Disclaimers
This presentation was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services.
This publication is a general summary that explains certain aspects of the Medicare Program, but is not a legal document. The official Medicare Program provisions are contained in the relevant laws, regulations, and rulings. Medicare policy changes frequently, and links to the source documents have been provided within the document for your reference
The Centers for Medicare & Medicaid Services (CMS) employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this presentation.
2
Quality Payment ProgramTopics
• Quality Payment Program Overview
• Merit-based Incentive Payment System (MIPS) Overview
• MIPS Value Pathways (MVP) Overview and Examples
• MVP RFI Questions for Consideration
• Help & Support
3
MIPS Value Pathways RFIHow to Comment on the MVP RFI
• Proposed rule includes proposed changes not reviewed in this presentation so please refer to proposed rule for complete information.
• Feedback during presentation not considered as formal comments; please submit comments in writing using formal process.
• See proposed rule for information on submitting comments by close of 60-day comment period on September 27 (When commenting refer to file code CMS-1715-P).
• Instructions for submitting comments can be found in proposed rule; FAX transmissions will not be accepted.
• You must officially submit your comments in one of following ways:
- electronically through Regulations.gov
- by regular mail
- by express or overnight mail
- by hand or courier
• For additional information, please go to: qpp.cms.gov. 4
Quality Payment Program
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS by law to implement an incentive program, referred to as the Quality Payment Program, that provides two participation tracks:
6
Quality Payment Program
7
Strategic Objectives
Improve beneficiary outcomes
Increase adoption of Advanced APMs
Improve data and information sharing
Reduce burden on clinicians
Maximize participation
Ensure operational excellence in program implementation
Deliver IT systems capabilities that meet the needs of users
Quick Tip: For additional information on the Quality Payment Program, please visit qpp.cms.gov
Merit-based Incentive Payment System (MIPS)
9
Quick Overview
Combined legacy programs into a single, improved program.
Physician Quality Reporting System (PQRS)
Value-Based Payment Modifier (VM)
Medicare EHR Incentive Program (EHR) for Eligible Professionals
MIPS
Merit-based Incentive Payment System (MIPS)Quick Overview
MIPS Performance Categories
• Comprised of four performance categories.
• So what? The points from each performance category are added together to give you a MIPS Final Score.
• The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment.
10
*Revised weights according to the 2020 Proposed Rule
11
Merit-based Incentive Payment System (MIPS)Terms and Timelines
As a refresher…
• TIN - Tax Identification Number
- Used by the Internal Revenue Service to identify an entity, such as a group medical practice, that is subject to federal taxes
• NPI – National Provider Identifier
- 10-digit numeric identifier for individual clinicians
• TIN/NPI
- Identifies the individual clinician and the entity/group practice through which the clinician bills services to CMS
Performance Period Also referred to as… Corresponding Payment Year
2017 2017 “Transition” Year 2019
2018 “Year 2” 2020
2019 “Year 3” 2021
2020 “Year 4” 2022
12
Merit-based Incentive Payment System (MIPS)Timelines
Performance period
2020Performance Year
• Performance period opens January 1, 2020
• Closes December 31, 2020
• Clinicians care for patients and record data during the year
submit
March 31, 2021Data Submission
• Deadline for submitting data is March 31, 2021
• Clinicians are encouraged to submit data early
Feedback available
Feedback
• CMS provides performance feedback after the data is submitted
• Clinicians will receive feedback before the start of the payment year
adjustment
January 1, 2022Payment Adjustment
• MIPS payment adjustments are prospectively applied to each claim beginning January 1, 2022
Current Participation in MIPS Stakeholder Feedback
What we’ve been hearing from clinicians:
• The current structure of MIPS and the reporting requirements are confusing
• There is too much choice and complexity when it comes to selecting and reporting measures and activities
• The measures and activities aren’t always relevant to a clinician’s specialty
• It’s hard for patients to compare performance across clinicians
14
MIPS Value Pathways
Why do we need a new participation framework for MIPS?
15
While there have been incremental changes to the program each year, additional long-term improvements are needed to align with CMS’ goal to develop a meaningful program for every clinician, regardless of practice size or specialty.
MIPS Value PathwaysRequest for Information
• CMS has proposed to create a new participation framework, called the MIPS Value Pathways (MVPs), which would begin with the 2021 performance year.
• This new framework would:
- Unite and connect measures and activities across the Quality, Cost, Promoting Interoperability, and ImprovementActivities performance categories of MIPS
- Incorporate a set of administrative claims-based quality measures that focus on population health/public health priorities
- Streamline MIPS reporting by limiting the number of required specialty or condition specific measures
16
MIPS Value Pathways
17
Future State ofMIPS(In Next 3-5Years)
Current Structure ofMIPS(In 2020)
New MIPS Value PathwaysFramework(In Next 1-2Years)
Building Pathways FrameworkMIPS Value Pathways
Clinicians report on fewer measures and activities baseon specialty and/or outcome within a MIPS ValuePathway
Moving toValue
Fully ImplementedPathwaysContinue to increase CMS provided data and feedback to
reduce reporting burden on clinicians
• Many Choices
• Not Meaningfully Aligned
• Higher Reporting Burden
• Cohesive
• Lower Reporting Burden
• Focused Participation around Pathways that are Meaningful to Clinician’s Practice/Specialty or Public Health Priority
• Simplified
• Increased Voice of thePatient
• Increased CMS Provided Data
• Facilitates Movement to Alternative Payment Models (APMs)
2-4Activities
ImprovementActivities
Quality
6+Measures
PromotingInteroperability
6+Measures
Cost
1 or MoreMeasures
Cost
Quality and IA aligned
Foundation
Promoting Interoperability
Population Health Measures
Foundation
Promoting Interoperability
Population Health Measures
Enhanced Performance Feedback
Patient-Reported Outcomes
Value
Quality ImprovementActivities
Cost
We Need Your Feedback on:
Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues;
CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.
Goal is for clinicians to report less burdensome data as MIPS evolves and for CMS to provide more datathrough
administrative claims and enhanced performance feedback that is meaningful to clinicians andpatients.Clinician/Group Reported Data CMS Provided Data
Pathways:
What should be the structure and focus of the Pathways? What criteria should we use to select measures and activities?
Participation:
What policies are needed for small practices and multi-specialty practices?Should there be a choice of measures and activities withinPathways?
Public Reporting:
How should information be reported to patients?
Should we move toward reporting at the individual clinician level?
MIPS Value Pathways: Surgical Example
18
MIPS moving towards value; focusing participation on specific meaningful measures/activities or public health priorities;facilitating movement to Advanced APMtrack
2-4Activities
ImprovementActivities
Quality
6+
Measures
PromotingInteroperability
6+
Measures
Cost
1 or MoreMeasures
Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues;CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.
Completion of an Accredited Safety or Quality Improvement Program(IA_PSPA_28)
Patient-Centered Surgical Risk Assessment and Communication (Quality ID:358) OR
Implementing the Use of Specialist Reports Back to Referring Clinicianor Group to Close Referral Loop (IA_CC_1)
Revascularization for Lower Extremity Chronic Critical Limb Ischemia (COST_CCLI_1)
Knee Arthroplasty (COST_KA_1)
Surgical Site Infection (SSI) (Quality ID:357)
Use of Patient SafetyTools (IA_PSPA_8) Medicare Spending Per Beneficiary (MSPB_1)Unplanned Reoperation within the 30-Day Postoperative Period (Quality ID: 355)
QUALITY MEASURES
MIPS Value Pathways for Surgeons
COST MEASURES
*Measures and activities selected for illustrative purposes and are subject to change.
IMPROVEMENT ACTIVITIES
Surgeon reports on same foundation of measures with patient-reported outcomes also included
Performance category measures in Surgical Pathway are more meaningful to thepractice
CMS provides even more data (e.g. comparative analytics) using claims data and surgeon’s reporting burden evenfurther reduced
Surgeon chooses from same set ofmeasures as all other clinicians, regardless of specialty or practicearea
Four performance categories feel likefour different programs
Reporting burden higher and population health not addressed
Surgeon reports same “foundation” of PI and population health measures as all other cliniciansbut now has a MIPS Value Pathway with surgical measures and activities aligned with specialty
Surgeon reports on fewer measures overall in apathway that is meaningful to theirpractice
CMS provides more data; reporting burden onsurgeon reduced
Clinician/Group CMS Clinician/Group CMSClinician/Group CMS
ImprovementActivities
CostQuality
Foundation
Promoting Interoperability
Population Health Measures
Foundation
Promoting Interoperability
Population Health MeasuresEnhanced Performance Feedback
Patient-Reported Outcomes
Future State of MIPS(In Next 3-5 Years)
Current Structure of MIPS(In 2020)
New MIPS Value PathwaysFramework(In Next 1-2 Years)
Cost
Quality and IA aligned
MIPS Value Pathways: Diabetes Example
19
MIPS moving towards value; focusing participation on specific meaningful measures/activities or public health priorities;facilitating movement to Advanced APMtrack
2-4Activities
ImprovementActivities
Quality
6+
Measures
PromotingInteroperability
6+
Measures
Cost
1 or MoreMeasures
Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues; CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmission measure.
Electronic Submission of Patient Centered Medical Home Accreditation (IA_PCMH)
Evaluation Controlling High Blood Pressure (Quality ID: 236)
OR
Medicare Spending Per Beneficiary (MSPB_1)Diabetes: Medical Attention for Nephropathy (Quality ID: 119)
Glycemic Management Services (IA_PM_4) Total Per Capita Cost (TPCC_1)Hemoglobin A1c (HbA1c) Poor Care Control (>9%) (Quality ID: 001)
QUALITY MEASURES
MIPS Value Pathways for Diabetes
COST MEASURES
*Measures and activities selected for illustrative purposes and are subject to change.
IMPROVEMENT ACTIVITIES
Chronic Care and Preventative Care Management for Empaneled Patients
(IA_PM_13)
Endocrinologist reports on same foundation of measures with patient-reported outcomes also included
Performance category measures in endocrinologist’s Diabetes Pathway are more meaningful to their practice
CMS provides even more data (e.g. comparative analytics) using claims data and endocrinologist’s reporting burden even further reduced
Endocrinologist chooses from same set of measures as all other clinicians, regardless of specialty or practice area
Four performance categories feel likefour different programs
Reporting burden higher and population health not addressed
Endocrinologist reports same “foundation” of PI and population health measures as all other clinicians but now has a MIPS Value Pathway with measures and activities that focus on diabetes prevention and treatment
Endocrinologist reports on fewer measures overall in a pathway that is meaningful to their practice
CMS provides more data; reporting burden on endocrinologist reduced
Clinician/Group CMS
ImprovementActivities
CostQuality
Foundation
Promoting Interoperability
Population Health Measures
Foundation
Promoting Interoperability
Population Health MeasuresEnhanced Performance Feedback
Patient-Reported Outcomes
Future State of MIPS(In Next 3-5 Years)
Current Structure of MIPS(In 2020)
New MIPS Value PathwaysFramework(In Next 1-2 Years)
Cost
Quality and IA aligned
Clinic ian/Group CMSClinic ian/Group CMS
Feedback Categories
• We are requesting information in the following areas:- MVP Approach, Definition, Development, Specification,
Assignment, and Examples
- Selection of Measures and Activities for MVPs
- MVP Assignment
- Transitioning to MVPs
- Small and Rural Practices Participation in MVPs
- Multispecialty Practices Participation in MVPs
- Incorporating QCDR Measures into MVPs
- Scoring MVP Performance
- Population Health Quality Measure Set
- Clinician Data Feedback
- Patient Reported Measures
- Publicly Reporting MVP Performance Information20
MIPS Value Pathways
22
More information available on the QPP website at: https://qpp.cms.gov/mips/mips-value-pathways
23
Technical AssistanceAvailable Resources
Learn more about technical assistance: https://qpp.cms.gov/about/help-and-support#technical-assistance
Comments due September 27When and Where to Submit Comments
• See proposed rule for information on submitting comments by close of 60-day comment period on September 27 (When commenting refer to file code CMS-1715-P)
• Instructions for submitting comments can be found in proposed rule; FAX transmissions will not be accepted
• You must officially submit your comments in one of following ways:
- electronically through Regulations.gov
- by regular mail
- by express or overnight mail
- by hand or courier
24
25
Q&A Session
• CMS must protect rulemaking process and comply with Administrative Procedure Act
• Participants are invited to share initial comments or questions, but only comments formally submitted through process outlined by Federal Register taken into consideration by CMS
• See proposed rule for information on how to submit a comment
Q&A Session
To ask a question, please dial:
1-866-452-7887
If prompted, use passcode: 649 7764
Press *1 to be added to the question queue.
You may also submit questions via the chat box.
Speakers will answer as many questions as time allows.
26