS or fall into special

categories (ie, non-patient facing)

AMG will assess for exclusions

through a MACRA Readiness

Assessment

Documents

Preparing for MACRA & CPC+ · 0 or 50 points Performance Score Can report on up to 7-9 additional measures to secure points for “performance” component of score. Up to 90 points