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MIPS Cost Category and Feedback ReportsFebruary 8, 2019
Presented by
Jackie Rogers, Director- Quality Reporting Engagement Group
Kate Elam, MIPS Senior Consultant
Disclaimer
▪ Information presented is done solely for informational and educational
purposes
▪ Information should not be relied upon for purposes of regulatory
compliance or as a guarantee for increased revenues or practice
successes or failures
▪ Information provided herein does not constitute and should not
substitute for legal advice; Practice should consult with Practice’s own
legal and regulatory counsel regarding all applicable legal and
regulatory requirements
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Performance Thresholds
Minimum points needed to avoid a downward adjustment
2019
Performance Thresholds
Minimum points needed to earn an Exceptional Performer Bonus
2019
MIPS Exceptional Performers
▪962 QREG Eligible Clinicians scored over 70 Points- 99.4%
▪48 QREG Eligible Clinicians scored 100 Points (Perfect Score)- 4.9%
▪6 QREG Eligible Clinicians scored under 70 Points- 0.6%
▪QREG Eligible Clinicians Average Score utilizing our full MIPS Services - 89.8 out of 100 points
▪QREG Eligible Clinicians Average Score utilizing our MIPS Alternative Service (ACI/IA categories only)- 48.25out of 50 points
Note: For 2017 and 2018, 70 points or more put Eligible Clinicians into the ‘Exceptional Performer’ category for MIPS reporting. This makes Clinicians eligible to receive from additional bonus pool of $500M for all those clinicians who were in this category.
MIPS – 2019
How data is submitted to the Quality Payment Program (QPP)
Cost Category Overview
Cost Category
▪ Bipartisan Budget Act 2018:
- 30% in first post-transition year (2022)
- May vary through 2021(10-30%)
▪ 2019 Finalized at 15%
- Anticipate Cost category to increase
by 5% each year
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QUALITY – 45%
PI – 25%IA – 15%
COST –
15%
Cost Category
▪ CMS uses Medicare claims data to calculate cost measure
performance
▪ Payment standardization
- Regional differences in labor costs and practice expenses
- Differences in the relative price of inputs in local markets where a service is provided
- Extra payments from Medicare in medically under-served regions
- Policy-driven payment adjustments such as those for teaching hospitals
▪ Benchmarks are established each year AFTER performance period
ends
- 2019 benchmarks will be determined based on 2019 claims data
- Benchmarks are same for all clinicians nationally
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Cost Category
▪ LOW COST = HIGH SCORES
▪ Scoring
- Practices who report as a group are scored on Cost as a group
- Practices who report as individuals are scored on Cost individually
- Will receive feedback for individuals, where applicable, even if the practice reported as a group
▪ 10 points per measure
▪ Only scored on measures that meet or exceed the case minimum
▪ Episode-based measures are not scored for 2018 or 2019 performance, but may be scored starting in 2020
- Feedback is provided if you meet the case minimum for any episode-based measure
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Total Per Capita Cost
Total Per Capita Cost
▪ The TPCC measure includes all Part A and Part B costs for an
attributed Medicare patient
▪ Cost = Medicare allowed charges
▪ Includes all of the Part A and B charges billed by any clinician or facility
during the performance period
- The total per capita cost of the patient is NOT just what your practice billed
▪ Each patient is attributed to one NPI-TIN
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TPCC
Total Per Capita Cost
▪ Attribution
- STEP 1: Patient is attributed to whichever PCP, NP, PA, or CNS provided the
most primary care services
- STEP 2: If the patient did not receive a primary care service from any PCP,
NP, PA, or CNS during the year, then the patient is attributed
- “Most” meaning allowed $
▪ Patients are NOT attributed to specialists if they have seen a PCP
during the year
▪ NPs, PAs, or CNSs who bill “incident to” do not fall under Step 1
▪ Case minimum: 20 patients
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TPCC
Total Per Capita Cost
▪ Primary Care Services
- E&M services
- Initial Medicare visits
- Annual wellness visits
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TPCC
Total Per Capita Cost
▪ Cost adjustments
- Annualized cost
>Adjusts cost based on Medicare new enrollee status or if patient died during the
year
>
- Risk-adjusted costs
>79 Hierarchical Condition Category (HCC) indicators from a beneficiary’s claims
during the 90-day period before the start of the episode
>End stage renal disease (ESRD) status
- Specialty adjusted cost
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TPCC
Medicare Spending Per Beneficiary
Medicare Spending Per Beneficiary
▪ The MSPB measure includes all Medicare Part A and Part B claims
surrounding a patient’s hospital inpatient stay, including 3 days prior to
admission through 30 days post-discharge
▪ Attribution: Each MSPB episode is attributed to the TIN-NPI
responsible for the plurality of Part B Physician/Supplier services
during the episode
▪ Case minimum: 35 episodes
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MSPB
Medicare Spending Per Beneficiary
▪ Risk adjustment
- 79 Hierarchical Condition Category (HCC) indicators from a beneficiary’s claims during the 90-day
period before the start of the episode
- Recent long-term care status
- End stage renal disease (ESRD) status
- The Medicare Severity Diagnosis-Related Group (MS-DRG) code of the index hospital admission
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MSPB
Episode-Based Measures
Episode-Based Measures
▪ Elective Outpatient Percutaneous Coronary Intervention (PCI)
▪ Knee Arthroplasty
▪ Revascularization for Lower Extremity Chronic Critical Limb Ischemia
▪ Routine Cataract Removal with Intraocular Lens (IOL) Implantation
▪ Screening/Surveillance Colonoscopy
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▪ Intracranial Hemorrhage or Cerebral Infarction
▪ Simple Pneumonia with Hospitalization
▪ ST-Elevation Myocardial Infarction (STEMI) with Percutaneous Coronary Intervention (PCI)
Procedural MeasuresAcute Inpatient Medical
Condition Measures
Feedback Only in 2018/2019
Case Minimum: 10 Case Minimum: 20
Feedback Reports
HARP User Access
▪ https://qpp.cms.gov
- MIPS submission
- Program requirements and resources
- Eligibility lookup
- Feedback reports
▪ Previously managed under Enterprise Identity Management (EIDM)
▪ Security Official or practice representative connects to the practice Tax
ID number
▪ Step-by-step walkthrough of account creation for first time users:
https://www.youtube.com/watch?v=4xGkWvPa33E
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What’s in a Feedback Report
▪ You receive MIPS feedback on all categories for which you submit
data
▪ You receive Cost data on measures for which you meet the case
minimum
- If you only met the case minimum for TPCC, but not MSPB, you only receive
feedback on TPCC
▪ Patient details are not included
- CMS has stated the are planning to provide these details in future
feedback—possibly 2018?
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2017 Feedback available now in QPP portal
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TPCC Feedback
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Items & Services
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In relation to TPCC
MSPB Feedback
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Where can I go if I need help?
Quality Reporting Engagement Group- QREG
Resources
▪ QPP/MIPS Resources:
- https://qpp.cms.gov/
- https://qpp.cms.gov/about/resource-library
- https://qpp.cms.gov/participation-lookup
- https://www.youtube.com/watch?v=4xGkWvPa33E
▪ QPP Help Desk: 1-866-288-8292
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