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Scott Hughes, DPM, ASPS, ACFAS

Webinar Topic Date

2018 Improvement Activities Performance Category June 19, 2018

2018 MIPS Overview May 23, 2018

2018 MIPS Quality Category May 2, 2018

2018 MIPS Cost Performance Category April 25, 2018

How to Avoid a 2020 Penalty for 2018 MIPS Reporting February 12, 2018

MIPS Year 2 Final Rule November 30, 2017

Registry Reporting October 30, 2017

MACRA Made Easy Webinar Series on MIPS Year 2

All past webinars and materials are posted online:

www.apma.org/MACRAWebinars

SENATE VOTE IN FAVOR OF

MACRA

92-8

HOUSE VOTE IN FAVOR OF

MACRA

392-37

Highest total of 100

EPs will receive either a positive or negative

payment adjustment to Medicare part B fee

schedule based on MIPS score

MIPS Score

2019: -4% to +4% (based on 2017 score)

2020: -5% to +5% (based on 2018 score)

2021: -7% to +7% (based on 2019 score)

2022 : -9% to +9% (based on 2020 score)

MIPS Adjustments

0 MIPS points = -4%

3 MIPS points = Neutral

15 MIPS points = +0.05%

40 MIPS points = +0.16%

94 MIPS points = +1.9%

100 MIPS points = +2.02%

2017 MIPS Points And Adjustments

Fact Sheet: 2019 Merit-based Incentive Payment System (MIPS) Payment Adjustments based on 2017 MIPS Final Scores : https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-MIPS-Payment-Adjustment-fact-sheet.pdf

2017 Results

2018 Final Rule

Threshold to avoid a penalty moves

from 3 MIPS points to 15 MIPS points

Mostly budget neutral

Penalty no more than 5%

Most positive adjustments no more than 5%

…positive moved based on budget neutrality

“Exceptional Performance” (70)

MIPS 2018

Physician Compare

https://www.medicare.gov/physiciancompare/#

Yelp ?

Employers ?

Private Insurance Carriers ?

Scores Will Be Publically Reported

2018 Final Rule

Exclusion Criteria

Less than or equal to $90K in Medicare

Part B allowable

OR

Less than or equal to 200 Medicare Part B

beneficiaries

https://qpp.cms.gov/participation-

lookup

https://qpp.cms.gov/participation-

lookup

Other Exclusions Still Exist

Newly Medicare-enrolled eligible

clinicians

Qualifying APM Participants (QPs)

Certain Partial Qualifying APM

Participants (Partial QPs)

Clinicians affected by Harvey,

Irma, Maria can file a hardship

exemption for 2018 reporting

period for Quality, ACI, and CPIA

2018 Final Rule

https://cmsqualitysupport.service-

now.com/exception_application.do

2018 Final Rule Category Weights

Quality – 50%

PI (ACI) – 25%

CPIA – 15%

Cost – 10%

Quality 50%

PI (ACI) 25%

Clinical PracticeImprovement Activities15%

Cost 10%

MIPS Score Performance Year 2018

If practice has greater than 15 eligible clinicians

2018 Final Rule Option

PI (ACI) exception for practices

with 15 or fewer clinicians!!

Re-weights Quality to 75%

Quality – 75%

PI (ACI) – Exception!

CPIA – 15%

Cost – 10%

2018 Final Rule Category Weights With PI Exception

Quality 75%

PI (ACI) 0%

Clinical PracticeImprovement Activities15%

Cost 10%

MIPS Score Performance Year 2018*

* With PI Exception

5 MIPS points added to final score of any EP or group who is in a small practice (15 or fewer clinicians)

EP or group must submit data on at least 1 performance category.

New Small Practice Bonus for 2018

Quality – 50% or 75%

Report 6 Quality measures

One must be an outcome measure

If outcome measure not available, must report on at

least one high priority measure

All 6 must be reported by the same mechanism

MIPS Quality (50% or 75%)

Claims

60% or more of Medicare Part B patients

Registry

60% or more of all patients

EHR

60% or more of all patients

CMS Web Interface (groups of 25+)

ALL SIX MUST BE SUBMITTED BY SAME MECHANISM

2018 Quality Measures Submission Methods

QPP.CMS.GOV

QPP.CMS.GOVQPP.CMS.GOV

QPP.CMS.GOVQPP.CMS.GOV

Claims

Registry

EHR

CMS Web Interface (groups of 25+)

ALL SIX MUST BE SUBMITTED BY SAME MECHANISM

Quality Measures Submission Methods

1. Documentation of Current Meds in the Medical Record

2. Diabetes: Hemoglobin A1c (HbA1c) Poor Control -Intermediate Outcome

3. Pain Assessment and Follow-Up

4. Pneumococcal Vaccination Status for Older Adults

5. BMI Screening and Follow Up Plan

6. Influenza Immunization

7. Screening for High Blood Pressure and Follow Up

8. Tobacco Screening and Cessation Intervention

9. Falls Risk Assessment

10. Falls Plan of Care

QUALITY MEASURES

Claims Reporting

1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control - Intermediate Outcome

2. Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam

3. Diabetic Foot and Ankle Care, Ulcer Prevention –Examination of Footwear

4. Documentation of Current Meds in the Medical Record

5. Immunizations for Adolescents

QUALITY MEASURES

Registry Reporting

7. Pain Assessment and Follow-Up

8. Pneumococcal Vaccination Status for Older Adults

9. Preventive Care & Screening: Body Mass Index (BMI) Screening & Follow-Up Plan

10. Preventive Care and Screening: Influenza Immunization

11. Screening for High Blood Pressure and Follow Up

12. Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention

13. Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling

14. Falls Risk Assessment

15. Falls Plan of Care

\

QUALITY MEASURES

Registry Reporting cont.

APMA.ORG/MIPS2018

Denominator – 18 or older, E&M

Claims - Documentation of Current Medications in the Medical Record

Numerator –

Performance Met: G8427 - Eligible clinician attests

to documenting in the medical record they

obtained, updated, or reviewed the patient’s

current medications

Performance Not Met: G8428 - Current list of medications

not documented as obtained, updated, or reviewed by

the eligible clinician, reason not given

Claims - Documentation of Current Medications in the Medical Record

Promoting Interoperability

(Advancing Care Information) (25%)

50% credit just for reporting

Other 50% depends on performance

No more clinical decision support rule

No more CPOE (Computerized Provider Order

Entry)

Promoting Interoperability (25%)

QPP.CMS.GOVQPP.CMS.GOV

Two Reporting Options

2014 CEHRT Only

4 required base

measures

7 additional optional

performance measures

2015 CEHRT Only

OR

2014 + 2015 CEHRT

5 required base measures

10 additional optional performance measures

Additional 10 bonus pointsfor using 2015 edition certified EHR exclusively

4 Required PI Measures - 2014 CEHRT Only

1. Security Risk Analysis

2. e-Prescribing

3. Provide Patient Access

4. Health Information Exchange

7 Additional Optional PI Measures

2014 CEHRT only

1. View, Download, or Transmit (VDT)

2. Patient-Specific Education

3. Secure Messaging

4. Medication Reconciliation

5. Immunization Registry Reporting

6. Specialized Registry Reporting

7. Syndromic Surveillance Reporting

1. Security Risk Analysis

2. e-Prescribing

3. Provide Patient Access

4. Send a Summary of Care

5. Request/Accept Summary Care

5 Required PI Measures – 2015 CEHRT or Combo

1. Patient Specific Education

2. View, Download or Transmit (VDT)

3. Secure Messaging

4. Patient-Generated Health Data

5. Clinical Information Reconciliation

6. Immunization Registry Reporting

7. Clinical Data Registry Reporting

8. Syndromic Surveillance Reporting

9. Electronic Case Reporting

10. Public Health Registry Reporting

10 Additional Optional PI Measures2015 CEHRT only or Combo

Clinical Practice Improvement Activities

(15%)

List of 93 options

Medium weight = 10 points

High weight = 20 points

Activities double weighted if group of 15 or less or solo

Score = points / 40

Clinical Practice Improvement Activities (15%)

Group of more than 15 clinicians:

Choose 4 medium weight or 2 high weight

activities or 1 high weight + 2 medium weight

Group of 15 or fewer clinicians or solo:

Choose 2 medium weight or 1 high weight

activity(s)

Clinical Practice Improvement Activities (15%)

QPP.CMS.GOVQPP.CMS.GOV

QPP.CMS.GOVQPP.CMS.GOV

1. Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real- Time

Access to Patient's Medical Record HIGH

2. Use of a QCDR to generate regular feedback reports that summarize local

practice patterns and treatment outcomes, including for vulnerable populations.

HIGH

3. Implementation of Use of Specialist Reports Back to Referring Clinician or Group

to Close Referral Loop MEDIUM

4. Implementation of improvements that contribute to more timely communication of

test results MEDIUM

5. Collection and follow-up on patient experience and satisfaction data on

beneficiary engagement HIGH

6. Participation in a QCDR, that promotes implementation of patient self-action

plans. MEDIUM

Clinical Practice Improvement Activities (15%)

7. Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms. MEDIUM

8. Improved Practices that Disseminate Appropriate Self-Management Materials MEDIUM

7. Annual registration in the Prescription Drug Monitoring Program MEDIUM

8. Consultation of the Prescription Drug Monitoring Program HIGH

9. Use of decision support and standardized treatment protocols MEDIUM

Clinical Practice Improvement Activities Cont. (15%)

12. Implementation of fall screening and assessment programs MEDIUM

13. CDC Training on CDC’s Guideline for Prescribing Opioids for Chronic Pain HIGH

12. Completion of CDC Training on Antibiotic Stewardship HIGH

13. Initiate CDC Training on Antibiotic Stewardship MEDIUM

14. Engagement of New Medicaid Patients and Follow-up HIGH

Clinical Practice Improvement Activities Cont. (15%)

Cost Category 10%

Cost calculated by:

Medicare Spending per Beneficiary (MSPB)

and

Total Per Capita Cost Measures (TPCC)

2018 Final Rule

Cost

Total Per Capital Cost (TPCC)

Total Cost per Beneficiary

Payment standardized

Annualized

Risk adjusted

Specialty adjusted

Medicare Spending Per Benificiary

(MSPB)

Minimum Cases

2018 Final Rule Reporting Periods

Quality: 365 days

PI (ACI): 90 days

CPIA: 90 days

Cost: 365 days

Proposed for 2019

Meet ONE of these:

o ≤ $90K in Part B allowable

o Provide care to ≤ Part B 200 beneficiaries

o Provide ≤ 200 Part B services

However, option to opt in if you only meet one or two

of those

2019 Proposed Low Volume Threshold

-7% to +7%

2021 Adjustment Based on 2019 Performance

Threshold to avoid a penalty moves from 15 to 30

Exceptional Performer threshold moves from 70 to 80

2019 Proposed Thresholds

Quality: 45% (down from 50%)

Cost: 15% (up from 10%)

Promoting Interoperability: 25% (no change)

Improvement Activities: 15% (no change)

Proposed 2019 Category Weights

If you only submit on one category

max MIPS score is 30

2019 Proposed QPP Proposed Rule

Remains 6 measures

One must be an outcome measure

If outcome measure not available, must report on at least

one high priority measure

60% of applicable patients throughout performance

year

Quality Category – 2019 Proposed

Different quality measures can be

reported via different mechanisms

Can submit a single quality measure via

multiple mechanisms – get the higher score

Quality Category – 2019 Proposed

Quality measures proposed for removal in 2019:

◼163: Comprehensive Diabetes Care: Foot Exam

◼154: Falls: Risk Assessment

◼155: Falls: Plan of Care

◼318: Falls: Screening for Future Fall Risk

(CMS proposes to replace these 3 falls measures with a new combined Falls measure)

Quality Category – 2019 Proposed

Limit claims-based reporting to

clinicians in small practices (< 15

eligible clinicians)

Quality Category – 2019 Proposed

Must use 2015 CEHRT

Elimination of base, performance, and bonus

scoring

Just numerator / denominator or Yes/No

PI Category – 2019 Proposed

CMS proposes to no longer apply a small

practice bonus to the final score, but

rather add a small practice bonus to the

quality performance category.

2019 Proposed QPP Proposed Rule

CMS estimates that 95.1 percent of

MIPS eligible clinicians will

participate in MIPS in 2019

2019 Proposed QPP Proposed Rule

COMING SOONAPMA MyMipsScore APP

An Analytic Tool to Maximize Your

MIPS Score

APMA is negotiating this as a member benefit

available to all APMA members

Analytics of the tool allow you to evaluate your

progress on MIPS Measures, maximize your

performance thus increasing your MIPS score and

therefore earn a your maximum incentive

Lets you simulate an increase in your performance

on a measure to see effect on MIPS score and

incentive payment

Additional Bonus Feature

Allows any APMA member to submit their

MIPS data to the APMA Registry even if

your EHR has not integrated with the

APMA Registry