Advanced Alternative Payment Models Advanced APM participants are eligible for 5% bonus payment. But, only some APMs are risk-bearing Medicare payment models that qualify for this bonus payment. Next Generation ACO Model Medicare Shared Savings Program – Tracks 2 & 3 In new Comprehensive Primary Care Plus MACRA Final (CPC+) Rule, Comprehensive ESRD Care Model Advanced Oncology Care Model Two-Sided Risk APMs include: Arrangement (in 2018) Cardiac & CJR Episode Model (in 2018) • MACRA does not change how any particular APM rewards value . • APM participants who are not “Q ualifying Providers ” (QPs) will receive favorable scoring under MIPS . 3 0
Not Every APM Will Qualify for 5% APM Bonus Most physicians and practitioners who participate in APMs will be subject to MIPS All APM and will receive favorable scoring under the Participants MIPS clinical practice improvement activities performance category. Only providers in Advanced APMs will be deemed qualifying APM participants ( “ QPs ” ) : 1. Report APM quality measures QPs in 2. Use of Certified EHR 3. Meet Advanced APM criteria (risk-bearing Advanced or medical home model) APMs 4. Must meet APM thresholds for payment and patient volumes
Impact of MACRA on Medicare Providers Reputational Status Financial & Strategy Implications • MACRA moves Medicare Publicly available scores on payment from one size fits all quality and value that compare to a meritocracy organizations/professionals will • Market share will shift from affect: low performers to high • Health plan negotiations performers over time • Talent recruitment • Delay means disaster; exponential leaps in value will • Consumer choice be needed to catch up with those that perform better as thresholds increase over time
How can clinicians and staff prepare? "People's lives can be absolutely transformed by being nudged along a slightly altered route.“ - Dr. Ben Fletcher
Sample QRUR
Immediate Actions to Consider • Engage leadership & key clinicians • Medical home recognition a critical first step • Dominate your quality data • Analyze QRUR and other payer feedback • Review compensation models
Some clinicians think MACRA means… • Stop seeing sick, non-compliant patients • Start accepting only patients who are healthy • But successful VBP/APM leaders understand the 5-50 Rule. 5% of patients are responsible for 50% of costs.
Focus on Common Elements on the Payment Innovation Journey Culture of Continuous Quality Improvement & Team Based Care Patient Attribution & Empanelment Performance Measurement, Data Analysis and Identification of Gaps in Care Identification of Higher Risk, High Cost Patients & Targeted Care Management Care Coordination across the Medical Neighborhood Patient Engagement & Experience of Care
Kentucky REC & the Great Lakes PTN CMS established the Transforming Clinical Practices Initiative (TCPI) to help clinicians achieve large-scale health transformations through collaborative and peer-based learning networks • Great Lakes PTN is one of 29 Practice Transformation Networks (PTNs) • GLPTN works with 10 Support and Alignment Networks (SANs) GLPTN State Level Leadership: • Indiana University (primary grant recipient) • University of Kentucky (Kentucky) • Purdue Healthcare Advisors (Indiana) • Northwestern University (Illinois) • Altarum Institute (Michigan)
Thank you! Questions?
Getting Ready for 2016 Reporting: Tips and Tricks for PQRS Healthcare Transformation Regional Roadshows Date here
Tip 1: List of Eligible Providers (EPs)
Tip 2: Reporting Methods Individual Reporting Methods: Claims Qualified PQRS Registry EHR Direct using certified EHR Technology (CEHRT)* CEHRT via Data Submission Vendor (DSV) Qualified Clinical Data Registry (QCDR) Group Reporting Methods: Qualified PQRS Registry Web Interface (for groups of 25 or more) EHR Direct using certified EHR Technology (CEHRT)* CEHRT via Data Submission Vendor (DSV) CAHPS for PQRS via CMS-certified survey vendor (for group practices of 2+) * Requires obtaining a CMS Enterprise Identity Management (EIDM) account formerly known as the IACS account
Tip 3: Reporting Criteria Required to submit 9 measures over 3 domains and one cross cutting measure Cross-cutting measures are defined as measures that are broadly applicable There are 6 National Quality Strategy Domains Satisfactorily reporting measures requires that the measure performance percentage must be greater than 0%
Tip 4: Reporting Timeframe Claims – report through out the program year, note cannot re-submit claim just to add PQRS modifiers Qualified PQRS Registry – selected registry will have from Jan.1,2017 through Mar. 31, 2017 to submit on behalf of the EP EHR Direct using certified EHR Technology (CEHRT) – EPs will be able to submit appropriate data files through the CMS portal from Jan.1, 2017 through Feb. 28, 2017 CEHRT via Data Submission Vendor (DSV) – Vendor can start submitting data on behalf of EPs from Jan. 1, 2017 through Feb. 28, 2017 Qualified Clinical Data Registry (QCDR) – selected QCDR will have from Jan.1,2017 through Mar. 31, 2017 to submit on behalf of the EP
Trick 1: PQRS Measure Selection Considerations Step 1: Review reporting year Measures list on PQRS website Step 2: Consider Important Factors Clinical conditions usually treated Types of care typically provided – e.g., preventive, chronic, acute. Other quality reporting programs in use or being considered – e.g. Value-Based Modifier Program, upcoming Quality Payment Program Step 3: Review Measure Specifications After making a selection of potential measures, review the specifications for the selected reporting mechanism for each measure under consideration. Select those measures that apply to services most frequently provided to Medicare patients by the EP or PQRS group practice.
Trick 2: Leverage all Available Information Download PQRS feedback reports from previous years to see past performance to identify improvement trends Obtain annual Quality Resource User Reports (QRURs) to review quality previous quality scores * * Requires obtaining a CMS Enterprise Identity Management (EIDM) account formerly known as the IACS account
Trick 3: Obtain EIDM Account Early Registration for an account is online using the CMS portal Individual requesting access will be required to enter their Social Security Number and Date of Birth for verification
Trick 4: Importance of Focusing on PQRS 2016 the last performance year for PQRS as you know it Starting performance year 2017 PQRS measures will be used to calculate 60% of the Merit-Incentive Payment System (MIPS) performance score proposed under the Medicare Access and CHIP Reauthorization Act (MACRA)
QUESTIONS?
Tips & Tricks for MU Lynn Grigsby Tiller, MBA, MSIS Project Manager, Kentucky REC
Meaningful Use Tips & Tricks 2016 Meaningful Use is Still Here Meaningful Use Measure Summary CQMS Requirements for 2016 Incentives and Payment Adjustments
Meaningful Use is Still Here Meaningful Use – Medicare versus Medicaid • Continue to attest – 2016 LAST year for the Medicare EHR Incentive Program • MACRA Implements, Sunsets and Incorporates Medicare MU Program for EPs • No changes yet to Medicaid MU requirements for both EPS and EHs • Continue on 2016 path monitoring regulations • Since Medicaid MU program continues to 2021, dual reporting will be required under current regulations
Breaking News: OPP Final Rule • Aligns MU & Advancing Care Aligns information objectives Reporting • 2016 reporting period: 90 days Period • 2017 reporting period: 90 days Objective • Removes CPOE Changes • Removes CDS Rules
Important Deadlines for 2016 Last Y ear to Enroll in Medicaid EHR Incentive Program • 2016 is last year for EPs to enroll in the Medicaid EHR Incentive Program • Feb 28, 2017 – Last day to register for 2016 Medicaid EHR Incentive Program Attestation Deadlines *Medicare – February 28, 2017 *Medicaid – March 31, 2017 Public Health • 60 days from start of reporting period • Last reporting period will be Oct 3 – Dec 31 • PH addendums must be signed by Dec 1 • Electronic Lab Reporting – If missed Oct 1 deadline – contact KHIE Clinical Quality Measures – Reporting Mechanism • Dual eligible providers in danger of PQRS – VM Penalty – determine reporting mechanism ASAP
Stage 2 Objectives 2016 - 2017 Objective Measure • Protect Patient Health Information Security Risk Analysis* • Clinical Decision Support 5 CDS Rules tied to 4 CQMS • Computerized order entry >60 % Medication Orders • >30 % Lab Orders • >30 % Radiology Orders • Electronic Prescribing >60% ePrescribing* • Health Information Exchange >10 % Exchange information with other physicians* • Patient Education >10 % Patient-Specific Education** • Medication Reconciliation >50% Patient Transitioned into EPs care has medication reconciliation performed • Patient Electronic Access >50% Patient Access* • 2016: 1 patient 2017: >5% View, Download and Transmit (VDT)** • Secure Electronic Messaging 2016: 1 patient 2017: >5 % Secure Messaging** • Public Health Reporting Immunization registry reporting** (& Bonus) • Syndromic surveillance reporting (Bonus) • Specialized registry *ACI Base Score ** ACI Performance Score
Stage 3 Objectives • All participants in Medicaid MU will attest to Stage 3 beginning in 2018 Exception: Medicaid providers in their first year of demonstrating meaningful use report on 90 days • All providers must use EHR technology certified to 2015 Edition for a full calendar year for 2018 EHR reporting period • Providers choosing option to attest to Stage 3 in 2017 MUST have 2015 CEHRT
2016 CQM Reporting Options: • Submit though Medicare attestation Medicare • Submit through PQRS Portal Quality • Submit individual through PQRS Portal • Submit group through PQRS Portal Programs • Report group through ACO Medicaid • Submit through Medicaid attestation
CQM Requirements for 2016 Dual EH & CAHs • Option 1: Attest to 16 of 29 possible CQMs through the EHR Registration & Attestation System • Option 2: eReport 4 CQMs through Hospital Inpatient Quality Reporting (IQR) through QualityNet Secure Portal • Note: The CQM reporting options for EPs and hospitals in 2016 are the same as the options that were available in 2015. Medicaid-only hospitals report their CQMs via their state's portal. • For more information on the 2016 program requirements and clinical quality measures, visit the 2015 CQM Reporting Options page on the CMS EHR Incentive Programs website.
Medicare EHR Incentives Payment First Payment First Payment First Payment First Payment Amount 2011 2012 2013 2014 $18,000 2011 $12,000 $18,000 2012 $7,840 $11,760 $14,700 2013 Reduction ($160) Reduction ($240) Reduction ($300) $3,920 $7,840 $11,760 $11,760 2014 Reduction ($80) Reduction ($160) Reduction ($240) Reduction ($240) $1,960 $3,920 $7,840 $7,840 2015 Reduction ($40) Reduction ($80) Reduction ($160) Reduction ($160) $1,960 $3,920 $3,920 2016 Reduction ($40) Reduction ($80) Reduction ($80) Total $43,720 $43,720 $38,220 $23,520 Incentive Payments
Medicaid EHR Incentives
2018 Payment Adjustments Based on 2016 Eps Participation Medicare EHR Incentive Program – 3% penalty based on participation in 2016 PQRS – 2% penalty based on participation in 2016 Value Based Payment Modifier (VM) Mandatory quality-tiering for PQRS reporters • Groups 2-9 EPs and solo physicians will see +/-2% adjustment based on quality-tiering • Groups with 10+ EPs will see +/-4% adjustment • Non-PQRS reporters will see automatic 2% penalty unless in group of 10+ and they will see 4% penalty
2018 Payment Adjustments Based on 2016 participation – EH/CAH
2016 – Prepare for MIPS • Attest to Meaningful Use (MU) • Submit Physician Quality Reporting System (PQRS) • Review and Understand your Quality Resource and Use Reports (QRURs) • Understand Implications of non-participation in CMS’ Quality Programs on your PRACTICE REVENUE
Thank you! Questions?
Kentucky Medicaid EHR Incentive Program You can find more information about the Kentucky Medicaid EHR Incentive Program at http://chfs.ky.gov/dms/ehr.htm For all other EHR questions, please send a note to the CHFS DMS EHR Incentive Program Mailbox
CMS Help Desks EHR Information Center Help Desk • (888) 734-6433 / TTY (888) 734-6563 • Hours:Monday-Friday 8:30 a.m. – 4:30 p.m. in all time zones (Except Federal holidays) NPPES Help Desk • Visit https://nppes.cms.hhs.gov/NPPES/Welcome.do • (800) 465-3203 - TTY (800) 692-2326 PECOS Help Desk • Visit https://pecos.cms.hhs.gov/ • (866)484-8049 / TTY (866)523-4759 Identification & Access Management System (I&A) Help Desk • PECOS External User Services (EUS) Help Desk Phone: 1-866-484-8049 • TTY 1-866-523-4759 • E-mail: EUSSupport@cgi.com Additional information available on new 2015 Program Requirements page: https://www .cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/indextml
Connect with Kentucky REC! Follow us on Twitter: @KentuckyREC Like us on Facebook: facebook.com/EHRResource Follow us on LinkedIn: linkedin.com/company/kentucky-rec Check out our website: www.kentuckyrec.com Contact us by Phone: 859-323-3090
LUNCH & PANEL DISCUSSION Optimizing Your Practice for MU, PQRS, and MACRA Success Facilitator: Polly Mullins-Bentley Panelists: Lynn Grigsby-Tiller: Kentucky REC Margie Banse: QSource Carla Cooper: Kentucky DMS Jennifer NeSmith: Kentucky Health Center Control Network
HIPAA Scan Brent McKune, CHPS, CPHIMS Project Manager, Kentucky REC
Agenda • Why a Security Risk Analysis should be conducted and/or reviewed on an annual basis • Review the National Institute of Standards and Technology (NIST) and OCR’s recommended steps to conducting a thorough Security Risk Analysis • Best practices and tactics to reduce breaches in your organization
Definitions • Business Associates (BA) - A person or entity, other than a member of the workforce of a covered entity, who performs functions or activities on behalf of, or provides certain services to, a covered entity that involve access by the business associate to protected health information. • Business Associates Agreement (BAA) - A covered entity’s contract or other written arrangement with its business associate must contain that describes the permitted and required uses of protected health information by the business associate. • Code of Federal Regulations (CFR) - The codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the federal government of the United States. • Covered Entity (CE) - Defined in the HIPAA rules as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with transactions for which HHS has adopted standards. • Electronic- Protected Health Information (e-PHI) - Any protected health information (PHI) that is covered under Health Insurance Portability and Accountability Act of 1996 (HIPAA) security regulations and is produced, saved, transferred or received in an electronic form. • Health Insurance Portability and Accountability Act (HIPAA) - is the federal Health Insurance Portability and Accountability Act of 1996. The primary goal of the law is to make it easier for people to keep health insurance, protect the confidentiality and security of healthcare information and help the healthcare industry control administrative costs. • National Institute of Standards and Technology (NIST) - a federal technology agency that works with industry to develop and apply technology, measurements, and standards
Definitions • Security Rule - The HIPAA Security Rule establishes national standards to protect individuals’ electronic personal health information that is created, received, used, or maintained by a covered entity. The Security Rule requires appropriate administrative, physical and technical safeguards to ensure the confidentiality, integrity, and security of electronic protected health information. • Security Risk Analysis (SRA) – the process of identifying the risks to system security and determining the likelihood of occurrence, the resulting impact, and the additional safeguards that mitigate this impact. • Privacy Rule - The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients’ rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections. • Protected Health Information (PHI) - Any information about health status, provision of health care, or payment for health care that can be linked to a
Evolution of HIPAA 1996 HIPAA was enacted 2003 2005 Privacy Rule Security Rule 2009 2013 HITECH Omnibus
Security Risk Analysis Overview
Reasons to Complete a Security Risk Analysis HIPAA Security Rule
Performing a Security Risk Analysis How often should I conduct a security risk analysis?
Security Risk Analysis Beneficiaries Covered Patients Entities Business Associates
Security Risk Analysis Steps The National Institute of Standards and Technology (NIST) recommends a 9 step methodology approach to conducting a security risk assessment
Risk Analysis Steps Step 1: System Characterization Step 2: Threat Identification Step 3: Vulnerability Identification Step 4: Control Analysis Step 5: Likelihood Determination Step 6: Impact Analysis Step 7: Risk Determination Step 8: Control Recommendations Step 9: Results Documentation
What does compliance look like? Is compliance one size fits all?
Approaches for Conducting a Security Risk Analysis
Mitigating Risks Should I mitigate all risks?
OCR Settlement Highlights • Cancer Care Group ($750,000 settlement, August 31, 2015) – OCR found widespread non-compliance, and lack of policies, after laptop bag with unencrypted media exposed records of 55,000 patients • Feinstein Institute for Medical Research (research institute organized as NY non-profit corporation ($3.9M settlement and substantial corrective action plan, March 17, 2016) – Laptop computer with ePHI of approx.13K patients stolen from employee’s car • Raleigh Orthopedic – ($750,000 settlement, April 14, 2016) – For providing PHI for 17,300 patients to potential business partner without first executing a BAA • St. Joseph Health – ($2,140,500 settlement, October 17, 2016) – Unrestricted access to PDF files containing ePHI of 31,800 individuals
Audits and Preparation
Kentucky REC Can Help! • Kentucky REC offers the following services performed by AHIMA Certified HIPAA Privacy & Security professionals: – Security Risk Analysis addressing HITECH requirements for Meaningful Use – Review of Administrative, Technical & Physical safeguards – Remediation plan and timeline to eliminate or mitigate identified gaps – HIPAA compliant sample policies – Breach Notification
Thank you! Questions?
Getting Ready for Practice Transformation Robin Huffman Kentucky Regional Extension Center
How will MIPS measure performance? Providers will receive a MIPS final score based on 4 weighted performance categories: Advancing Improvement Cost Quality MIPS Care activities Final Information Score 0-100 CY19 60% 0% 15% 25% CY20 50% 10% 15% 25% CY21 30% 30% 15% 25%
Improvement Activities Expanded Practice Access Population Management Care Coordination Beneficiary Engagement Patient Safety and Practice Assessment PCMH/PCSP Certification = Participation in an APM, Full Points for Category including a medical home model Achieving Health Equity Emergency Preparedness and Response Integrated Behavioral and Mental Health
“The Gold Standard” for Primary Care Transformation
A journey of a thousand miles begins with a single step… Payment Innovation Care Delivery Innovation Meaningful Use (PCMH) Health IT & HIE + Quality Improvement
PCMH: A Roadmap PCMH is a model that provides specific standards for transforming the organization and delivery of primary care to be more: Comprehensive Patient-Centered Coordinated Accessible Safe
Patient-Centered Medical Neighborhood
Patient-Centered Specialty Practice • An innovative program for improving specialty care. • Organizes care around patients • Promotes team based care • Coordinating and tracking care over time with primary care and other specialists • Improve quality • Reduce redundancies and negative patient experiences • Proactive coordination • Patient centered • Encourages the use of health information technology • Meaningful Use Alignment
Benefits of a PCMH • Long-term partnerships, not hurried visits • Care that is coordinated among providers • Better access • Shared decision-making with patients • Reduced cost of care • Decreased ER visits, hospitalizations • More satisfied providers and patients
Benefits of PCSP • Effective care coordination • Greater efficiency • Improved patient safety • Readiness for a delivery/reimbursement model that focuses on outcomes and reduced duplication of services. • Promoting a practice’s suitability for newly proposed physician delivery and payment models.
PCMH Recognition For outpatient primary care Practice-site level Recognizes PCPs at the site, including NPs and PAs who can be designated as a personal clinician 3-year Recognition period Practice may add/remove clinicians
Who is eligible for PCMH Recognition? • Recognized Practices: • Internal Medicine • Family Medicine • Pediatrics • Recognized Providers: • Physicians (MD or DO) • APRNs • PAs
PCSP Recognition Practice-based evaluation for clinicians who provide care in non- primary care specialties Recognizes eligible specialty clinicians at the practice NCQA defines a practice as one or more clinicians who practice together and provide patient care at a single geographic location. 3-year Recognition period Practice may add/remove clinicians
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