Industry Webinar - QPP Year 2 (2018)
YOUR HOST MICHELLE BOWES Michelle has more than 20 years of hands on work experience in hospitals, clinics, imaging centers, medical consulting firms and billing companies, both on the clinical and the administrative spectrums. She’s a trusted colleague of the Colorado State Office of Rural Health and helped anchor one of the most successful REC programs in the nation from 2010-2015. Michelle has assisted with several hundred Eligible Provider and nearly 100 Hospital/CAH MU attestations over the years. The deviation from the EHR Incentive Program to Quality Payment Program has forced everyone to shift gears, and naturally Michelle has embraced the challenge of establishing herself as an expert in the new era of Value Based Reimbursement. Michelle joined the Azalea Health team in 2015 as the CMS Regulatory Program Compliance Team Lead Consultant. She works closely with development to support the 2015 ONC Certification and red tape requirements, as well as with clients to provide expertise, insight and support.
AGENDA ● Welcome & Overview ● Where we are today ● A bit more on APMs ● 2017 reweighting & submissions ● 2018 QPP ● Q&A
WHERE WE ARE TODAY
WHERE WE ARE TODAY 2017 QPP Performance Year SUBMISSIONS ARE DUE BY 3/31/2018 ...but it is not too late to start ! MIPS: ● The minimum submission is literally something (aka a “TEST” which is a minimum of a single CQM, for a single patient, on a single day, via a claim) to avoid the negative payment adjustment ● Decide whether you’ll submit as a group (under a single TIN) or by individual Eligible Clinician ○ Understand the ACI transitive effect of group reporting if manually aggregating your own data ○ Maximize your incentive - submit 90+ days of data from each category with a composite score of at least 70 MIPS points = Exceptional Performance ● Document your Practice Improvement Activities (PI) Alternative Payment Model (APM): ● Clarify the APM you’re working with is a “MIPS” APM or “Advanced” APM - there are major differences between the two! ● Clarify what the MIPS APM is submitting on your behalf - all categories or just Quality? Don’t make assumptions!
A BIT MORE ON APMs
A BIT MORE ON APMs... CMS is pushing HARD toward Advanced APM participation. CMS predicts that 100,000 Part B clinicians will participate in Advanced APMs in 2017. They’re estimating 185,000-250,000 qualifying participants (QPs) in Performance Year 2018 - almost double! RCM / Billing ● Earn an annual 5% Part B incentive (paid 2019 - 2024) and are exempt from MIPS. ○ Bonus is only on services (unlike MIPS which is bonused on services and items) billed to Medicare Part B ● In 2026, Advanced APM qualifying participants (QPs) will accrue a higher annual Part B physician fee schedule (PFS) increase of 0.75%, rather than 0.25%. ● QP status is determined by three performance year-to-date snapshots for Part B claims filed in the periods ending on March 31, June 30 and August 31. Sales & Marketing Development ● Participants, in turn, must receive a certain percentage of their Medicare Part B payments or see a certain percentage of patients through an Advanced APM.
2017 REWEIGHTING & SUBMISSIONS
2017 ACI HARDSHIP REWEIGHTING 2017 ACI Reweighting Application - deadline for submission is 3/31/2018 Special Status Clinicians RCM / Billing There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application. ● Hospital-based MIPS-eligible clinicians (75% of hospital POS 21,22 or 23) ● Physician Assistants ● Nurse practitioners ● Clinical nurse specialists ● Certified registered nurse anesthetists ● Non-patient facing clinicians ● Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians (approved in QPP 2018 Final Sales & Marketing Development Rule to start in 2017 Transition period) ● Non-patient facing **Just because you fall into this category, that does NOT mean you cannot still submit your ACI. If you choose to do so, your ACI score will be counted normally at 25%.
2017 MIPS SUBMISSIONS EXACTLY HOW DO YOU SUBMIT TO QPP FOR MIPS? Let me count the ways. 1. Electronically via your EHR’s API to CMS. RCM / Billing 2. Electronically via a Registry or Qualify Clinical Data Registry (QCDR). 3. Via Claims. 4. Manual attestation through QualityNet. EHR MANUAL SUBMISSION Each category may be submitted REGISTRY / QCDR separately and through different 2017 submission methods. However, each MIPS item within a category must be Sales & Marketing submitted through the same method. CLAIMS
2017 MIPS MANUAL SUBMISSIONS MANUAL SUBMISSIONS ARE MOVING FROM THE CMS R&A WEBSITE TO QPP. QPP Requires Enterprise Identity Management (EIDM) Accounts RCM / Billing If your individual eligible clinicians and/or group plans to manually attest for MIPS, you will need an EIDM account to sign into the Quality Payment Program portal. QPP is open to receive attestations now! ● If you have an EIDM Account - You’ll need your EIDM credentials and you must have an appropriate user role associated with your organization to sign into QPP. ● If you do NOT have an EIDM Account - Create an account on the CMS Enterprise Portal. EIDM Account & User Role Guide More EIDM References, Education and Videos 2017 QPP SUBMISSION DEADLINE - MARCH 31, 2018
2018 QPP
2018 QPP - BIGGER AND BETTER 2018 is an opportunity for further involvement and improvement! 2017 QPP 2018 QPP MORE MONEY! Learning the Think strategy. Up to 5% in program. Payment Year Focus on Learning improvement. 2020 appropriate Maximize documentation. participation. Learning how to submit.
2018 QPP - EFFECT ON 2017 EFFECT ON QPP 2017 Exclusions added: Low volume exclusions for the HIE and eRX objectives were added for the 2017 QPP. If your EC or group had less than 100 transitions of care out or less than 100 ePrescriptions ordered, during your reporting period, you may claim an exclusion in 2017. ACI Automatic reweighting: For ECs in an ambulatory surgery center (ASC), the ACI category will automatically be reweighted to 0% in 2017 QPP (FINALIZED TO BEGIN AT THE BEGINNING OF THE TRANSITION YEAR)
2018 QPP - THE CHANGES THE BASICS PENALTIES + INCENTIVES | MIPS max penalty and incentive is 5%. Translation – an EC or group may be penalized or bonused anywhere from -5% to +5% of their Medicare Part B reimbursement in 2020, depending on what level they participate in QPP in 2018. CATEGORIES | 2018 MIPS category weights are Quality: 50%, ACI: 25%, IA: 25%, Cost: 10%. Translation – Each category’s weight contributes to the overall MIPS Score. New for 2018 is Cost. VOLUME | 2018 MIPS low-volume thresholds are ≤ $90,000 Medicare Part B allowed charges or ≤ 200 Medicare Part B beneficiaries. Translation – Check your Medicare Part B volumes and eligibility on the QPP Website beginning in 2018. If your EC NPI reflects “not eligible” in either the individual or group categories, your EC and/or group may be exempt from participation in the 2018 QPP.
2018 QPP - THE CHANGES THE BASICS SIZE | Relief for small practices (1 to 15 clinicians). Translation – If you don’t meet low volume thresholds, you still get special treatment since you’re small! Bonus points added to final scores, lower PI requirements, the ability to join Virtual Groups, hardship exemptions for ACI and credit for quality measures submitted below data completeness standards. POINTS | MIPS Performance threshold increased from 3 to 15. Translation – an EC or group must submit enough data to earn them 15 points in order to avoid a negative payment adjustment. CQMs still have a 3 point floor. COMPLEXITY | Bonuses for complex patients. Translation - Up to 5 bonus points available to recognize clinicians who treat complex patient populations, based on a combination of Hierarchical Condition Categories (HCCs) and the dual eligible population treated.
2018 QPP - THE CHANGES THE BASICS DATA | Data completeness threshold increases to 60%. Translation – For the Quality category, ECs/groups must submit data on at least 60% of applicable Medicare Part B patients seen during the performance period for which that measure applies. TECHNOLOGY | May use either 2014 or 2015 CEHRT, or a combination of both. Translation – EHR and other technology vendors must certify with the ONC that they meet certain standards. Most vendors are currently certified to 2014 CEHRT and are working or have achieved the 2015 certification. In 2018, you may use either CEHRT or combination of both. CMS is offering a 10% scoring bonus for those ECs/groups reporting using only 2015 CEHRT. APMS | Fewer MIPS ECs expected to participate in 2018. APMs are expanding to all-payer models starting in 2019. Translation – CMS is pushing ECs/groups to participate in MIPS APMs and Advanced APMs. IMPROVEMENT SCORING | Measure improvements from 2017 to 2018 in Quality and Cost categories. Translation – For Quality, improvements in the category as a whole will result in up to 10% bonus of the Quality score. For Cost, improvement analysis occurs at the measure level for an earning potential of up to 1% bonus in the Cost category.
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