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Quality Payment ProgramGetting Startedwith theQuality Payment ProgramElissa BalchMay 17, 20171

Quality Payment ProgramWhat is “MACRA”?MACRA stands for the Medicare Access and CHIP Reauthorization Act of2015, bipartisan legislation signed into law on April 16, 2015.What does it do? Repeals the Sustainable Growth Rate (SGR) Formula Changes the way that Medicare pays clinicians andestablishes a new framework to reward clinicians for quality ofservices over quantity Streamlines multiple quality reporting programs into 1 newsystem (MIPS) Provides bonus payments for participation in advancedalternative payment models (APMs)2

Quality Payment ProgramThe Quality Payment ProgramClinicians have two tracks from whichto choose:The Merit-based IncentivePayment System (MIPS)If you decide to participate in traditionalMedicare, you may earn a performance-basedpayment adjustment through MIPS.ORAdvanced Alternative PaymentModels (APMs)If you decide to take part in an Advanced APM, youmay earn a Medicare incentive payment forparticipating in an innovative paymentmodel.3

Quality Payment ProgramQuality Payment Program Strategic GoalsImprove beneficiary outcomesEnhance clinician experienceIncrease adoption ofAdvanced APMsMaximize participationImprove data andinformation sharingEnsure operational excellencein program implementationQuality Payment ProgramQuick Tip:For additional information on the Quality Payment Program, please visit QPP.CMS.GOV4

Quality Payment ProgramMIPS EligibilityWhat Do I Need to Know?5

Quality Payment ProgramEligible Clinicians:Clinicians billing more than 30,000 a year in Medicare Part B allowedcharges AND providing care for more than 100 Medicare patients a year.BILLING 30,000AND 100These clinicians onerClinical s6

Quality Payment ProgramEligibility ExampleDr. “A.” is: An eligible clinician Billed 100,000 inMedicare Part B charges Saw 110 patientsTherefore, Dr. A. would beELIGIBLE for MIPS.Remember: To be eligibleBILLING 100,000 BILLING 30,000 110ELIGIBLEFor MIPSAND 1007

Quality Payment ProgramWho is Exempt from MIPS?Clinicians who are:Newly-enrolledin MedicareBelow the low-volumethreshold Enrolled in Medicarefor the first time duringthe performance period(exempt until followingperformance year) Medicare Part B allowedcharges less than or equalto 30,000 a yearOR See 100 or fewerMedicare Part B patients ayearSignificantlyparticipating inAdvanced APMs Receive 25% of theirMedicare paymentsOR See 20% of their Medicarepatients through anAdvanced APM8

Quality Payment ProgramExempt ExampleDr. “B.” is: An eligible clinician Billed 100,000 inMedicare Part B charges Saw 80 patientsDr. B. would be EXEMPTfrom MIPS due to seeingless than 100 patients.Remember: To be eligibleBILLING 100,000 BILLING 30,000 80EXEMPTFrom MIPSAND 1009

Quality Payment ProgramEligibility for Non-Patient Facing Clinicians Non-patient facing clinicians are eligible to participate in MIPS as longas they exceed the low-volume threshold, are not newly enrolled, andare not a Qualifying APM Participant (QP) or Partial QP that elects not toreport data to MIPS The non-patient facing MIPS-eligible clinician threshold for individualMIPS-eligible clinicians is 100 patient facing encounters in adesignated period A group is non-patient facing if 75% of NPIs billing under the group’sTIN during a performance period are labeled as non-patient facing There are more flexible reporting requirements for non-patient facingclinicians20

Quality Payment ProgramPart I:MIPS BasicsWhat Do I Need to Know?11

Quality Payment ProgramWhat is the Merit-based Incentive Payment System?Performance g CareInformation Comprised of four performance categories Provides clinicians with flexibility to choose the activities and measures that aremost meaningful to their practice12

Quality Payment ProgramWhat is the Merit-based Incentive Payment System?A visualization of how the legacy programs streamline into the MIPSperformance categories:Participating in Is similar to reporting on PQRSQualityVMCostEHRAdvancing CareInformation13

Quality Payment ProgramWhen Does the Merit-based Incentive PaymentSystem Officially Begin?Performance yearsubmitFeedback available2017March 31, 2018FeedbackPerformance YearData Submission Performanceperiod opensJanuary 1, 2017. Closes December31, 2017. Clinicians care forpatients andrecord data duringthe year. Deadline forsubmitting data isMarch 31, 2018. Clinicians areencouraged tosubmit data early.adjustmentJanuary 1, 2019Payment Adjustment CMS providesperformancefeedback afterthe data issubmitted. Clinicians willreceive feedbackbefore the startof the paymentyear. MIPS paymentadjustments areprospectivelyapplied to eachclaim begin January1, 2019.10

Quality Payment ProgramMIPS ParticipationWhat Do I Need to Know?15

Quality Payment ProgramPick Your Pace for Participation for the Transition YearMIPSParticipate in anAdvanced AlternativePayment Model Some practices maychoose to participatein an AdvancedAlternative PaymentModel in 2017Test Submit some data afterJanuary 1, 2017 Neutral paymentadjustmentNote: Clinicians do not need totellCMS which option they intend topursue.Full YearPartial Year Report for 90-dayperiod after January 1,2017 Fully participatestarting January 1,2017 Neutral or positivepayment adjustment Positive paymentadjustmentNot participating in the Quality Payment Program for theTransition Year will result in a negative 4% payment adjustment.16

Quality Payment ProgramMIPS: Choosing to Test for 2017 Submit minimum amount of 2017 data to Medicare Avoid a downward adjustment Gain familiarity with the programMinimum Amount of Data1QualityMeasureOR1ImprovementActivityOR4 or ng on CEHRT edition23

Quality Payment ProgramMIPS: Partial Participation for 2017 Submit 90 days of 2017 data to Medicare May earn a positive payment adjustment“So what?” - If you’re not ready on January 1,you can start anytime between January 1 andOctober 2Need to send performancedata by March 31, 201818

Quality Payment ProgramMIPS: Full Participation for 2017 Submit a full year of 2017 data to Medicare May earn a positive payment adjustment Best way to earn largest payment adjustment is to submit dataon all MIPS performance categoriesKey Takeaway:Positive adjustments are based on the performance data on theperformance information submitted, not the amount of informationor length of time submitted.19

Quality Payment ProgramMIPS ReportingWhat Do I Need to Know?20

Quality Payment ProgramIndividual vs. Group ReportingOPTIONSIndividual1. Individual—underanNational ProviderIdentifier (NPI) numberand TaxpayerIdentification Number(TIN) where they reassignbenefitsGroup2. As a Groupa)2 or more clinicians(NPIs) who havereassigned theirbilling rights to asingle TIN*b) As an APM Entity* If clinicians participate as a group, they are assessedas a group across all 4 MIPS performance categories21

Quality Payment ProgramMIPS Submission MethodsWhat Do I Need to Know?22

Quality Payment ProgramSubmission MethodsIndividual Qualified Clinical DataRegistry(QCDR)Qualified RegistryEHRClaimsImprovementActivities QCDRQualified RegistryEHRAttestationAdvancingCareInformation QCDRQualified RegistryEHRAttestationQualityGroup QCDRQualified RegistryEHRAdministrativeClaimsCMS WebInterfaceCAHPS for MIPSSurveyQCDRQualified RegistryEHRCMS WebInterfaceAttestation QCDRQualified RegistryEHRAttestationCMS WebInterface*Must be reported via a CMS approved survey vendor togetherwith another submission method for all other Quality measures.30

Quality Payment ProgramGroup RegistrationRegistration is required for eligible clinicians participating as a groupthat wish to report via:Web Interface CAHPS for MIPS surveyGroup registration closes on June 30, 2017.24

Quality Payment ProgramMIPS Scoring MethodologyWhat Do I Need to Know?25

Quality Payment ProgramMIPS Scoring for Quality(60% of Final Score in Transition Year)Quick Tip:Easier for a clinician whoparticipates longer tomeet case volumecriterion needed toreceive more than 3points.Select 6 of the approximately 300 available qualitymeasures (minimum of 90 days) Or a specialty set Or CMS Web Interface measuresClinicians receive 3 to 10 points on each qualitymeasure based on performance against benchmarksBonus points areavailable Failure to submit performance datafor a measure 0 points 2 points for submitting anadditional outcomemeasure1 point for submitting anadditional high-priority measure1 point for using CEHRT tosubmit measureselectronicallyend-to-end26

Quality Payment ProgramQuality: Requirements for the Transition Year Test means:oSubmitting 1 Qualitymeasure Partial and Full means:oSubmitting at least 6 qualitymeasures, including 1 Outcome or1 High-Priority measureo90 days for Partial Yearo1 year for Full YearFor a full list of measures, please visit QPP.CMS.GOV27

Quality Measures28

Quality Measure: Opioid Treatment Agreement29

Quality Payment ProgramMIPS Scoring for Cost(0% of Final Score in Transition Year)No submission requirementsClinicians assessedthrough claims dataClinicians earn amaximum of 10 pointsperepisode cost measure30

Quality Payment ProgramMIPS Performance Category: Improvement Activities 15% of Final Score in 2017 Attest to participation in activities that improve clinical practice- Examples: Shared decision making, patient safety, coordinating care, increasing accessClinicians choose from 90 activities under 9 subcategories:1. Expanded Practice Access2. Population Management3. Care Coordination4. BeneficiaryEngagement5. Patient Safety andPractice Assessment6. Participation in an APM7. Achieving Health Equity8. Integrating Behavioraland Mental Health9. Emergency Preparednessand Response31

Quality Payment ProgramMIPS Scoring for Improvement Activities(15% of Final Score in Transition Year)Total points 40Activity WeightsAlternate ActivityWeights* Medium 10 points High 20 points Medium 20 points High 40 points*For clinicians in small,rural, and underservedpractices or with nonpatient facing clinicians orgroupsFull credit forclinicians in apatient-centeredmedical home,Medical HomeModel, or similarspecialty practice32

Quality Payment ProgramImprovement Activity: Requirementsfor the Transition YearPartial and Full means:Test means: Attesting to 1 ImprovementActivityoo Activity can be high or mediumweightIn most cases, to attest you need toindicate that you have done theactivity for 90 days. Attesting to 1 of the following combinations:o 2 high-weighted activitieso1 high-weighted activity and2 medium-weighted activitiesoAt least 4 medium-weighted activitiesClinicians with special considerations:o 1 high-weighted activityo 2 medium-weighted activitiesFor a full list of activities, please visit QPP.CMS.GOV33

Improvement Activities: Keyword Diabetes

Improvement Activities35

Improvement Activity: Consultation of PDMP36

Quality Payment ProgramMIPS Performance Category: Advancing CareInformation (25% of Final Score in Transition Year) Earn up to 155% maximum score, which will be capped at100%Advancing Care Information category score includes:RequiredBase score(50%)Performance score(up to 90%)Bonus score(up to 15%)Keep in mind: You need to fulfill the Base score or you will get a zero in the Advancing Care InformationPerformance Category37

Quality Payment ProgramAdvancing Care Information: Requirements forthe Transition YearTest means: Submitting 4 or 5 base score measureso Depends on use of 2014 or 2015EditionPartial and Full means: Submitting more than thebase score in the TransitionYearReporting all required measures inthebase score to earn any credit in theAdvancing Care Informationperformance categoryFor a full list of measures, please visit QPP.CMS.GOV38

Quality Payment ProgramCalculating the Final Score Under MIPSFinal Score Clinician Qualityperformancecategory score xactual Qualityperformancecategory weight Clinician Costperformancecategory score xactual Costperformancecategory weight ClinicianImprovementActivitiesperformancecategory score xactualImprovementActivitiesperformancecategory weight ClinicianAdvancing CareInformationperformancecategory score xactual AdvancingCare Informationperformancecategory weight10039

Quality Payment ProgramTransition Year 2017Final Score 70 pointsPayment Adjustment 4-69 points3 points0 points Positive adjustmentEligible for exceptional performance bonus—minimum of additional0.5% Positive adjustmentNot eligible for exceptional performance bonus Neutral payment adjustment Negative payment adjustment of -4%0 points does not participate 50

Quality Payment ProgramPart 2:Checklist for Preparing and Participating inMIPS41

Quality Payment ProgramPreparing and Participating in MIPS: A Checklist Determine your eligibility and understand the requirements. Choose whether you want to submit data as an individual or as a part of a group. Choose your submission method and verify its capabilities. Verify your EHR vendor or registry’s capabilities before your chosen reporting period. Prepare to participate by reviewing practice readiness, ability to report, and the Pick YourPace options. Choose your measures. Visit qpp.cms.gov for valuable resources on measure selection andremember to review your current billing codes and Quality Resource Use Report to helpidentify measures that best suit your practice. Verify the information you need to report successfully. Care for your patients and record the data. Submit your data by March 2018.42

Quality Payment Program Determine Your EligibilityHow Do I Do This?1.1.Calculate your annual patient count and billing amount for the2017 transition ye