macra/mips for 2017 made easy: it’s not too late...sep 07, 2017 · macra/mips for 2017 made...
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MACRA/MIPS for 2017 Made Easy: It’s Not Too Late
10:55 AM – 11:55 AM Steering Toward Success - Achieving Value in Whole Person Care September 25 and October 26, 2017
The Healthier Washington Practice Transformation Support Hub
Steering Toward Success: Achieving Value in Whole Person Care
Barbara Wall, ADN, BSHA, JD
Attune Healthcare Partners
MIPS Decisions Made Easy: It’s Not Too Late
Be able to explain:
• MACRA’s changes to the Medicare payment system
• How MIPS works & why it is important to submit for 2017
• How to decide on the practice’s 2017 plan for MIPS
Learning Objectives
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MIPS Pays a % of the Medicare Physician Fee Schedule Based on Performance in Four Weighted Categories
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• Composite Performance Scoring for 2017: – 0 points: – 4% adjustment to fee schedule – 3 points: 0% adjustment – 4-70 points: positive adjustment – 71-100 points: bonus payment
• Performance Thresholds – 2017: 3 points – 2018: 15 points (proposed) – 2019: rises to national average
MIPS Learning Opportunity: 2017 - 2018
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1. Choose reporting strategy (test, partial, full)
2. Choose practice reporting approach (group or individual)
3. Select quality measures
4. Choose data submission method for each category
5. Consider/select improvement activities
6. Review ACI requirements, identify practice abilities
6 Steps to MIPS Decisions
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#1 Choose 2017 Reporting Strategy: Test vs. Partial Year (if Missed 1 Year Start)
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Individual Group (> 2 ECs/Same TIN) • Each EC can select reporting measures
• Measures selected for entire group
• If 1 reports as individual, all must • Applies to all 4 performance categories
• If select Group, no individual opt out • Applies to all 4 performance categories
• No reporting for low volume exempt • Data included for low volume exempted could affect score for whole group
• Can report using Claims for Quality Category
• Can report by CMS Web Interface (25+) • Can report CAHPS for MIPS survey
Advantage • Performance report is individualized:
better for planning improvement Disadvantage • More work for the individual
Disadvantage • Performance score/report is aggregated:
does not target individual improvement Advantage • Less work for individual group members
#2 Choose 2017 Practice Reporting Approach (Individual vs. Group)
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• 60% of MIPS Score in 2017
• Max possible points = 60 – 10 pts X 6 measures (include 1 Outcome)
• Bonus points – capped at 6 points – 2: each add. Outcome Measure (after 1st) – 1: each add. High Priority Measure – 2: each Patient Experience Measure – 1: End-to-End Electronic Reporting
• Data completeness = report on > 50% of patients in denominator
• 20 Case minimum
• Benchmarks are set for most quality measures
#3 Select Quality Measures – Basics
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#3 Quality Measure Scoring: Decile Point Scale
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#3 Point Scale for Each Measure is Based on Peer Performance
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#3 Point Range Unique to Each Measure is Available on Benchmark List – Points Also Vary by Submission Method
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Screening for High Blood Pressure & Follow Up
Performance Claims Score Registry Score EHR Direct
89% 7.6 9 10
1. ID measures for your targeted disease populations & prevention initiatives
2. ID quality measures that quantify resource use and match your targeted cost saving initiatives
3. ID at least 1 Outcome Measure
4. Eliminate those – Without a benchmark – Are topped out – Those with < 20 cases – You are unable to report on with at least
50% of the patients in the denominator
#3 Develop Target Quality Measure List
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5. Evaluate & give remaining measures a +/- on basis of:
– Are hard/easy to document its elements – Require significant change in how you currently
document the elements – Are hard/easy to calculate – Bonus points (capped at 6 points) – You will score well on the measure – It supports your cost savings initiative(s)
6. Select target quality measures
#3 ID Target Quality Measures
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7. Validate documentation practices, data collection & reporting ability for target measures – run sample reports on selected measures
8. Look up your target measures on the Benchmark List to compare your performance (%) to the percentages within the deciles to see how many points you will score on that measure
9. Finalize measure selection: remember that MIPS scores become public information and balance measures your practice can perform well on with measures that support your cost improvement initiatives
#3 Select Your Quality Measures
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#4 Choose A Data Submission Method for Each Category – Quality Category
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Method # Avail. Outcome (All/PCP)
High Priority
No Bench Mark
Topped Out
Bench Marks Not Topped
Claims 74 9/2† 42 31% 49% 20%
Registry 243* 69/6† 158 53% 23% 24%
EHR 53 7/4† 21 17% 9% 74%
• For Qualified Clinical Data Registries (QCDR), the number of measures available depends on what measures the QCDR has been approved for and has implemented.
• †See Appendix for list of Quality Outcome Measures for Primary Care with Submission Method
Performance Claims Score Registry Score EHR Direct
89% 7.6 9 10
#4 Pro & Cons of Submission Methods – Applies to All Categories
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Method Considerations
Claims • Confusion and inaccurate reporting of codes for the quality measures
• Shared responsibility with billing company • Most affordable option but limited # of measures • Only available to individuals for Quality Category • Medicare patients only (not all payers)
QCDR/ Qualified Registry
• Qualified Registries have the most measures; QCDRs are often specialty-specific => may have more or less measures than Qualified Registries
• Usually pay a registration fee + fees for data integration; but some national specialty orgs offer free or low cost QCDRs
• May be difficult to link to some EHRs and auto-extract data (often requires manual data entry)
#4 Pro & Cons of Submission Methods – All Categories (Continued)
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Method Considerations
Attest • Affordable; no submission data required • Must keep documentation for CMS audits
CEHRT • Vendor submits data; must trust vendor to submit correctly and accurately
• Limited # of measures can be reported by EHR
CMS Web Interface
• Only for groups > 25 Eligible Clinicians & must register by June 30, 2017
• More data required: report full year & 14 measures
CAHPS for MIPS
• Must register by June 30, 2017 • Must be reported in conjunction with another
submission method
• 15 % of Composite Score
• 90 continuous days minimum – Except for Test
• Full credit – 2 high or 4 medium: most eligible clinicians
– 1 high or 2 medium: TINs < 15, in a rural or health professional shortage area, & non-patient facing clinicians
– Certified PCMH/recognized specialty program
– In currently designated MIPS APMs
• Half credit – Other APMs
#5 Consider/Select Improvement Activities – Category Basics
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• Consider those activities aligned with targeted patient populations, quality measures, processes for cost/quality improvement, or ACI practice needs
• See Appendix for suggestions on improvement activities for high impact populations and methods
• Select submission method: Attestation, QCDR, Qualified Registry, CEHRT
#5 Select Improvement Activities & Category Submission Method
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• 25% of Composite Score – 2014 and/or 2015 CEHRT
• Base Score + Performance Score + Bonus Score
• Minimum for Base Score: o Security Risk Analysis
o “Yes” during performance period or no score for ACI category
o E-Prescribing o Provide Patient Access* o Health Information Exchange (2014)* o Send Summary of Care & Request/Accept Summary of Care
(2015)* *Also count as Performance Measures
• Performance score for up to 9 measures
#6 Review ACI Requirements
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• Decide whether to attest/submit
– Probably need a professionally done Security Risk Analysis to pass audit
– If you can’t meet requirements for base measures, no points awarded for performance measures
• Develop list of work to do in this area to support improvement initiatives
• Select submission method: Attestation, QCDR, Qualified Registry, CEHRT
#6 Review ACI Requirements & Identify Practice Abilities and Needs
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Implementation: 1. Update your EHR once measures have been
selected
2. Review and update necessary templates
3. Revise workflows to make it practical for end users
4. Provide prompts when available to providers and staff for overdue or out of performance measures for individual patients during visits
– based on measure denominators
Then What?
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5. Develop reports identifying care gaps and work flows for patient outreach to close gaps
6. Provide training and audit performance on correct & complete data input
7. Develop understanding of processes and requirements for reporting using EHR, & registries right away
– Registry set up takes 2-3 months & data due date is 4-6 weeks before CMS cut-off of 3/31/18
Implementation - Continued
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Barbara Wall Senior Partner Attune Healthcare Partners (206) 629-4174 [email protected] www.attunehealthcare.com
Questions?
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Quality Payment Program Resources
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Attune Healthcare Partners
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www.AttuneHealthcare.com
For More Information about the Quality Payment Program
• Qualis Health QPP Resource Center
• Medicare.qualishealth.org/QPP
• 877-560-2618
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Q & A
The project described was supported by Funding Opportunity Number CMS-1G1-14-001 from the U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services. The contents provided are solely the responsibility of the authors and do not necessarily represent the official views of HHS or any of its agencies.
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Appendix 1: Primary Care Quality Outcome Measures
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Appendix 2. Quality Measures Supporting Cost Initiatives
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Appendix 2. Quality Measures Supporting Cost Initiatives – Cont.
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Appendix 2. Quality Measures Supporting Cost Initiatives – Cont.
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Appendix 3. Improvement Activities Supporting Cost Initiatives
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Appendix 3. Improvement Activities Supporting Cost Initiatives – Cont.
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Appendix 3. Improvement Activities Supporting Cost Initiatives – Cont.
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Appendix 3. Improvement Activities Supporting Cost Initiatives – Cont.
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