2018 mips update€¦ · category reporting requirements. quality – report 6 measures – include...

2018 MIPS Update

Beth HickersonQPP Advisor

November 9, 2017

Value Driven. Health Care. Solutions.

Disclaimer

Medical Advantage Group would like to disclose that no one in a position to control or influence the content of this activity has reported relevant financial relationships with commercial interests.

The information and guidelines contained in this activity are generalized and may not apply to all practice situations. The faculty recommends that legal advice be obtained from a qualified attorney for specific application to your practice.The information is intended for educational purposes and should be used as a reference guide only.

2Value Driven. Health Care. Solutions.

Housekeeping

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Submit questions– Use the GoToWebinar control panel

– Chat window– We’ll open up the phones toward

the end for live Q&A

After the webinar– All registrants to receive copy

of presentation + link to webinar recording


WHAT DOES NOT CHANGE IN 2018?

MIPS Eligible Providers

Years 1 and 2 Medicare Part B clinicians:

Physicians MD, DOPodiatristsOptometristsChiropractorsDentistsPhysician AssistantsNurse PractitionersClinical Nurse SpecialistsCertified Registered Nurse Anesthetists

Year 3+ Medicare Part B clinicians:

Occupational TherapistsPhysical TherapistsSpeech TherapistsAudiologistsNurse MidwivesClinical Social WorkersDietitians


Who is Exempt from MIPS?

3 groups of clinicians:


First year of Medicare Part B

participation

Below low patient volume threshold

Certain participants in

ADVANCEDAlternative

Payment ModelsBUT low-volume threshold

has increased!

Category Reporting Requirements

Quality– Report 6 measures– Include at least one outcome or high-priority measureAdvancing Care Information– ACI Objectives and Measures OR– 2017 ACI Transition Objectives and MeasuresImprovement Activities – Attest to up to 4 activities– Double-credit for small, rural, and under-served practicesCost– No submission required, data collected from claims


Submission Methods

MIPS GENERAL CHANGES

Payment Adjustment Increase

Takeaway:• Stakes are getting higher each year.• Payment year 2021 increases to -/+7%

Payment Year 2019 Payment Year 2020-4% to +4% -5% to +5%

Category Weights


Quality Advancing Care

Information

Improvement Activities

Cost

50% 25% 15% 10%

Takeaway:• Cost will factor into your 2018 MIPS Final Score!

Reporting Periods


2017 201Category 2017 2018

Quality 90 days 365 days

Advancing Care Information 90 days 90 days

Improvement Activities 90 days 90 days

Cost 365 days 365 days

Takeaway:• Quality measure workflows and tracking must be in

place by January 1 for optimal performance.

Low-volume Threshold

Takeaway:• Many providers who were NOT exempt in 2017 will be

exempt in 2018.• Elective participation in 2018?

• Individual – no incentive, regardless of performance• Group – subject to same payment adjustment as

group

2017 2018</= $30,000 Part B charges </= $90,000 Part B charges</+ 100 Part B patients </+ 200 Part B patients

Virtual Groups

Combination of 2 or more TINs made up of 1-10 eligible clinicians who report aggregated dataEach TIN must exceed the low-volume thresholdSubject to the same requirements and benefits as single TIN groupsNot specialty or location specificElection process requiredMore info available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/2018-Virtual-Groups-Toolkit.zip


https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/2018-Virtual-Groups-Toolkit.zip

Performance threshold

Takeaway:• You can NOT avoid penalty by submitting just one

Quality measure.• You CAN avoid penalty by topping out your

Improvement Activities category score.

2017 20183 points 15 points

Exceptional Performer Threshold

Takeaway:• Earning the extra 0.5% to 10% incentive is still very

achievable for providers reporting all MIPS categories.

2017 201870 points 70 points

Complex Patient Bonus

Up to 5 points for the treatment of complex patients – Based on Hierarchical Condition Categories (HCCs)

and– Number of dually eligible patients treatedAdded to MIPS Final Score

Takeaway:• Make sure your providers are coding to maximize

HCCs.


Small Practice Bonus

Five points automatically added for any individual or group who is in a small practice (15 or fewer providers)Must submit data in at least 1 MIPS categoryAdded to MIPS Final Score

Takeaway:• No extra work necessary!


MIPS Hardship Exceptions

Designed to accommodate providers impacted by natural disasters (hurricanes, fires, etc.)Impacted providers will not receive a penalty if they fail to report MIPS dataRetroactive to 2017Automatically given in 2017 to all providers in identified areas (hurricanes Irma and Harvey, wildfires, etc.)Providers must apply for exception in 2018


QUALITY CHANGES

Quality Measures


2017 2012017 2018

Total # of measures 291 297Specialty measure sets 31 32Removed n/a 3New n/a 9Substantive changes n/a 12

Takeaway:• Vast majority of practices will be able to report the same

Quality measures in 2018

Removed Quality Measures

Stroke and Stroke Rehabilitation: Discharged on Antithrombotic TherapyParkinson’s Disease: Parkinson’s Disease Medical and Surgical Treatment Options ReviewedUse of Imaging Studies for Low Back Pain


Takeaway:• If you are reporting any of these measures in 2017, you

will not be able to report them in 2018.

New Quality Measures

Well-child visits in the third, fourth, fifth and sixth year of lifeDevelopmental screenings in the first three years of lifeAverage Change in Back Pain following Lumbar Discectomy / LaminotomyAverage Change in Back Pain following Lumbar FusionAverage Change in Leg Pain following Lumbar Discectomy / LaminotomyBone Density Evaluation for Patients with Prostate Cancer and Receiving Androgen Deprivation TherapyPrevention of Post-Operative Vomiting (POV) - Combination Therapy (Pediatrics)Otitis Media with Effusion (OME): Systemic Antimicrobials-Avoidance of Inappropriate UseUterine Artery Embolization Technique: Documentation of Angiographic Endpoints and Interrogation of Ovarian Arteries


Substantive Measure Changes

Tobacco Use: Screening and Cessation Intervention– Now 3 rates instead of 1Body Mass Index (BMI) Screening and Follow-Up Plan– Decreased BMI measurement frequency from 6 months to 12

monthsInfluenza Immunization– Removed 2 visit requirement for inclusion in denominatorUse of High-Risk Medications in the Elderly– Rate B changed from two different medications to two instances

of the same medicationClosing the Referral Loop: Receipt of Specialist Report – Added option to report via registry


Data Completeness Criteria

Submission Method 2017 2018Claims 50% of Medicare Part B 60% of Medicare Part B

Registry, QCDR, EHR

50% of all payors 60% of all payers

Web Interface Medicare Part B sampling Medicare Part B sampling

CAHPS for MIPS Medicare Part B sampling Medicare Part B sampling


Takeaway:• If you submit via claims, manually enter data into a

registry, or practice in multiple settings, make sure you are reporting on 60% of applicable patients

Quality Scoring - No Changes

3-point minimum for all reported Quality measures scored against a benchmark3 points for each measure that– Does not have a benchmark– Does not have at least 20 patients in the denominatorBonus points for additional outcome and high priority measure reportingBonus points for end-to-end electronic reporting

Takeaway:• Keep doing what you’re doing.


Quality Scoring - Changes

Reported measures that do not meet data completeness requirements will score– 3 points for small practices (15 or fewer providers)– 1 point for larger practices (16 or more providers)

Takeaway:• Small practices – no effective change• Large practices – virtually no credit for reporting

measures that do not meet data completeness standards


Quality Scoring – Topped Out Measures


Six measures with 7-point scoring maximum– Perioperative Care: Selection of Prophylactic Antibiotic-First or

Second Generation Cephalosporin– Melanoma: Overutilization of Imaging Studies in Melanoma– Perioperative Care: Venous Thromboembolism (VTE)

Prophylaxis (When Indicated in ALL Patients– Image Confirmation of Successful Excision of Image Localized

Breast Lesion– Optimizing Patient Exposure to Ionizing Radiation: Utilization of a

Standardized Nomenclature for Computerized Tomography (CT) Imaging Description

– Chronic Obstructive Pulmonary Disease (COPD): Inhaled Bronchodilator Therapy

Quality Scoring - Improvement Points

Earn up to 10 points for improving your achievement score (without bonus points) over 2017Improvement measured at the category levelImprovement must be statistically significant to earn pointsMore improvement = more bonus points

Takeaway:• Improvement can have a significant payoff. You will

earn more points for the measure itself AND earn overall improvement points.


ADVANCING CARE INFORMATION CHANGES

New Base Measure Exclusions

Electronic Prescribing– Claim exclusion if provider/group writes fewer than

100 prescriptions during the reporting periodHealth Information Exchange – Claim exclusion if provider/group refers fewer than

100 patients during the reporting period

Takeaway:• Many providers practicing in acute care settings can

now successfully report ACI.• You can avoid the hassle of sending electronic

summaries of care for a couple more years.


CEHRT Edition Requirements

Can use 2014 Edition and/or 2015 Edition technology to report2015 Edition will be required in 2019 reporting year90 day reporting period for 2018 and 2019

Takeaway:• You can continue to use the 2017 Advancing Care

Information Transition List of Objectives and Measures in 2018.

• Select a reporting period for 2018 that is prior to your 2015 Edition update, if possible.


ACI Measures Scoring

Measure Type 2017 2018Base measures Must have 1 in

numerator for each measure to earn 50%

category score

Must have 1 in numerator for each to

earn 50% category score

Performance Measures

Earn 1-10 performance points for each optional

measure submitted

Earn 1-10 performance points for each optional

measure submitted

Public Health or QCDR reporting

Not eligible for performance points

Earn 10% performance points


T k

Takeaway:• Very similar to 2017 scoring

ACI Bonus Points

Measure Type 2017 2018CEHRT Improvement Activity

10% bonus points 10% bonus points

Use of 2015 CEHRT

No points awarded 10% bonus points

Public Health or QCDR reporting

Earn 5% bonus points 5% bonus point for reporting to second PH

agency or QCDR


Takeaway:• Additional bonus point options not feasible for most

practices

IMPROVEMENT ACTIVITIES CHANGES

Improvement Activities

Submission Method

2017 2018

Activities List 92 activities 112 activities

PCMH CreditOnly 1 practice site must meet PCMH

requirements

50% of practice sites must meet PCMH

requirementsCEHRT Activities for ACI Bonus Points

18 35


Takeaway:• Even more options for maxing out this category!

COST CHANGES

Cost Measures

2017 2018Total Per Capita Cost Total Per Capita CostMedicare Spending per Beneficiary

Medicare Spending per Beneficiary

10 episode based care measures No episode-based care measures


Takeaway:• If no Cost score can be calculated, 10% weighting will

be shifted to Quality• Pull your 2016 Quality Resource Use Report (QRUR)

for historical practice data on Cost measures

Cost Measures Explained


Total Per Capita Cost• All Medicare Part A and Part B costs during the performance

period• Two-step attribution process• 20 patient case minimum for measure scoreMedicare Spending Per Beneficiary

• Medicare costs associated with a hospitalization (immediately prior, during, and immediately after)

• Only for clinicians who see patient in the hospital• Episode attributed to clinician who provided plurality of Part B

services during the admission• 35 patient case minimum for measure score

Q AND A

Value Driven.Health Care. Solutions.Value Driven. Health Care. Solutions.

About Medical Advantage Group»Health care consulting company»20 years of experience helping

practices succeed in value-based contracts

»Transformed more than 1,000 primary care practices in Michigan and Ohio

»Key partner in building one of the largest PCMH networks in the U.S.

»Key partner in the Great Lakes Practice Transformation Network, helping Ohio practices prepare for MACRA

Value Driven. Health Care. Solutions.

Thank You!Beth Hickerson

[email protected]

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