Quality Payment Program Year 4: Final Rule Overview The information contained in this presentation is for general information purposes only. The information is provided by UK HealthCare’s Kentucky Regional Extension Center and while we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to content.
Kentucky Regional Extension Center Services UK’s Kentucky REC is a trusted advisor and partner to healthcare organizations, supplying expert guidance to maximize quality, outcomes and financial performance. Kentucky REC Description Physician Services 1. Promoting Interoperability (MU) & Mock Audit 2. HIPAA SRA, Project Management & Vulnerability Scanning To date, the Kentucky REC’s activities include: 3. Patient Centered Medical Home (PCMH) Consulting • Assisting more than 5,000 individual providers 4. Patient Centered Specialty Practice (PCSP) Consulting across Kentucky, including primary care providers and specialists 5. Value Based Payment & MACRA Support • Helping more than 95% of the Federally Qualified 6. Quality Improvement Support Health Centers (FQHCs) and Rural Health Clinics (RHCs) within Kentucky 7. Telehealth Services • Working with more than 1/2 of all Kentucky hospitals Hospital Services • Supporting practices and health systems across the Commonwealth with practice transformation and 1. Promoting Interoperability (Meaningful Use) preparation for value based payment 2. HIPAA Security Analysis & Project Management 3. Hospital Quality Improvement Support
2020 QPP Final Rule On November 1 st , 2019 CMS released the QPP Final Rule •These changes are set to go into effect starting on January 1 st , 2020* *Some changes are retrospective
Objectives Year 4 Quality Payment Program Overview Merit-Based Incentive Payment System (MIPS) Track Updates MIPS Value Pathways (MVPs) Alternative Payment Model (APM) Track Updates Questions
QPP Y4: Final Rule Name of Legislation or Medicare Program; CY 2020 Revisions to Payment Policies Under the Regulation: Physician Fee Schedule and Other Changes to Part B Payment Policies… Final Rule Full Text: Links for More Information: https://www.federalregister.gov/documents/2019/11/15/2019-24086/medicare- program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule- and-other Will impact Medicare Part B payments to eligible clinicians beginning in 2022. Those Impacted: Effective: Begins January 2019 with affected payments based on those measures beginning in 2021.
2020 Quality Payment Program (QPP) Overview
QPP Y4: Glossary of Terms MACRA (Medicare Access & CHIP Reauthorization Act) • Legislation that replaced Sustainable Growth Rate, with a goal for CMS to pay for quality and value, rather than volume (fee for service). QPP (Quality Payment Program) • Created by the MACRA legislation which pays for quality and value rather than volume. Providers will choose between MIPS and APM. MIPS (Merit-Based Incentive Payment System) • Medicare pay-for-performance system created by MACRA that consolidates several existing Medicare pay-for- performance programs. APM (Alternative Payment Model) • CMS Model that pays providers for services based on quality, outcomes, and cost-containment; 5% annual bonus payment to Qualified Physicians who are participating in APMs, and exempts them from participating in MIPS. MVPs (MIPS Value Pathways) • A conceptual participation framework that would apply to future proposals beginning with the 2021 performance year. The goal is to move away from siloed activities and measures and move towards an aligned set of measure options more relevant to a clinician’s scope of practice that is meaningful to patient care.
QPP Y4: Program Tracks By law, MACRA requires CMS to implement an incentive program, referred to as the Quality Payment Program, which provides two participation tracks for clinicians: If you are a MIPS EC, you will be If in an Advanced APM, you may subject to a performance-based earn an incentive payment for payment adjustment through MIPS participating in one of these models
QPP Y4: QPP Clinician Eligibility Eligible Clinician Types: Physician, PA, NP, CNS, CRNA, PT, OT, Qualified Speech-Language Pathologist, Qualified Audiologist, Clinical Psychologist, Registered Dietitian or Nutrition Professional QPP Track Eligibility Requirements Advanced Alternative Payment Merit-Based Incentive Program Model (MIPS) (APMs) 200 Advanced 50% 35% $90K Medicare 200 PFS APM Payment Medicare Part B Patients Participant or Patients
QPP Y4: Virtual Groups Virtual Groups Reminder: Data aggregation No Changes required for Virtual Groups across all TINs
2020 Merit-Based Incentive Payment System
QPP Y4: MIPS Thresholds 45 Points 85+ = Minimum Between 46-84 0 Points = Exceptional Threshold = Points = Performance Full 9% Penalty No Penalty, No Penalty Split $500M Pool No Reward Year 5 Minimum Threshold = 60 Points
QPP Y4: MIPS Overview Quality Improvement Promoting Cost Activities Interoperability Adjustment Program Payment Factor Year Year + / - 2020 2022 45% 15% 25% 15% 9% (Y4) Applied Reporting 365- 90-Day 90-Day 365- During Payment Timeframes Days Minimum Minimum Days Year Must Submit by March 31 st , 2021
QPP Y4: Data Submission Types Submission Type Submitter Type Collection Type Performance The mechanism by which a The MIPS EC, group, or third Set of quality measures with Category submitter type submits data party intermediary acting on comparable specifications and behalf of a MIPS EC or group data completeness criteria Direct Individual eCQMs Log-in & Upload Group MIPS CQMs Quality 3 rd Party Intermediary CMS Web Interface QCDR Measures Medicare Part B Claims (Small) CMS Web Interface Measures CMS Approved Survey Vendor Direct Individual Promoting Measure Log-in & Upload Group Interoperability Medicare Part B Claims 3 rd Party Intermediary Log-in & Attest (small practices) Direct Individual Improvement Administrative Claims Log-in & Upload Group Measures Activities 3 rd Party Intermediary Log-in & Attest No data submission required Individual Cost Group
QPP Y4: Reporting Options Virtual Individual Group Group Combination of > 2 clinicians > 2 TINs Under an NPI (NPIs) who assigned to > 1 number & TIN have individual MIPS As an APM where they reassigned ECs, or to > 1 Entity reassign their billing groups benefits rights to a consisting of < single TIN 10 ECs with > 1 MIPS EC
QPP Y4: Reporting Categories: Basics PI: Quality: Cost: IA: 100 points raw score 6 Measures Required Score is based on 40 points raw score except for: Medicare claims, required required including: • Combination of CMS Web Interface • 4 Objectives, 5 medium & highly report 10 quality Measure 1: Medicare Measures weighted activities measures Spending per Scoring: Beneficiary (MSPB) • 50% ECs must At least 1 Outcome • Performance Measure 2: Total per participate in measure Score capita costs (TPCC) same activity • Bonus for all attributed 7 th Measure based on • 50% of the beneficiaries claims for large groups locations under 2015 CEHRT the TIN are 18 Episode-Based Required Certified Measures PCMH/PCSP Year 4: Minimum Threshold = 45 Points; 9% Risk
QPP Y4: Changes to Quality Measures Requirements • Adding: • Increase of Data Completeness Requirement to 70% • 3 New Measures Final Score: • Scoring: • 7 New Specialty Measure Sets • 45% for 2020 • Flat percentage benchmarks • Add 1 New Measure to the Controlling High Blood CMS Web Interface Set • TBD for 2021 Pressure & A1C Poor Control • Added Claims-Based Measure • 30% for 2022 & Beyond for PY21 • Removing: • 42 Measures • Altering: Submission: • 83 Significantly for 2020+ • No Significant Changes to • 1 Retroactive Change for the Reporting 2019+ Requirements or Submission Mechanisms
QPP Y4: Changes to Improvement Activities (IA) Measures Requirements Final Score: • Removing: • No Proposed Changes to • 15% of Final Score Scoring • 15 Activities • 40 Category Points Needed • Annual registration in PDMP Across 2-4 Activities • Adding: • 50% ECs perform same activity • 2 New Activities • > 90 consecutive day reporting • Modifying: timeframe • 7 Existing Activities Submission: • No Significant Changes to the Reporting Requirements or Submission Mechanisms
QPP Y4: Changes to Promoting Interoperability (PI) Measures Requirements Final Score: • 25% of Final Score • Maintained 4 Objectives • Use of 2015 CEHRT • Maintained EC type • Removed Verify Opioid • > 90 consecutive day reporting reweights Treatment Agreement timeframe • Modified PDMP to Y/N* • Scoring: • e-Rx measure will be worth 10 • Maintained Performance- points based measurement Submission: • Clarified HIE exclusion reweight* • Maintained 100 raw category points for full credit • Hospital-Based as 75% or more • No Significant Changes to of ECs under TIN the Reporting Requirements or Submission Mechanisms
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