Final Requirements for the Quality Payment Program (QPP) Update on - PowerPoint PPT Presentation

Final Requirements for the Quality Payment Program (QPP) Update on the Medicare Access and CHIP Reauthorization Act (MACRA)/QPP Final Rule with Comment Period Infectious Diseases Society of America (IDSA) November 14, 2016 CHRISTINE G GROSSMAN, E ESQ. HART RT HEALTH S STRATEGIES, I INC NC.

MACRA FINAL RULE THE MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS), ALTERNATIVE PAYMENT MODEL (APM) INCENTIVE, AND CRITERIA FOR THE PHYSICIAN-FOCUSED PAYMENT MODELS (PFPMS)

Overview of QPP Payment Adjustments AGEN ENDA Alternative Payment Models (APMs) The Merit-based Incentive Payment System (MIPS)

For Infectious Diseases, there are really two main considerations: - Employment model - Inpatient vs Outpatient Inpatient Outpatient Employed MIPS or MIPS or Possibly APMs Possibly APMs Private Practice MIPS MIPS

MEDICARE’S QUALITY PAYMENT PROGRAM (QPP) MIPS ADVANCED APMs • Consolidates existing physician-focused Medicare quality • Clinicians determined to be Qualifying APM Participants (QPs) in improvement programs an Advanced APM are excluded from participation in MIPS AND • Creates a FINAL SCORE to inform physician payment based on qualify for a 5% bonus four performance categories: • Quality (formerly PQRS) • To be an Advanced APM, an APM must meet the following three criteria: • Require participants to use certified EHR technology; • Advancing Care Information (formerly the EHR Incentive Program) • Provide payment for covered professional services based on quality measures comparable to those used in MIPS; and • Resource Use (formerly the Value-based Payment Modifier) • Either (1) be a Medical Home Model explained under CMS Innovation Center authority; or (2) require participating APM Entities to bear more than a nominal amount of financial risk for • Improvement Activities (IAs) (new) monetary losses.

Overview of QPP Payment Adjustments AGEN ENDA Alternative Payment Models (APMs) The Merit-based Incentive Payment System (MIPS)

Alternative Payment Models (APMs) in the QPP ADVANCED APMS MIPS APMS • 7 models identified by CMS, including: • 10 models identified by CMS, including: • Accountable Care Organization (ACO) model: • Accountable Care Organization (ACO) model: • Medicare Shared Savings Program – Track 2 • Medicare Shared Savings Program – Track 1 Medicare Shared Savings Program – Track 3 Medicare Shared Savings Program – Track 2 Medicare Shared Savings Program – Track 3 • Comprehensive Primary Care Plus (CPC +) Model • Comprehensive Primary Care Plus (CPC +) Model • Next Generation ACO • Next Generation ACO What about Bundled Payment Models, such as the Comprehensive Care for Joint Replacement (CJR) Model?

Overview of QPP Payment Adjustments AGEN ENDA Alternative Payment Models (APMs) The Merit-based Incentive Payment System (MIPS)

The he M Mer erit-ba based ed I Incen entive P e Paymen ent S System em ( (MIPS) ( (2019 P 019 Paymen ent Y Year) Quality (at least 60%) + Resource Use (0%) + Improvement Activities (15%) + Advancing Care Information (25%) = MIPS FINAL SCORE

MIPS Mandates Payment Shift Towards Quality Four Categories Determine MIPS Score : Quality, Cost, Improvement Activities (IA), Advancing Care Information (ACI) Relative Weight of Each Component of the MIPS score (2019 and Beyond) Category 2019 2020 2021+ Quality 60% 50% 30% Cost 0% 10% 30% IA 15% 15% 15% ACI 25% 25%* 25%* * Weight could decrease depending on how many clinicians are meaningful users.

MIPS PARTICIPATION FOR THE 2019 PAYMENT YEAR IMPROVEMENT ACTIVITIES COST (0 POINTS) ADVANCING CARE QUALITY (60-70 PTS.) (40 PTS.) INFORMATION (100+ PTS.) • Calculated based on Medicare • Report on six quality claims • More than 90 weighted options measures or a “specialty • Base Score : Provide in nine categories, including • The cost category will not be numerator/denominator and measure set” participation in APMs factored into the final score “yes/no” for 5 measures • One outcome/high priority • Activities range from 10-20 pts. for 2017. • Performance Score: Report measure • Activities must be performed for • However, CMS still intends to performance on up to 9 measures a continuous 90 days • Threshold reduced to 50% calculate performance on cost to earn up to 10% for each • 40 points to achieve a maximum • For groups of 16 or more measure measures for informational score, but some are given special eligible clinicians, CMS will purposes. • Bonus Points: Bonus available for consideration (small practices, apply the All-Cause • Finalized inclusion of 10 reporting one public health registry rural and geographic HPSA practices and non-patient facing Readmission Measure (beyond the immunization episode-based measures MIPS eligible clinicians) category) + completing IAs using previously in sQRURs. CEHRT

MIPS EXCLUSIONS FINAL EXCLUSIONS: • New Medicare-Enrolled Eligible Clinician • Qualifying APM Participant • Low-Volume Threshold • CMS finalized for 2017, the low-volume threshold at less than or equal to $30,000 in Medicare Part B allowed charges OR less than or equal to 100 Medicare patients , representing 32.5% of pre-exclusion Medicare clinicians but only 5% of Medicare Part B spending

Participating in an Advanced APM • CMS classified 7 models as Advanced APMs • CMS will “broaden opportunities” for clinicians to participate in Advanced APMs PICK CK YOUR P R PACE CE Meeting the Full Reporting Requirements • CMS finalized reduced requirements for full participation in MIPS • Cost Category = 0 The final rule with comment period follows a September 8, 2016 blog post, where Avoid the Penalty Acting Administrator Andy • To avoid the penalty in 2019, eligible clinicians can choose to report one measure in the quality performance category; one Slavitt announced the activity in the improvement activities performance category; or agency’s plans to provide report the required measures of the advancing care information flexibility in 2017 by offering performance category clinicians four options to Partially Participate participate in the QPP to Clinicians may be eligible for a small positive adjustment by avoid a penalty in 2019. submitting MIPS data “more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category” to avoid a penalty in 2019.

ADVANCING CARE INFORMATION (ACI) PERFORMANCE CATEGORY HOW DO ELIGIBLE CLINICIANS WHO ARE TYPICALLY HOSPITAL-BASED PARTICIPATE IN THE ADVANCING CARE INFORMATION PERFORMANCE CATEGORY?  Definition of a Hospital-based Eligible Clinician : 75 percent of payments for covered professional services associated with claims with Place of Service (POS) Codes 21 (inpatient hospital) or 23 (emergency department)  Significant Hardship  Participate in the ACI category, even if you haven’t before

ADVANCING CARE INFORMATION PERFORMANCE CATEGORY: HARDS DSHI HIPS Clinicians Not Previously Eligible to Participate in the EHR Incentive Program: NPs, PAs, CNSs, CRNAs MIPS Eligible Clinicians Facing a Significant Hardship: Including lacking control over availability of CEHRT and lack of face-to-face patient interaction Hospital-based MIPS Eligible Clinicians

IMPROVEMENT ACTIVITIES CATEGORY Patient Safety and Expanded Practice Population Beneficiary Care Coordination Practice Access Management Engagement Assessment Emergency Integration of Achieving Health Participation in an Preparedness and Primary Care and Equity APM Response Behavioral Health

Possible CPIAs for ID Physicians Population Management: Manage medications to maximize efficiency, effectiveness and safety that could include one or more of the following: Reconcile and coordinate medications and provide medication management across transitions of care settings and eligible clinicians or groups; Integrate a pharmacist into the care team; and/or conduct periodic, structured medication reviews. Medium. For example, prescribing Outpatient Parenteral Antibiotic Therapy (OPAT). Patient Safety and Practice Assessment: Implementation of an antibiotic stewardship program that measures the appropriate use of antibiotics for several different conditions (URI Rx in children, diagnosis of pharyngitis, Bronchitis Rx in adults) according to clinical guidelines for diagnostics and therapeutics. Medium. Emergency Response and Preparedness: Participation in Disaster Medical Assistance Teams, or Community Emergency Responder Teams. Activities that simply involve registration are not sufficient. MIPS eligible clinicians and MIPS eligible clinician groups must be registered for a minimum of 6 months as a volunteer for disaster or emergency response. Medium. For example, preparation, implementation, and when necessary execution of a bio-preparedness plan.