MIPS Reporting Deep Dive: Which Path is Right for Your Practice?
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1 MIPS Reporting Deep Dive: Which Path is Right for Your Practice? Emily E. Volk, MD, MBA, FCAP Chair, QCDR Ad Hoc Committee Stephanie Peditto Director of Quality at the College of American Pathologists September 6, 2018
2 Welcome Emily E. Volk, MD, MBA, FCAP Chair of the CAP Clinical Data Registry Ad-Hoc Committee Vice Chair, CAP Council on Government and Professional Affairs 2
3 Today Quality Payment Program (QPP) and Merit Incentive Payment System (MIPS) Confirm your MIPS reporting status Decide if you will report as an individual or group Determine your best reporting method Monitor Your MIPS Performance 3
4 Quality Payment Program QPP MIPS APMs 4
5 More Money is at Stake Each Year +4% +5% +7% +9% +/- Maximum Adjustments -4% -5% -7% -9% Doing nothing will result in a penalty onward Merit-based Incentive Payment System (MIPS) 5
6 Exempt Clinicians MIPS will NOT apply to you or your practice if any of the following apply: o You are a first time enrollee in Medicare in 2018 o You are in an Advanced APM and are a Qualifying APM Participant (QP) or Partial QP o If reporting as an individual, you have billed $90,000 or less in Physician Fee Schedule (PFS) services to Medidcare Part B Fee-for-Service (FFS) beneficiaries o If reporting as a group, your group has billed $90,000 or less in PFS services to Medicare Part B FFS beneficiaries o You or your group have 200 or fewer Medicare Part B FFS beneficiaries 6
7 To Confirm Your 2018 MIPS Status Before you log on, have available: 1. Enterprise Identity Data Management (EIDM) credentials 2. Tax Identification Number (TIN) 3. National Provider Identifier (NPI) 7
8 Determine Patient-Facing vs. Non-Patient-Facing Status Non-Patient Facing o An individual clinician who bills 100 or fewer patient facing encounters per calendar year o A group with greater than 75% of clinicians billing 100 or fewer patient-facing encounters 8
9 Non-Patient Facing Pathologists in MIPS For non-patient-facing pathologists, the score is likely based on two categories in 2018* Cost category may be applicable to some non-patient-facing pathologists. o Check 2017 MIPS performance feedback = 85% = 15% 9
10 Individual Vs. Group Reporting Designation Designation applies to all measures in MIPS Group reporting increases case volume Claims based reporting for Quality = Individual Reporting o Must do individual attestation for Improvement Activities 10
11 Determine Your Best Reporting Method CMS QPP Portal Claims-based (billing company) Qualified Clinical Data Registry (QCDR) Qualified Registries (QR) CMS Web Interface o Available for multispecialty practices (25 providers or more) 11
12 IA Attestation via CMS QPP Portal Attest to 1 high-weighted or 2 mediumweighted Improvement Activities (IAs) if you are a non-patient-facing pathologist o As an individual or a group If you report quality measures via claims, you will have to attest IAs for each individual in your practice You are still required to find a mechanism for Quality measures 100+ CMS-defined Improvement Activities 17 Pathologyspecific activities (available on cap.org/advocacy) 12
13 Non-Patient Facing Provider Claims-Based Reporting Report on a minimum of six measures including one outcome or high priority measure QPP Measures QPP 99: Breast Cancer Resection Pathology Reporting * QPP 100: Colorectal Cancer Resection Pathology Reporting * QPP 249: Barrett Esophagus Pathology Reporting * QPP 250: Radical Prostatectomy Pathology Reporting * QPP 251: Evaluation of HER2 for Breast Cancer Patients * QPP 395: Lung Cancer Reporting (biopsy/cytology specimens)* QPP 396: Lung Cancer Reporting (resection specimens) QPP 397: Melanoma Reporting* Outcome or high-priority measure. *Topped-out measure 13
14 Eligible Measure Applicability (EMA) If you report via claims and submit less than 6 quality measures, CMS will determine whether additional measures should have been submitted o Applies to claims-based and QR reporting, o Does not apply to QCDR reporting If the CMS finds no additional applicable measures o Your quality score will be based on the measures submitted If you have less than 6 measures that apply to you, we recommend you review the EMA clusters and report via claims or a QR 14
15 Claims EMA Pathology Clusters Cluster 1 99 Breast Cancer Resection Pathology Reporting 100 Colorectal Cancer Resection Pathology Reporting 249 Barrett s Esophagus 250 Radical Prostatectomy Pathology Reporting 251 Quantitative Immunohistochemical (IHC) Evaluation of Human Epidermal Growth Factor Receptor 2 Testing (HER2) for Breast Cancer Patients Cluster Lung Cancer Reporting (Biopsy/ Cytology Specimens) 396 Lung Cancer Reporting (Resection Specimens) 15
16 Qualified Registry (QR) Reporting Check the CMS QPP Resource Center for a list of available QRs Eight QPP measures available o Report on a minimum of six measures including an outcome or high priority measure o Not all QRs contain pathology measures Not all QRs have IA attestation available, so ensure that improvement activities are covered EMA applies if you report on less than six measures or do not report on an outcome/high priority measure 16
17 Qualified Registry (QR) EMA Pathology Clusters Cluster 1 99 Breast Cancer Resection Pathology Reporting 251 Quantitative Immunohistochemical (IHC) Evaluation of Human Epidermal Growth Factor Receptor 2 Testing (HER2) for Breast Cancer Patients Cluster Lung Cancer Reporting (Biopsy/Cytology Specimens) 396 Lung Cancer Reporting (Resection Specimens) 17
18 Qualified Clinical Data Registry (QCDR) Reporting CAP s Pathologists Quality Registry One stop shopping o Allows individual or group reporting o Report on quality measures and/or improvement activities More pathologist-specific specific measures to choose from o Report on a minimum of six measures including an outcome or high priority measure o EMA process does not apply to QCDRs so ensure you have at least six measures (including outcome/high priority) that you can report 18
19 Quality Measures Available in the Pathologists Quality Registry QPP Measures QPP 99: Breast Cancer Resection Pathology Reporting * QPP 100: Colorectal Cancer Resection Pathology Reporting * QPP 249: Barrett Esophagus Pathology Reporting * QPP 250: Radical Prostatectomy Pathology Reporting * QPP 251: Evaluation of HER2 for Breast Cancer Patients * QPP 395: Lung Cancer Reporting (biopsy/cytology specimens)* QPP 396: Lung Cancer Reporting (resection specimens) QPP 397: Melanoma Reporting* Non-QPP (QCDR) Measures CAP1: Turnaround Time (TAT) Standard Biopsies+ CAP2: Cancer Protocol Elements for Endometrium Completed CAP3: Cancer Protocol Elements for Kidney Resection Completed CAP4: Cancer Protocol Elements for Intrahepatic Bile Duct Completed CAP5: Cancer Protocol Elements for Hepatocellular Carcinoma Completed CAP6: Cancer Protocol Elements for Pancreas Resection Completed CAP7: Helicobacter pylori Documentation Rate CAP8: Turnaround Time (TAT) Lactate CAP9: Turnaround Time (TAT) Troponin Outcome or high-priority measure. * Flagged as a Topped-out measure by CMS. 19
20 Pathologists Quality Registry: MIPS Dashboard Enhance practice success and levels of patient care via registry dashboards and quarterly benchmarking reports providing feedback on individual and/or pathology practice performance *Individual Dashboard restricted to provider and practice administrator 20
21 Monitor Your Performance CMS-provided 2017 MIPS Performance Feedback 21
22 The CAP Has MIPS Resources Decoding MIPS Webinar Series: Pathologist Improvement Activities You Can Attest to Under MIPS webinar on September 20 at 1 PM ET/ 12 PM CT Earn the Maximum Bonus-A look At Pathology Specific Quality Measures That Will Improve Your Score webinar on December 4 at 12 PM ET/ 11 AM CT Steps Pathologists Should Take Before Reporting MIPS Data to the CMS webinar on January 8, 2019 at 3 PM ET/ 2 PM CT Visit cap.org/advocacy for MIPS tools and resources MACRA video MIPS checklist MIPS calculator Improvement Activities made simple Measure descriptions and specifications 22
23 Questions? us at 23
24
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