MIPS VALUE PATHWAYS RFI OVERVIEW

SEPTEMBER 4, 2019

Disclaimers

This presentation was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services.

This publication is a general summary that explains certain aspects of the Medicare Program, but is not a legal document. The official Medicare Program provisions are contained in the relevant laws, regulations, and rulings. Medicare policy changes frequently, and links to the source documents have been provided within the document for your reference

The Centers for Medicare & Medicaid Services (CMS) employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this presentation.

2

Quality Payment ProgramTopics

• Quality Payment Program Overview

• Merit-based Incentive Payment System (MIPS) Overview

• MIPS Value Pathways (MVP) Overview and Examples

• MVP RFI Questions for Consideration

• Help & Support

3

MIPS Value Pathways RFIHow to Comment on the MVP RFI

• Proposed rule includes proposed changes not reviewed in this presentation so please refer to proposed rule for complete information.

• Feedback during presentation not considered as formal comments; please submit comments in writing using formal process.

• See proposed rule for information on submitting comments by close of 60-day comment period on September 27 (When commenting refer to file code CMS-1715-P).

• Instructions for submitting comments can be found in proposed rule; FAX transmissions will not be accepted.

• You must officially submit your comments in one of following ways:

- electronically through Regulations.gov

- by regular mail

- by express or overnight mail

- by hand or courier

• For additional information, please go to: qpp.cms.gov. 4

QUALITY PAYMENT PROGRAMOverview

5

Quality Payment Program

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS by law to implement an incentive program, referred to as the Quality Payment Program, that provides two participation tracks:

6

Quality Payment Program

7

Strategic Objectives

Improve beneficiary outcomes

Increase adoption of Advanced APMs

Improve data and information sharing

Reduce burden on clinicians

Maximize participation

Ensure operational excellence in program implementation

Deliver IT systems capabilities that meet the needs of users

Quick Tip: For additional information on the Quality Payment Program, please visit qpp.cms.gov

MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)Overview

8

Merit-based Incentive Payment System (MIPS)

9

Quick Overview

Combined legacy programs into a single, improved program.

Physician Quality Reporting System (PQRS)

Value-Based Payment Modifier (VM)

Medicare EHR Incentive Program (EHR) for Eligible Professionals

MIPS

Merit-based Incentive Payment System (MIPS)Quick Overview

MIPS Performance Categories

• Comprised of four performance categories.

• So what? The points from each performance category are added together to give you a MIPS Final Score.

• The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment.

10

*Revised weights according to the 2020 Proposed Rule

11

Merit-based Incentive Payment System (MIPS)Terms and Timelines

As a refresher…

• TIN - Tax Identification Number

- Used by the Internal Revenue Service to identify an entity, such as a group medical practice, that is subject to federal taxes

• NPI – National Provider Identifier

- 10-digit numeric identifier for individual clinicians

• TIN/NPI

- Identifies the individual clinician and the entity/group practice through which the clinician bills services to CMS

Performance Period Also referred to as… Corresponding Payment Year

2017 2017 “Transition” Year 2019

2018 “Year 2” 2020

2019 “Year 3” 2021

2020 “Year 4” 2022

12

Merit-based Incentive Payment System (MIPS)Timelines

Performance period

2020Performance Year

• Performance period opens January 1, 2020

• Closes December 31, 2020

• Clinicians care for patients and record data during the year

submit

March 31, 2021Data Submission

• Deadline for submitting data is March 31, 2021

• Clinicians are encouraged to submit data early

Feedback available

Feedback

• CMS provides performance feedback after the data is submitted

• Clinicians will receive feedback before the start of the payment year

adjustment

January 1, 2022Payment Adjustment

• MIPS payment adjustments are prospectively applied to each claim beginning January 1, 2022

MIPS VALUE PATHWAY (MVP) OVERVIEWOverview

13

Current Participation in MIPS Stakeholder Feedback

What we’ve been hearing from clinicians:

• The current structure of MIPS and the reporting requirements are confusing

• There is too much choice and complexity when it comes to selecting and reporting measures and activities

• The measures and activities aren’t always relevant to a clinician’s specialty

• It’s hard for patients to compare performance across clinicians

14

MIPS Value Pathways

Why do we need a new participation framework for MIPS?

15

While there have been incremental changes to the program each year, additional long-term improvements are needed to align with CMS’ goal to develop a meaningful program for every clinician, regardless of practice size or specialty.

MIPS Value PathwaysRequest for Information

• CMS has proposed to create a new participation framework, called the MIPS Value Pathways (MVPs), which would begin with the 2021 performance year.

• This new framework would:

- Unite and connect measures and activities across the Quality, Cost, Promoting Interoperability, and ImprovementActivities performance categories of MIPS

- Incorporate a set of administrative claims-based quality measures that focus on population health/public health priorities

- Streamline MIPS reporting by limiting the number of required specialty or condition specific measures

16

MIPS Value Pathways

17

Future State ofMIPS(In Next 3-5Years)

Current Structure ofMIPS(In 2020)

New MIPS Value PathwaysFramework(In Next 1-2Years)

Building Pathways FrameworkMIPS Value Pathways

Clinicians report on fewer measures and activities baseon specialty and/or outcome within a MIPS ValuePathway

Moving toValue

Fully ImplementedPathwaysContinue to increase CMS provided data and feedback to

reduce reporting burden on clinicians

• Many Choices

• Not Meaningfully Aligned

• Higher Reporting Burden

• Cohesive

• Lower Reporting Burden

• Focused Participation around Pathways that are Meaningful to Clinician’s Practice/Specialty or Public Health Priority

• Simplified

• Increased Voice of thePatient

• Increased CMS Provided Data

• Facilitates Movement to Alternative Payment Models (APMs)

2-4Activities

ImprovementActivities

Quality

6+Measures

PromotingInteroperability

6+Measures

Cost

1 or MoreMeasures

Cost

Quality and IA aligned

Foundation

Promoting Interoperability

Population Health Measures

Foundation

Promoting Interoperability

Population Health Measures

Enhanced Performance Feedback

Patient-Reported Outcomes

Value

Quality ImprovementActivities

Cost

We Need Your Feedback on:

Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues;

CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.

Goal is for clinicians to report less burdensome data as MIPS evolves and for CMS to provide more datathrough

administrative claims and enhanced performance feedback that is meaningful to clinicians andpatients.Clinician/Group Reported Data CMS Provided Data

Pathways:

What should be the structure and focus of the Pathways? What criteria should we use to select measures and activities?

Participation:

What policies are needed for small practices and multi-specialty practices?Should there be a choice of measures and activities withinPathways?

Public Reporting:

How should information be reported to patients?

Should we move toward reporting at the individual clinician level?

MIPS Value Pathways: Surgical Example

18

MIPS moving towards value; focusing participation on specific meaningful measures/activities or public health priorities;facilitating movement to Advanced APMtrack

2-4Activities

ImprovementActivities

Quality

6+

Measures

PromotingInteroperability

6+

Measures

Cost

1 or MoreMeasures

Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues;CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmissionmeasure.

Completion of an Accredited Safety or Quality Improvement Program(IA_PSPA_28)

Patient-Centered Surgical Risk Assessment and Communication (Quality ID:358) OR

Implementing the Use of Specialist Reports Back to Referring Clinicianor Group to Close Referral Loop (IA_CC_1)

Revascularization for Lower Extremity Chronic Critical Limb Ischemia (COST_CCLI_1)

Knee Arthroplasty (COST_KA_1)

Surgical Site Infection (SSI) (Quality ID:357)

Use of Patient SafetyTools (IA_PSPA_8) Medicare Spending Per Beneficiary (MSPB_1)Unplanned Reoperation within the 30-Day Postoperative Period (Quality ID: 355)

QUALITY MEASURES

MIPS Value Pathways for Surgeons

COST MEASURES

*Measures and activities selected for illustrative purposes and are subject to change.

IMPROVEMENT ACTIVITIES

Surgeon reports on same foundation of measures with patient-reported outcomes also included

Performance category measures in Surgical Pathway are more meaningful to thepractice

CMS provides even more data (e.g. comparative analytics) using claims data and surgeon’s reporting burden evenfurther reduced

Surgeon chooses from same set ofmeasures as all other clinicians, regardless of specialty or practicearea

Four performance categories feel likefour different programs

Reporting burden higher and population health not addressed

Surgeon reports same “foundation” of PI and population health measures as all other cliniciansbut now has a MIPS Value Pathway with surgical measures and activities aligned with specialty

Surgeon reports on fewer measures overall in apathway that is meaningful to theirpractice

CMS provides more data; reporting burden onsurgeon reduced

Clinician/Group CMS Clinician/Group CMSClinician/Group CMS

ImprovementActivities

CostQuality

Foundation

Promoting Interoperability

Population Health Measures

Foundation

Promoting Interoperability

Population Health MeasuresEnhanced Performance Feedback

Patient-Reported Outcomes

Future State of MIPS(In Next 3-5 Years)

Current Structure of MIPS(In 2020)

New MIPS Value PathwaysFramework(In Next 1-2 Years)

Cost

Quality and IA aligned

MIPS Value Pathways: Diabetes Example

19

MIPS moving towards value; focusing participation on specific meaningful measures/activities or public health priorities;facilitating movement to Advanced APMtrack

2-4Activities

ImprovementActivities

Quality

6+

Measures

PromotingInteroperability

6+

Measures

Cost

1 or MoreMeasures

Population Health Measures: a set of administrative claims-based quality measures that focus on public health priorities and/or cross-cutting population health issues; CMS provides the data through administrative claims measures, for example, the All-Cause Hospital Readmission measure.

Electronic Submission of Patient Centered Medical Home Accreditation (IA_PCMH)

Evaluation Controlling High Blood Pressure (Quality ID: 236)

OR

Medicare Spending Per Beneficiary (MSPB_1)Diabetes: Medical Attention for Nephropathy (Quality ID: 119)

Glycemic Management Services (IA_PM_4) Total Per Capita Cost (TPCC_1)Hemoglobin A1c (HbA1c) Poor Care Control (>9%) (Quality ID: 001)

QUALITY MEASURES

MIPS Value Pathways for Diabetes

COST MEASURES

*Measures and activities selected for illustrative purposes and are subject to change.

IMPROVEMENT ACTIVITIES

Chronic Care and Preventative Care Management for Empaneled Patients

(IA_PM_13)

Endocrinologist reports on same foundation of measures with patient-reported outcomes also included

Performance category measures in endocrinologist’s Diabetes Pathway are more meaningful to their practice

CMS provides even more data (e.g. comparative analytics) using claims data and endocrinologist’s reporting burden even further reduced

Endocrinologist chooses from same set of measures as all other clinicians, regardless of specialty or practice area

Four performance categories feel likefour different programs

Reporting burden higher and population health not addressed

Endocrinologist reports same “foundation” of PI and population health measures as all other clinicians but now has a MIPS Value Pathway with measures and activities that focus on diabetes prevention and treatment

Endocrinologist reports on fewer measures overall in a pathway that is meaningful to their practice

CMS provides more data; reporting burden on endocrinologist reduced

Clinician/Group CMS

ImprovementActivities

CostQuality

Foundation

Promoting Interoperability

Population Health Measures

Foundation

Promoting Interoperability

Population Health MeasuresEnhanced Performance Feedback

Patient-Reported Outcomes

Future State of MIPS(In Next 3-5 Years)

Current Structure of MIPS(In 2020)

New MIPS Value PathwaysFramework(In Next 1-2 Years)

Cost

Quality and IA aligned

Clinic ian/Group CMSClinic ian/Group CMS

Feedback Categories

• We are requesting information in the following areas:- MVP Approach, Definition, Development, Specification,

Assignment, and Examples

- Selection of Measures and Activities for MVPs

- MVP Assignment

- Transitioning to MVPs

- Small and Rural Practices Participation in MVPs

- Multispecialty Practices Participation in MVPs

- Incorporating QCDR Measures into MVPs

- Scoring MVP Performance

- Population Health Quality Measure Set

- Clinician Data Feedback

- Patient Reported Measures

- Publicly Reporting MVP Performance Information20

MVPS REQUEST FOR INFORMATIONDeveloping MVPs in Partnership with Stakeholders

21

MIPS Value Pathways

22

More information available on the QPP website at: https://qpp.cms.gov/mips/mips-value-pathways

23

Technical AssistanceAvailable Resources

Learn more about technical assistance: https://qpp.cms.gov/about/help-and-support#technical-assistance

Comments due September 27When and Where to Submit Comments

• See proposed rule for information on submitting comments by close of 60-day comment period on September 27 (When commenting refer to file code CMS-1715-P)

• Instructions for submitting comments can be found in proposed rule; FAX transmissions will not be accepted

• You must officially submit your comments in one of following ways:

- electronically through Regulations.gov

- by regular mail

- by express or overnight mail

- by hand or courier

24

25

Q&A Session

• CMS must protect rulemaking process and comply with Administrative Procedure Act

• Participants are invited to share initial comments or questions, but only comments formally submitted through process outlined by Federal Register taken into consideration by CMS

• See proposed rule for information on how to submit a comment

Q&A Session

To ask a question, please dial:

1-866-452-7887

If prompted, use passcode: 649 7764

Press *1 to be added to the question queue.

You may also submit questions via the chat box.

Speakers will answer as many questions as time allows.

26

Questions

27