Quality Payment Program Year 4: Final Rule Overview The - - PowerPoint PPT Presentation
Quality Payment Program Year 4: Final Rule Overview The information contained in this presentation is for general information purposes only. The information is provided by UK HealthCares Kentucky Regional Extension Center and while we
The information contained in this presentation is for general information purposes only. The information is provided by UK HealthCare’s Kentucky Regional Extension Center and while we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to content.
UK’s Kentucky REC is a trusted advisor and partner to healthcare organizations, supplying expert guidance to maximize quality, outcomes and financial performance.
To date, the Kentucky REC’s activities include:
across Kentucky, including primary care providers and specialists
Health Centers (FQHCs) and Rural Health Clinics (RHCs) within Kentucky
hospitals
Commonwealth with practice transformation and preparation for value based payment
Physician Services
Hospital Services
Kentucky REC Description
*Some changes are retrospective
Year 4 Quality Payment Program Overview Merit-Based Incentive Payment System (MIPS) Track Updates MIPS Value Pathways (MVPs) Alternative Payment Model (APM) Track Updates Questions
Name of Legislation or Regulation: Medicare Program; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies… Links for More Information: Final Rule Full Text: https://www.federalregister.gov/documents/2019/11/15/2019-24086/medicare- program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule- and-other Those Impacted: Will impact Medicare Part B payments to eligible clinicians beginning in 2022. Effective: Begins January 2019 with affected payments based on those measures beginning in 2021.
MACRA (Medicare Access & CHIP Reauthorization Act)
than volume (fee for service).
QPP (Quality Payment Program)
between MIPS and APM.
MIPS (Merit-Based Incentive Payment System)
performance programs.
APM (Alternative Payment Model)
bonus payment to Qualified Physicians who are participating in APMs, and exempts them from participating in MIPS.
MVPs (MIPS Value Pathways)
performance year. The goal is to move away from siloed activities and measures and move towards an aligned set of measure options more relevant to a clinician’s scope of practice that is meaningful to patient care.
By law, MACRA requires CMS to implement an incentive program, referred to as the Quality Payment Program, which provides two participation tracks for clinicians:
If you are a MIPS EC, you will be subject to a performance-based payment adjustment through MIPS If in an Advanced APM, you may earn an incentive payment for participating in one of these models
Merit-Based Incentive Program (MIPS) $90K Part B 200 Medicare Patients 200 PFS Advanced Alternative Payment Model (APMs) Advanced APM Participant 50% Payment
35% Medicare Patients QPP Track Eligibility Requirements
Eligible Clinician Types: Physician, PA, NP, CNS, CRNA, PT, OT, Qualified Speech-Language Pathologist, Qualified Audiologist, Clinical Psychologist, Registered Dietitian or Nutrition Professional
No Changes Reminder: Data aggregation required for Virtual Groups across all TINs
0 Points = Full 9% Penalty 45 Points Minimum Threshold = No Penalty, No Reward Between 46-84 Points = No Penalty 85+ = Exceptional Performance Split $500M Pool
Year 5 Minimum Threshold = 60 Points
Program Year Payment Year
Quality Improvement Activities Promoting Interoperability Cost
Adjustment Factor + / -
2020 (Y4) 2022 45% 15% 25% 15% 9% Reporting Timeframes 365- Days 90-Day Minimum 90-Day Minimum 365- Days
Applied During Payment Year
Must Submit by March 31st, 2021
Performance Category Submission Type Submitter Type Collection Type
The mechanism by which a submitter type submits data The MIPS EC, group, or third party intermediary acting on behalf of a MIPS EC or group Set of quality measures with comparable specifications and data completeness criteria
Quality
Direct Log-in & Upload CMS Web Interface Medicare Part B Claims (Small) Individual Group 3rd Party Intermediary eCQMs MIPS CQMs QCDR Measures CMS Web Interface Measures CMS Approved Survey Vendor Measure Medicare Part B Claims (small practices) Administrative Claims Measures
Promoting Interoperability
Direct Log-in & Upload Log-in & Attest Individual Group 3rd Party Intermediary
Improvement Activities
Direct Log-in & Upload Log-in & Attest Individual Group 3rd Party Intermediary
Cost
No data submission required Individual Group
Individual
Under an NPI number & TIN where they reassign benefits
Group
> 2 clinicians (NPIs) who have reassigned their billing rights to a single TIN As an APM Entity
Virtual Group
Combination of > 2 TINs assigned to > 1 individual MIPS ECs, or to > 1 groups consisting of < 10 ECs with > 1 MIPS EC
Quality:
6 Measures Required except for: CMS Web Interface report 10 quality measures At least 1 Outcome measure 7th Measure based on claims for large groups
IA:
40 points raw score required
medium & highly weighted activities
participate in same activity
locations under the TIN are Certified PCMH/PCSP
Cost:
Score is based on Medicare claims, including: Measure 1: Medicare Spending per Beneficiary (MSPB) Measure 2: Total per capita costs (TPCC) for all attributed beneficiaries 18 Episode-Based Measures
PI:
100 points raw score required
Measures Scoring:
Score
2015 CEHRT Required
Year 4: Minimum Threshold = 45 Points; 9% Risk
Final Score:
Submission:
the Reporting Requirements or Submission Mechanisms
Measures
CMS Web Interface Set
for PY21
2019+
Requirements
Requirement to 70%
Controlling High Blood Pressure & A1C Poor Control
QPP Y4: Changes to Improvement Activities (IA)
Final Score:
Submission:
the Reporting Requirements or Submission Mechanisms
Measures
Requirements
Scoring
Across 2-4 Activities
timeframe
QPP Y4: Changes to Promoting Interoperability (PI)
Final Score:
reweights
Submission:
the Reporting Requirements or Submission Mechanisms
Measures
Treatment Agreement
points
Requirements
timeframe
based measurement
points for full credit
Final Score:
Submission:
Measures
per Beneficiary
capita costs
based measures Requirements
MSPB Clinician
methodology
episode
TPCC
methodology
Event and risk window
beneficiary*
specialty exclusions
Adjustment methodology
monthly basis
Episode-Based Measures
method
thresholds
Attribution will be to each MIPS EC who renders a trigger service as identified by HCPCS/CPT procedure codes.
Attribution will be to each MIPS EC who bills inpatient E&M claim lines during a trigger inpatient hospitalization under a TIN that renders > 30%.
*Lower GI Hemorrhage will only be measured at the group level
Procedural Episodes Acute Inpatient Medical Condition Episodes
measures will not be publicly reported for the first two years in use, starting with Performance Year 2
measures will not be publicly reported for the first two years in use
indicator of “Successful”
performing” indicator will not be reported
publicly reported if all
reporting criteria are satisfied
MIPS Historical Categories
Quality, Cost, Improvement Activities Promoting Interoperability (Foundational)
Administrative Claims-Based Quality Measures
Population & Public Health Priorities Condition Specific Measures
Enhanced Data & Feedback
Increase in Comparable Performance Data Fewer Variations in Submissions A conceptual participation framework that would apply to future proposals beginning with the 2021 performance
measure options more relevant to a clinician’s scope of practice that is meaningful to patient care.
Program Year Payment Year Quality Improvement Activities Promoting Interoperability Cost
2020 (Y4) 2022 60% 20% 30% 0% Reporting Timeframes 365-Days 90-Day Minimum 90-Day Minimum 365-Days
Must Submit by March 31st, 2021
Bundled Payments for Care Improvement (BPCI) Advanced Comprehensive Care for Joint Replacement (CJR) Payment Model - Track 1 CEHRT Comprehensive End-Stage Renal Disease (ESRD) Care (CEC) Comprehensive Primary Care Plus (CPC +) Next Generation ACO (Next Gen) Oncology Care Model (OCM) Medicare ACO Track 1+ Medicare Shared Savings Program (SSP) Track 2 Medicare Shared Savings Program (SSP) Track 3 Vermont All-Payer ACO (Vermont Medicare ACO Initiative) *Not in KY
Qualifying Participant Status
MIPS APMs
Alignment of MSSP & Web Interface Measure Sets
Non-ACO Group Reporters
Minimum CEHRT Threshold:
payment must be:
MIPS Comparable Measures:
Payer-Initiated Process for Remaining Other Payers:
Revenue-Based Nominal Amount Standard:
Individual EC Information
Facility-based ECs
downloadable database
late CY2019 Finalized Disclaimer
entire patient population, the variety of services furnished by the EC, or the health conditions of individuals treated”
Finalized Physician Compare Updates
45 Points Threshold; 60 for Year 5 50% IA 85 Points to be Exceptional Performer Expanded Cost Measures; defined at measure level MVPs 2021; Mandatory 2022 QCDR Push Removal of IA’s PDMP Quality Measures adjustments and removal 70% Data Validation No Weight shifts
QPP SURS Technical Assistance: Free, high-level resources for organizations with 15 or fewer eligible clinicians as they navigate the Quality Payment Program. The Resource Center include: straightforward, self-directed resources and tools, up-to-date materials, and access to expert Quality Improvement Advisors. Sign up: www.qppresourcecenter.com VBP Individualized Assistance: 12 months of planning and transformation support tailored to meet specific client needs and support success in value-based payment. This includes current state analysis, recommendations for action, collaborative goal setting and project planning, education, strategic decision support and ongoing advisory services. Advanced APM Support: Ongoing support, research, work plan development and application support for transition to advanced alternative payment models (APM).
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