Quality Reporting Updated: 01/17/17 1
The Way It Was … Quality Reporting REPORTING PERIODS 2007-2016 • Physician Quality Reporting System • The Physician Quality Reporting System (PQRS) applied bonus payments (reporting years 2007-2014, bonus payments 2009-2016) to eligible professionals (EP) who satisfactorily reported data on quality measures for covered services provided to Medicare Part B fee-for- service beneficiaries and applied negative payment adjustments (reporting years 2013-2016, payment adjustments 2015-2018) to EPs who failed to satisfactorily report data on quality measures. • Meaningful Use of the Electronic Health Record • The Medicare Electronic Health Record (EHR) Incentive Program provides bonus payments to EPs who demonstrate meaningful use (MU) of certified EHR technology and applied negative payment adjustments to those who do not demonstrate. • Value-based Payment Modifier Program • The Value-Based Payment Modifier (VBPM/VM) Program adjusts payment rates under the Medicare Physician Fee Schedule based on an EP’s performance on quality and cost categories . 2
2014 REPORTING IMPACTS 2016 PAYMENTS 3
IMPACTED 2016 2014 Quality Reporting PAYMENTS PQRS reporting results only available to providers ≅ 2 years later. 4
2014 REPORTING Provider Reporting Results IMPACTED 2016 PAYMENTS Via 2016 MREP (Medicare Remit Easy Print): (CARC) (CARC) RARC: N699 – Payment adjustment based on PQRS NOTE: 253 is an additional 2% payment cut. N700 – Payment adjustment based on EHR N701 – Payment adjustment based on VBPM/VM http://www.wpc-edi.com/reference/ 5
2015 REPORTING IMPACTS 2017 PAYMENTS 6
IMPACTS 2017 PAYMENTS 2015 PQRS Reporting Full year report results available (9/2016) via the Quality and Resource Use Reports (QRURs) https://portal.cms.gov. -OR- Via 2017 MREP remits for payment adjustment codes. 7 No MREP sample yet as Medicare holds payments for 14 days .
IMPACTS 2017 PAYMENTS 2015 PQRS Reporting (cont.) To Contest PQRS Results: Informal Review period 09/26/2016 – 11/30/2016 https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/PhysicianFeedbackProgram/2015-QRUR.html Nothing can be done to change 2017 PQRS impact. • There are no hardship exemptions for the PQRS negative payment adjustment. • Informal review request were required within 60 days of the September 26, 2016 release date of the 2015 PQRS feedback reports. Informal review period September 26 - November 30, 2016. https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/PQRS/Payment-Adjustment-Information.html Contact Help Desk: 1-866-288-8912 (TTY 1-877-715-6222) Email: qnetsupport@hcqis.org 8
2015 REPORTING Provider Reporting Results IMPACTED 2017 PAYMENTS To Contest EHR Results: NOTE: CMS Meaningful Use (MU) Letters were received ~12/27/16 notifying providers of 2017 EHR (MU) payments adjustments. EPs who believe they erroneously received a negative payment adjustment for failing to demonstrate MU in 2015 can apply for a Hardship Exception by submitting a Reconsideration Form. https://www.cms.gov/Regulations-and- Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_Re considerationFormEP.pdf EHR DEADLINE IS FEBRUARY 28, 2017 9
2016 REPORTING IMPACTS 2018 PAYMENTS 10
IMPACTS 2016 PQRS Reporting 2018 PAYMENTS 2016 reporting requirements: • Full year of reporting (January 1 – December 31, 2016) • Report on at least 9 measures (including 1 cross-cutting measure) across 3 domains for at least 50% of the Medicare Part B patients • Cross-cutting measures are any measures that are broadly applicable across multiple clinical settings and eligible professionals (EPs) or group practices within a variety of specialties. • In early 2011, the Agency for Healthcare Research and Quality (AHRQ) delivered the National Quality Strategy (NQS) to Congress. 11
IMPACTS 2018 PAYMENTS 2016 PQRS Reporting (cont.) • The AHRQ/NQS strategy included three aims and six priorities whose intent was to focus our collective attention on: Quality and the measurement of quality within health care. • Those six priorities have morphed into what we now referred to as the six NQS domains . • Patient Safety • Patient and Family Engagement • Care Coordination • Clinical Processes/Effectiveness • Population and Public Health • Efficient Use of Healthcare Resources 12
IMPACTS 2018 PAYMENTS 2016 PQRS Reporting (cont.) What can a provider do now to fix 2016 reporting. • Claims reporting: Nothing. (get all your charges with Cat II codes filed by deadline) • Registry Reporting: – Review results to see if Cat II numerators can be added to data for recalculation. – Confirm the last day to send data to your specific registry. – Review the list of Qualified Registries to see if participation is still available: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/PQRS/Downloads/2016QualifiedRegistries.pdf • EHR Reporting: – Attest to a 90 day period in 2016 and submit data by deadline. • Last date to submit data to CMS: 13
2017 REPORTING IMPACTS 2019 PAYMENTS 14
2017 THE CHANGE (more acronyms) MACRA: Medicare Access and CHIP Reauthorization Act • CHIP: Children’s Health Insurance Program • SGR: Sustainable Growth Rate • QPP: Quality Payment Program CMS (Centers for Medicare and Medicaid Services) is replacing the long standing SGR provider fee schedule system used prior to 2017 to calculate physician reimbursement based on an economic growth formula resulting in a conversion factor (CF) threat of a ~20% cut each year. 15
IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) QPP will change physician reimbursement from quantity to quality by establishing two tracks for quality reporting (provider picks): • MIPS: Merit Based Incentive Payment (most widely used by providers) – Will potentially provide incentive payments to ECs for participation • APM: Alternative Payment Model (may be more widely used by 2018) Eligible Clinicians (EC) (previously called Eligible Professionals (EP)): • Physician (MD/DO and DMD/DDS) • Physician Assistant (PA) • Nurse Practitioner (NP) • Clinical Nurse Specialist (CNS) • Certified Registered Nurse Anesthetist (CRNA) 20 19 (3 rd year of QPP reporting) to broaden ECs to include: • Physical (PT) / Occupational Therapist (OT) • Speech/Language Therapist (SLP) • Audiologists • Nurse Midwives • Clinical Social Workers • Clinical Psychologists • Dietitians / Nutritional Professionals 16
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IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) Exempt providers: Based on CMS analysis of a providers historical data from a billing / determination period: September 1, 2015 – August 31, 2016 CMS OR will notify provider, September 1, 2016 – August 31, 2017 no action necessary Exempt providers include: • Providers who see less than 100 Medicare patients OR • Providers who bill (submit claims for) less than $30,000 • Submitted claims* yielding Medicare ‘Allowed’ amount (recall MREP sample) OR • Newly enrolled providers • Enrolled in Medicare in 2017 (not reenrolled, true first time enrolled) 18
IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) Reporting Requirements Must report on at least 50% of the clinician or group’s patients who meet the measure’s denominator criteria for the performance period. • Individuals or groups who submit Quality measure data using QCDRs, qualified registries, or via EHR: CMS will expect to receive Quality data for both Medicare and non- Medicare patients. • Individual MIPS eligible clinicians who submit Quality measure data on Medicare Part B claims (claims reporting): CMS will expect to receive Quality data for Medicare patients only. NOTE: The Medicare Remit Easy Print (MREP) conveys CARCs and RARCs of numerator acceptance, i.e., N620 - Alert: This procedure code is for quality reporting / informational purposes only. 19
Provider Reporting Acknowledgment Via MREP (Medicare Remit Easy Print): (CARC) (CARC) RARC: N620 – Alert: This procedure code is for quality reporting/informational purposes only. http://www.wpc-edi.com/reference/ 20
IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) Why act now? Possibility of more timely feedback and protecting future fee schedule. 21
IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) MIPS: Merit Based Incentive Payments – Four reporting options: • Submit Something neutral fee schedule adjustment Avoid the payment penalty in 2019 • Submit a Partial Year + positive fee schedule adjustment Avoid the payment penalty in 2019 Become eligible for a partial positive adjustment • Submit a Full Year ++ positive fee schedule adjustment Avoid the payment penalty in 2019 Become eligible for a moderate positive adjustment • Don’t Participate negative fee schedule adjustment Receive a -4% payment penalty in 2019 22
IMPACTS 2019 PAYMENTS 2017 MACRA Reporting (cont.) Track 1: MIPS - Four categories to calculate a providers 2017 composite performance score (possible 100 points) Categories ( https://qpp.cms.gov ) • Quality – All ECs • Clinical Practice Improvement Activities (CP IA ) – All ECs • Advancing Care Information (ACI) – See exemptions • Cost (not used until 2018) - Deferred 23
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