Navigating the Merit-Based Incentive Payment System (MIPS) Maria Balderas, PhD August 10, 2016
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Polling Question 1: Q: Are you or your organization planning to use a vendor to help track your Merit-based Incentive Payment System (MIPS) measurement performance? Definitely Possibly Probably Not I Don’t Know Not Applicable (e.g., not a member of a practice)
Polling Question 2: Q: Are you or your organization planning to use a vendor to help report MIPS data to CMS? Definitely Possibly Probably Not I Don’t Know Not Applicable (e.g., not a member of a practice)
On April 27, 2016, CMS issued a Notice of Proposed Rulemaking (NPRM) to put in place key parts of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA): Quality Payment Program(QPP) MACRA replaces the flawed Sustainable Growth Rate (SGR) formula by paying clinicians for the value and quality of care they provide. Streamlines multiple quality reporting programs into the new Merit-based Incentive Payment System (MIPS) Provides incentive payments for participation in Advance Alternative Payment Models (APMs) Promotes coordinated care at reasonable costs through a uniform merit-based system. Improved quality and value of care for Medicare beneficiaries
Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Source: CMS, MACRA and Delivery System Reform NQF Conference (Goodrich, Kate 2016)
Source: CMS, MACRA and Delivery System Reform NQF Conference (Goodrich, Kate 2016)
Merit-Based Incentive Payment System (MIPS) Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015 - The Merit-Based Incentive Payment System: Quality Performance Category
MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)
Quality Payment Program Providers Have Choices Regarding Medicare Payment Under MACRA KEY FEATURES: • Repeals the Sustainable Growth Rate (SGR) Formula • Changes the way that Medicare rewards clinicians for value over volume • Streamlines multiple quality programs under the Merit-Based Incentive Payments System (MIPS) • Provides bonus payments for participation in eligible alternative payment models (APMs) Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: Path to Value
Major Provisions under MIPS* Outlines participant eligibility Performance categories & scoring Data submission Performance period & payment adjustments *Based on Proposed Rule that will be finalized in November 1, 2016. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Most clinicians will be subject to MIPS SUBJECT TO MIPS QP in ADVANCED APM • • Not part of an APM Some clinicians may be in Advanced APMs but not • In a APM, but not one of have enough payments or the CMS selected patients through the “Advanced APMs”. Advanced APM to be a QP*. • In an Advance APM, but not a QP*. *Qualified Participant (QP) Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Who does MIPS apply to?
Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015 - The Merit-Based Incentive Payment System (MIPS)
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: Path to Value
MIPS Participation: Individual Group • • Solo practitioner Defined by taxpayer identification number (TIN) • Assessed across all four MIPS performance categories Note: “Virtual groups” will not be implemented in Year 1 of MIPS. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
MIPS Performance Categories and Scoring (Based on Proposed Rule) Excellent Good Average Poor
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview
Quality Performance Category Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Quality Performance Category Selection of 6 measures 1 cross-cutting measure and 1 outcome measure, or another high priority measure if outcome is unavailable Select from individual measures or a specialty measure set Population measures automatically calculated PQRS Changes: Reduced from 9 measures to 6 measures with no domain requirement* Emphasis on outcome measurement Year 1 Weight: 50% NOTE: According to CMS, small practices (15 or less), practices located in rural areas, and non-patient facing MIPS clinicians will provide special accommodations. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Resource Use Category Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Resource Use Category Assessment under all available resource use measures, as applicable to the clinician. CMS calculates score based on claims; no reporting required . Will compare resources used to treat similar care episodes and clinical conditions groups across practices. Can be risk-adjusted to reflect external factors. Value Modifier Changes: Adding 40+ episode specific measures to address specialties Year 1 Weight: 10% NOTE: According to CMS, small practices (15 or less), practices located in rural areas, and non-patient facing MIPS clinicians will provide special accommodations. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Clinical Practice Improvement Activities Category Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Clinical Practice Improvement Activities Category Minimum selection of one CPIA activity; additional credit will be provided to those who report on more activities Select from 90+ proposed activities Full credit for patient-centered medical home (PCMH)* CPIA is a new program Year 1 Weight: 15% NOTE: According to CMS, small practices (15 or less), practices located in rural areas, and non-patient facing MIPS clinicians will provide special accommodations. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Advancing Care Information Category Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Advancing Care Information Category Scoring based on key measures of patient engagement and information exchange Flexible scoring for all measures to promote care coordination for better patient outcomes Rewarded for performance on measures that matter the most Participation can be at the individual or group practice level EHR Changes: Dropped “all or nothing” threshold for measurement Removed redundant measures to alleviate reporting burden Eliminated Clinical Provider Order Entry and Clinical Decision Support objectives Reduced the number of required public health registries to which clinicians must report. Year 1 Weight: 25% NOTE: According to CMS, small practices (15 or less), practices located in rural areas, and non-patient facing MIPS clinicians will provide special accommodations. Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Advancing Care Information Category Proposed Base score objectives Proposed Performance score objectives Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview
*MACRA allows potential 3x upward adjustment BUT unlikely Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)
Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview
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