Industry Webinar - QPP Year 2 (2018) YOUR HOST MICHELLE BOWES - - PowerPoint PPT Presentation

Industry Webinar - QPP Year 2 (2018)

YOUR HOST

MICHELLE BOWES

Michelle has more than 20 years of hands on work experience in hospitals, clinics, imaging centers, medical consulting firms and billing companies, both

• n the clinical and the administrative spectrums.

She’s a trusted colleague of the Colorado State Office of Rural Health and helped anchor one of the most successful REC programs in the nation from 2010-2015. Michelle has assisted with several hundred Eligible Provider and nearly 100 Hospital/CAH MU attestations over the years. The deviation from the EHR Incentive Program to Quality Payment Program has forced everyone to shift gears, and naturally Michelle has embraced the challenge of establishing herself as an expert in the new era of Value Based Reimbursement. Michelle joined the Azalea Health team in 2015 as the CMS Regulatory Program Compliance Team Lead Consultant. She works closely with development to support the 2015 ONC Certification and red tape requirements, as well as with clients to provide expertise, insight and support.

AGENDA

• Welcome & Overview
• Where we are today
• A bit more on APMs
• 2017 reweighting & submissions
• 2018 QPP
• Q&A

WHERE WE ARE TODAY

WHERE WE ARE TODAY

2017 QPP Performance Year SUBMISSIONS ARE DUE BY 3/31/2018 ...but it is not too late to start! MIPS:

• The minimum submission is literally something (aka a “TEST” which is a minimum of a

single CQM, for a single patient, on a single day, via a claim) to avoid the negative payment adjustment

• Decide whether you’ll submit as a group (under a single TIN) or by individual Eligible

Clinician ○ Understand the ACI transitive effect of group reporting if manually aggregating your own data ○ Maximize your incentive - submit 90+ days of data from each category with a composite score of at least 70 MIPS points = Exceptional Performance

• Document your Practice Improvement Activities (PI)

Alternative Payment Model (APM):

• Clarify the APM you’re working with is a “MIPS” APM or “Advanced” APM - there are

major differences between the two!

• Clarify what the MIPS APM is submitting on your behalf - all categories or just Quality?

Don’t make assumptions!

A BIT MORE ON APMs

A BIT MORE ON APMs...

RCM / Billing Sales & Marketing Development

CMS is pushing HARD toward Advanced APM participation. CMS predicts that 100,000 Part B clinicians will participate in Advanced APMs in 2017. They’re estimating 185,000-250,000 qualifying participants (QPs) in Performance Year 2018 - almost double!

• Earn an annual 5% Part B incentive (paid 2019 - 2024) and are exempt from MIPS.

○ Bonus is only on services (unlike MIPS which is bonused on services and items) billed to Medicare Part B

• In 2026, Advanced APM qualifying participants (QPs) will accrue a higher annual Part B physician fee

schedule (PFS) increase of 0.75%, rather than 0.25%.

• QP status is determined by three performance year-to-date snapshots for Part B claims filed in the periods

ending on March 31, June 30 and August 31.

• Participants, in turn, must receive a certain percentage of their Medicare Part B payments or see a certain

percentage of patients through an Advanced APM.

2017 REWEIGHTING & SUBMISSIONS

2017 ACI HARDSHIP REWEIGHTING

RCM / Billing Sales & Marketing Development

2017 ACI Reweighting Application - deadline for submission is 3/31/2018 Special Status Clinicians There are some MIPS-eligible clinicians that are considered Special Status, who will be automatically reweighted (or exempted in the case of MIPS-eligible clinicians participating in a MIPS APM) and do not need to submit a Quality Payment Program Hardship Exception Application.

• Hospital-based MIPS-eligible clinicians (75% of hospital POS 21,22 or 23)
• Physician Assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Non-patient facing clinicians
• Ambulatory Surgical Center (ASC) Based MIPS-Eligible Clinicians (approved in QPP 2018 Final

Rule to start in 2017 Transition period)

• Non-patient facing

**Just because you fall into this category, that does NOT mean you cannot still submit your ACI. If you choose to do so, your ACI score will be counted normally at 25%.

2017 MIPS SUBMISSIONS

RCM / Billing Sales & Marketing

EXACTLY HOW DO YOU SUBMIT TO QPP FOR MIPS? Let me count the ways. 1. Electronically via your EHR’s API to CMS. 2. Electronically via a Registry or Qualify Clinical Data Registry (QCDR). 3. Via Claims. 4. Manual attestation through QualityNet.

2017 MIPS

MANUAL SUBMISSION CLAIMS REGISTRY / QCDR EHR

Each category may be submitted separately and through different submission methods. However, each item within a category must be submitted through the same method.

2017 MIPS MANUAL SUBMISSIONS

RCM / Billing

MANUAL SUBMISSIONS ARE MOVING FROM THE CMS R&A WEBSITE TO QPP. QPP Requires Enterprise Identity Management (EIDM) Accounts If your individual eligible clinicians and/or group plans to manually attest for MIPS, you will need an EIDM account to sign into the Quality Payment Program portal. QPP is open to receive attestations now!

• If you have an EIDM Account - You’ll need your EIDM credentials and you must have an appropriate user role

associated with your organization to sign into QPP.

• If you do NOT have an EIDM Account - Create an account on the CMS Enterprise Portal.

EIDM Account & User Role Guide More EIDM References, Education and Videos

2017 QPP SUBMISSION DEADLINE - MARCH 31, 2018

2018 QPP

2018 QPP - BIGGER AND BETTER

2018 is an opportunity for further involvement and improvement! 2018 QPP

Think strategy. Focus on improvement. Maximize participation.

2017 QPP

Learning the program. Learning appropriate documentation. Learning how to submit.

MORE MONEY! Up to 5% in Payment Year 2020

2018 QPP - EFFECT ON 2017

EFFECT ON QPP 2017 Exclusions added: Low volume exclusions for the HIE and eRX objectives were added for the 2017 QPP. If your EC

• r group had less than 100 transitions of care out or less than 100 ePrescriptions ordered, during your reporting

period, you may claim an exclusion in 2017. ACI Automatic reweighting: For ECs in an ambulatory surgery center (ASC), the ACI category will automatically be reweighted to 0% in 2017 QPP (FINALIZED TO BEGIN AT THE BEGINNING OF THE TRANSITION YEAR)

2018 QPP - THE CHANGES

THE BASICS PENALTIES + INCENTIVES | MIPS max penalty and incentive is 5%. Translation – an EC or group may be penalized or bonused anywhere from -5% to +5% of their Medicare Part B reimbursement in 2020, depending on what level they participate in QPP in 2018. CATEGORIES | 2018 MIPS category weights are Quality: 50%, ACI: 25%, IA: 25%, Cost: 10%. Translation – Each category’s weight contributes to the overall MIPS Score. New for 2018 is Cost. VOLUME | 2018 MIPS low-volume thresholds are ≤ $90,000 Medicare Part B allowed charges or ≤ 200 Medicare Part B beneficiaries. Translation – Check your Medicare Part B volumes and eligibility on the QPP Website beginning in 2018. If your EC NPI reflects “not eligible” in either the individual or group categories, your EC and/or group may be exempt from participation in the 2018 QPP.

2018 QPP - THE CHANGES

THE BASICS SIZE | Relief for small practices (1 to 15 clinicians). Translation – If you don’t meet low volume thresholds, you still get special treatment since you’re small! Bonus points added to final scores, lower PI requirements, the ability to join Virtual Groups, hardship exemptions for ACI and credit for quality measures submitted below data completeness standards. POINTS | MIPS Performance threshold increased from 3 to 15. Translation – an EC or group must submit enough data to earn them 15 points in order to avoid a negative payment adjustment. CQMs still have a 3 point floor. COMPLEXITY | Bonuses for complex patients. Translation - Up to 5 bonus points available to recognize clinicians who treat complex patient populations, based on a combination of Hierarchical Condition Categories (HCCs) and the dual eligible population treated.

2018 QPP - THE CHANGES

THE BASICS DATA | Data completeness threshold increases to 60%. Translation – For the Quality category, ECs/groups must submit data on at least 60% of applicable Medicare Part B patients seen during the performance period for which that measure applies. TECHNOLOGY | May use either 2014 or 2015 CEHRT, or a combination of both. Translation – EHR and other technology vendors must certify with the ONC that they meet certain standards. Most vendors are currently certified to 2014 CEHRT and are working or have achieved the 2015 certification. In 2018, you may use either CEHRT or combination of both. CMS is offering a 10% scoring bonus for those ECs/groups reporting using only 2015 CEHRT. APMS | Fewer MIPS ECs expected to participate in 2018. APMs are expanding to all-payer models starting in 2019. Translation – CMS is pushing ECs/groups to participate in MIPS APMs and Advanced APMs. IMPROVEMENT SCORING | Measure improvements from 2017 to 2018 in Quality and Cost categories. Translation – For Quality, improvements in the category as a whole will result in up to 10% bonus of the Quality score. For Cost, improvement analysis occurs at the measure level for an earning potential of up to 1% bonus in the Cost category.

2018 QPP - THE CHANGES

THE BASICS IMPROVEMENT SCORING | Measure improvements from 2017 to 2018 in Quality and Cost categories. Translation – For Quality, improvements in the category as a whole will result in up to 10% bonus of the Quality score. For Cost, improvement analysis occurs at the measure level for an earning potential of up to 1% bonus in the Cost category.

2018 QPP - WHAT’S NEW

WHAT’S NEW VIRTUAL GROUPS | Solo and small groups (with 10 or fewer ECs) have the option of teaming up to form a virtual group starting in 2018. That virtual group, comprised of at least 2 TINS, would then aggregate all the participants data to submit to MIPS as a single entity. Who can participate? · The following solo practitioners who exceed the low-volume threshold and who is not a newly enrolled Medicare clinician, a QP, or a Partial QP · Physicians · Physician assistants · Nurse practitioners · Clinical nurse specialists · Certified registered nurse anesthetists · A Group that includes these clinicians who exceed the low-volume threshold as a group. Utilize the Virtual Group Toolkit to get started.

2018 QPP - WHAT’S NEW

WHAT’S NEW IMPROVEMENT SCORING | New in 2018, bonus percentage points will be available to those ECs/groups who demonstrate an improvement in their Quality and Cost categories. ACI CATEGORY REWEIGHTING & EXCEPTIONS | Automatic reweighting for the following clinicians: · Hospital-based ECs (revised to include ECs in POS 19) · Ambulatory Surgical Center (ASC)-based ECs (retroactive to 2017 QPP) · NPs, PAs, CNSs, CRNAs Reweighting through approved application: · New hardship exception for clinicians in small practices of 15 or fewer clinicians · New decertification exception of ECs whose EHR was decertified, retroactive to 2017 QPP · Significant hardship exceptions – 5 year limit applied to these Deadline: Applications are typically due on December 31 of the Performance Year (for 2017, due on 3/31/2018)

2018 QPP - WHAT’S NEW

WHAT’S NEW THE COST CATEGORY | In 2018 QPP, the Cost category will bear a weight of 10% of the total MIPS Score. Furthermore, this increases to a whopping 30% in 2019 QPP. (Yet another push toward APM participation.) Cost is measured on the Medicare Spending per Beneficiary (MSPB) and total per capita cost measures…..but what exactly does this mean? First of all, it means there is no data submission required for this category.

“The MSPB measure assesses Medicare Part A and B costs incurred during an episode. An episode includes the dates falling between three days prior to an Inpatient Prospective Payment System (IPPS) hospital admission (referred to as an index admission) and 30 days post-hospital discharge. The MSPB measure evaluates the observed cost of episodes compared to their expected costs. For the MSPB measure:

• Clinicians who do not see patients in the hospital will not be attributed to any episodes and not scored on the measure.
• Clinicians must be attributed to at least 35 cases to be scored on this measure.
• Episodes will be attributed to the clinician who provided the plurality of Medicare Part B services to a beneficiary during an index admission.

The total per capita cost measure assesses all Medicare Part A and B costs for each attributed beneficiary. For the total per capita cost measure:

• Clinicians must be attributed to at least 20 unique beneficiaries to be scored on this measure.
• Attribution uses a two-step process:

1) A beneficiary is attributed to a tax identification number (TIN) if the beneficiary received more primary care services from primary care physicians, nurse practitioners, physician assistants, clinical nurse specialists within that TIN than from clinicians in any other TIN. 2) If a beneficiary cannot be attributed to a TIN using the first step, the beneficiary will be attributed to a TIN if they received more primary care services from specialist physicians within a TIN than from clinicians in any other TIN.” (Source: AAFP)

CONCLUSION

Q&A

Michelle Bowes CMS Regulatory Compliance Team Lead Consultant E | mbowes@azaleahealth.com P | 402.770.9875

LETS CONNECT

www.linkedin.com/company/azalea-health/ @AzaleaHealth www.facebook.com/azaleahealth/

Stay Up to Date: AzaleaHealth.com/newsletter-signup