The Quality Payment Program: What You Need to Know Now Jenn Gordon, - PowerPoint PPT Presentation

The Quality Payment Program: What You Need to Know Now Jenn Gordon, MSW Project Lead, QIN-QIO Miriam Sheehey, RN Director of Clinical Operations OneCare VT This material was prepared by the New England QIN-QIO, the Medicare Quality Innovation Network-Quality Improvement Organization for New England, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. CMSMA_D1_201611_0804

Overview � What is MACRA? � Merit-based Incentive Payment Systems and Alternative Payment Models � Eligibility and exclusion criteria � Reporting options � Performance categories � Alignment with NCQA-PCMH � Scoring methodology � How to prepare for 2017 � Resources, Tools and Support 1/17/2017 2

Disclaimer This material was prepared by the New England Quality Innovation Network-Quality Improvement Organization (QIN- QIO), the Medicare Quality Improvement Organization for New England, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 1/17/2017 3

* * Sustainable Growth Rate 1/17/2017 4

Sound Familiar? The foundation of the Quality Payment Program is high-quality, patient-centered care followed by useful feedback, in a continuous cycle of improvement. 1/17/2017 5

Merit-based Incentive Payment System (MIPS) MIPS Performance Existing Program Categories Quality PQRS Advancing Care Meaningful Use Information (ACI) Cost (Resource Use) Value-Based Payment Modifier Improvement Activities (IAs) 1/17/2017 6

Timeline Event Begin Date End Date PQRS & MU 2016 Data Submission 1/2/17 3/31/17 MIPS 2017 Performance Year 1/1/17 12/31/17 PQRS & MU 2017 Payment Year from 2015 Performance 1/1/17 12/31/17 Year MIPS 2017 Data Submission 1/2/18 3/31/18 MIPS 2018 Performance Period 1/1/18 12/31/18 PQRS & MU 2018 Payment Period from 2016 Performance 1/1/18 12/31/18 Year MIPS 2018 Data Submission 1/2/19 3/31/19 MIPS 2019 Performance Period 1/1/19 12/31/19 MIPS 2019 Payment Year from 2017 Performance 1/1/19 12/31/19 Year 1/17/2017 7

Two Payment Model Tracks MIPS APMs All Non - MIPS APMs: MSSP Track 1 One Care VT and Practices and Advanced APMs: None MSSP Tracks 2 and 3, Next Gen, CPC+, in Comprehensive ESRD VT Model, Oncology Care Model 1/17/2017 8

Eligibility and Exclusion Criteria for 2017 � Who is eligible for MIPS? Certified Physician Nurse Clinical Nurse Registered Physician Assistant Practitioner Specialist Nurse Anesthetist � What is the low-volume exclusion? � Submit < $30,000 in Medicare Part B claims � Care for fewer than 100 Medicare patients � In first year of submitting Medicare claims � Participate in a qualified advanced APM 1/17/2017 9

Non-Patient Facing Clinicians � ECs with ≤ 100 Patient Facing Encounters � Groups where > 75% of individual clinicians have ≤ 100 Patient Facing Encounters � 25% of MIPS ECs are considered NPF Nuclear Pathologist Diagnostic Medicine Anesthesiologist Radiologist 1/17/2017 10

MIPS – Pick Your Pace Reporting Don’t Submit Submit a Submit a Participate Something Partial Year Full Year Submit one Report on 90 quality Earn a continuous Receive a measure or IA moderate days and earn 4% negative and avoid a payment a neutral or payment downward adjustment small adjustment payment incentive adjustment 1/17/2017 11

MIPS Program in 2017 MIPS MIPS APM 15% 20% Quality Quality ACI ACI 50% 25% 60% IA IA 30% 1/17/2017 12

Data Submission Mechanisms Performance Individual Reporting Group Reporting Category Quality Claims, QCDR, Qualified QCDR, Qualified Registry, EHR, Registry, EHR, Administrative CMS Web interface (25+), CMS- Claims (no submission required) approved CAHPS for MIPS survey vendor, Administrative Claims Cost Administrative Claims Administrative Claims Advancing Attestation, QCDR, Qualified Attestation, QCDR, Qualified Care Registry, EHR Registry, EHR Information Web interface (25+) Improvement Attestation, QCDR, Qualified Attestation, QCDR, Qualified Activities Registry, EHR, Administrative Registry, EHR, Web interface (25+), Claims (if technically feasible, Administrative Claims (if technically no submission required) feasible, no submission required) 1/17/2017 13

MIPS Quality Measures � Choose 6 measures � Include 1 outcome measure (intermediate outcome or high priority) or � 1 specialty specific measure set https://qpp.cms.gov/measures/quality 1/17/2017 14

Larger Practices Report More � ≥ 25 ECs + web interface � Report 15 quality measures � ≥ 15 ECs and ≥ 200 attributed hospitalizations � All Cause Readmissions is being scored through administrative claims 1/17/2017 15

Fewer Points Earned If… � Does not have a benchmark � Does not have at least 20 episodes � Does not meet data completeness criteria 1/17/2017 16

Scoring Methodology 1/17/2017 17

Quality Point System Measure Name Measure Type Performance Total Potential Potential Points Possible High Priority CEHRT Points Bonus Bonus Points Points Measure 1 Outcome 3 to 10 10 0 (required) 1 Measure 2 High priority 3 to 10 10 0 (required if 1 outcome is N/A) Measure 3 Outcome or patient 3 to 10 10 2 1 experience Measure 4 High priority 3 to 10 10 1 1 Measure 5 ? 3 to 10 10 ? 1 Measure 6 ? 3 to 10 10 ? 1 Total ? 60 ? ? Cap applied to each bonus category Up to 6 Up to 6 (10% of total possible points) Total with high priority and CEHRT bonus Up to 72 1/17/2017 18

MIPS Quality Scoring in a Nutshell 1/17/2017 19

Topped Out Measures � Measures with a median performance rate ≥ 95 % � 2018 is first year that a measure will be scored using this methodology 1/17/2017 20

MIPS APM Quality Measures � OCV submits 31 measures on behalf of practice No. of Measures Domain 8 Pt/Caregiver Experience 10 Care Coordination/ Pt Safety 5 Clinical Care for At-Risk Population 8 Preventive Health https://s3.amazonaws.com/publicinspection.federalregister.gov/2016-26668.pdf (pages 1125-1127) 1/17/2017 21

Current Process � First week of January � Patient records randomly identified � Medicare: 616 per measure � Medicaid and Commercial: 348 per measure � � 7k total patients � OCV clinical consultants extract data � CMS audit possible 1/17/2017 22

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Improvement Activities MIPS MIPS APM � PCMH? Earn full credit � MSSP? Earn full credit points (40) points (40) � CMS will assign same � Maximum credit earned by reporting on activities score to all practices totaling 40 points � Activities weighted as medium (10 points) or high (20 points) � Select from over 90 IAs 1/17/2017 24

https://qpp.cms.gov/measures/ia MIPS IMPROVEMENT ACTIVITY OPTIONS 1/17/2017 25

MIPS IA Scoring in a Nutshell 1/17/2017 26

Advancing Care Information MIPS and MIPS APMs � Required Base Score Measures � Report yes/no and ≥1 in numerator � Performing a Security Risk Analysis � E-Prescribing � Providing Patient Access to Their Data � Sending Summary of Care via HIE � Requesting/Accepting Summary of Care (required 2018) 1/17/2017 27

Advancing Care Information � Performance Score Measures Example 1/17/2017 28

ACI Scoring in a Nutshell 1/17/2017 29

What if I’m in a MIPS APM? � Attest using the same method as MIPS � Practice scores are aggregated on a weighted average � Will result in one group score 1/17/2017 30

Cost/Resource Use � 2017 = 0% � 2018 = 10% � Collected from adjudicated claims � Total per capita costs for all attributed beneficiaries � Annual costs per beneficiary from all sources � Attributed to one Primary Care Provider group � Medicare Spending Per Beneficiary � Charges attributed to inpatient stays � Attributed to provider (group) with plurality of charges � Episodes of Care � 10 anticipated and more being monitored 1/17/2017 31

Financial Impact of MIPS What does budget neutral mean? Incentives are funded by penalties. 1/17/2017 32

Example of Final MIPS Score Calculation � Quality = (42 of 60 points) x 60% weight x100 = 42 points � ACI = (50 of 100 points) x 25% weight x 100 = 12.5 points � IA = (40 of 40 points) x 15% weight x 100 = 15 points � Total MIPS points = 42 + 12.5 + 15 = 69.5 Final Score = 69.5 1/17/2017 33

Program Performance Payment Maximum -% Maximum +% Year Adjustment Payment Payment Year Adjustment Adjustment +4%*X PQRS/VBM 2016 2018 -4% penalty incentive +4%*X MIPS 2017 2019 -4% penalty incentive +5%*X MIPS 2018 2020 -5% penalty incentive +7%*X MIPS 2019 2021 -7% penalty incentive +9%*X MIPS 2020 2022 -9% penalty incentive � Medicare Part B payment adjustments only � For MIPS, X capped at 3.0 plus a 10% "exceptional performance bonus" � For Performance Year 2020, up to 9% x 3.0 + 10% = 37% bonus 1/17/2017 34

Reputational Impact � https://www.medicare.gov/physiciancompare/ 1/17/2017 35