Navigating the Merit-Based Incentive Payment System (MIPS) Maria - - PowerPoint PPT Presentation

Navigating the Merit-Based Incentive Payment System (MIPS)

Maria Balderas, PhD

August 10, 2016

Housekeeping

• 1. Using the control panel - Use the control panel on the right

side of your screen to minimize and expand this panel by clicking on the arrow in the upper right corner.

• 2. Ask Questions - You can submit questions using the

Question section located near the bottom of the control

• panel. We will take time to answer as many questions as we

can during Q&A at the end of the presentation. If your question was not answered, we will respond to you individually after the event.

• 3. After the webinar - We want your feedback! Please take

the short survey at the completion of the webinar. Also, all registrants will receive a copy of the presentation, and the recording for on-demand replay.

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)

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)

MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)

Quality Payment Program

Providers Have Choices Regarding Medicare Payment Under MACRA

• 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)

KEY FEATURES:

Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: Path to Value

Major Provisions under MIPS*

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (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.

Most clinicians will be subject to MIPS

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

SUBJECT TO MIPS QP in ADVANCED APM

• Some clinicians may be in

Advanced APMs but not have enough payments or patients through the Advanced APM to be a QP*.

• Not part of an APM
• In a APM, but not one of

the CMS selected “Advanced APMs”.

• In an Advance APM, but

not a QP*.

*Qualified Participant (QP)

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

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

MIPS Participation: Individual Group

• Defined by taxpayer

identification number (TIN)

• Assessed across all four

MIPS performance categories

• Solo practitioner

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)

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

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

Quality Performance Category

Quality Performance Category

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

 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

Resource Use Category

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

 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

Clinical Practice Improvement Activities Category

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

 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

Advancing Care Information Category

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

 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, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview

Source: CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS)

*MACRA allows potential 3x upward adjustment BUT unlikely

Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview

$10,000 $12,500 $17,500 $22,500 $0 $50,000 $100,000 $150,000 $200,000 $250,000 2019 (-4%) 2020 (-5%) 2021 (-7%) 2022+ (-9%)

Example: MIPS Medicare Part B Penalty

Actual Earned Penalty

Source: CMS, Medicare Access & CHIP Reauthorization Act of 2015: Path to Value *VM and MIPS have possible upward or downward adjustments. Due to budget neutrality, incentives scale based on available funds. Maximum reduction for MIPS listed in statute.

* *

How IBM Watson Health Solutions are expected to support MIPS

• [PLACE HOLDER]

Take-aways:

1. MACRA changes the way Medicare pays clinicians and offers financial incentives for providing high value care. 2. Only Medicare Part B clinicians will participate in the MIPS program, unless:

• 1st year of Part B participation
• Meet criteria for participation in advanced APMs, or
• Low volume of patients.

3. Reporting starts January 2017. 4. Payment adjustments and bonuses will begin in 2019. 5. Final rule is targeted for November 1, 2016

References

• CMS, The Medicare Access & CHIP Reauthorization Act of 2015: The Merit-Based Incentive Payment System (MIPS).

Baltimore, MD: Retrieved from https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value- Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-MIPS-NPRM-Slides.pdf.

• CMS, The Medicare Access & CHIP Reauthorization Act of 2015 - The Merit-Based Incentive Payment System: Quality

Performance Category. Baltimore, MD: Retrieved from https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Performance-Category-training-slide-deck.pdf.

• Goodrich, Kate, MACRA and Delivery System Reform. Retrieved from

www.qualityforum.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=82246.

• CMS, Medicare Access & CHIP Reauthorization Act of 2015: Quality Payment Program All-Payer Combination Option.

Baltimore, MD: Retrieved from https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value- Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-All-Payer-Overview.pdf.

• CMS, The Medicare Access & CHIP Reauthorization Act of 2015 – Quality Payment Program. Baltimore, MD: Retrieved from

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and- APMs/NPRM-QPP-Fact-Sheet.pdf.

• CMS, Medicare Access & CHIP Reauthorization Act of 2015: Path to Value. Baltimore, MD: Retrieved from

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and- APMs/MACRA-LAN-PPT.pdf.

• CMS, Medicare Access & CHIP Reauthorization Act of 2015: MIPS Scoring Methodology Overview. Baltimore, MD: Retrieved

from https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA- MIPS-and-APMs/MIPS-Scoring-Methodology-slide-deck.pdf.

• CMS, Quality Payment Program: Flexibilities and Support for Small Practices. Baltimore, MD: Retrieved from

https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and- APMs/Small-Practices-Fact-Sheet.pdf.

• U.S. Department of Health and Human Services, Centers for Medicare and Medicaid, 42 CFR Parts 414 and 495. Retrieved from

https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf.

QUESTIONS?

THANK YOU!

The recording and handouts will be sent to you via email within 2 business days Questions? Contact Shawn Auer at sauer@us.ibm.com