OC TOBER 19, Quality Payment Program Overview

Transcription

1 OC TOBER 19, Quality Payment Program Overview

2 Quality Payment Program Panel TOM S. LEE, PHD CEO & Founder SA Ignite BETH HOUCK, MBA Vice President, Client Services SA Ignite MATTHEW FUSAN Director, Solutions Consulting SA Ignite

3 Agenda Quality Payment Program (QPP) Overview Merit-based Incentive Payment Program (MIPS) MIPS Categories Alternative Payment Models Q&A

4 QPP Overview

5 Quality Payment Program at-a-glance QPP MIPS APMs Advanced APMs (if sufficient participation, then 5% annual bonus & MIPS-exempt) Non-Advanced APMs For CY2017, out of 1.3M Part B clinicians CMS projects*: ~ 600,000 MIPS eligible clinicians ~100,000 Advanced APM clinicians *QPP final rule

6 2017 MIPS Components & Scoring (Per QPP Final Rule, Oct 14,2016) Creates 100-point system to increase and consolidate financial impacts Ranks peers nationally, and reports scores publicly Scoring Model 2017 weightings put 85% in the Quality and ACI categories Resource Use is 0 for 2017, but will be scored in 2018 and beyond 0 POINTS 15 POINTS 25 POINTS 60 POINTS Resource Use (Cost) Clinical Practice Improvement Activities Advancing Care Information (Meaningful Use) Quality (PQRS/VBM)

7 Winners and Losers: Large Penalties Fund Large Incentives (Globally Budget Neutral) +4%*x +5%*x +7%*x +9%*x onward Budget- Neutrality Multiplier x up to 3 Incentive +/- Maximum Adjustments Penalty -4% -5% -7% -9% onward Plus: Exceptional Performance Bonus of up to 10% ($500M/year pool) onward Performance Year

8 2017 MIPS Payment Adjustment: Pick Your Pace CMS sample estimate from QPP Final Rule, p Actual could be higher or lower depending on score and Part B $ distributions. Part B Payment Adjustment % Total Incentive Base Incentive Max Total Incentive % ~2.4% Max Base Incentive ~0.9% MIPS Points PT = Performance Threshold -4% Avoid a penalty by reporting at least one measure from any category Minimum 90-day performance period allowed and can earn up to 100 points

9 Merit-based Incentive Payment System (MIPS)

10 Program Eligibility: Eligible Clinicians Years 1 and 2 (2017 & 2018) Years 3+ (2019+) Secretary may broaden eligible clinicians group to include others such as:

11 Who Is Not Eligible First year of Medicare Part B participation Below low patient volume threshold Medicare billing charges less than or equal to $30,000 or provides care for 100 or fewer Medicare patients in one year Certain participants in ADVANCED Alternative Payment Models

12 Clinician Attributes Impacting MIPS Scoring Hospital based clinicians Non-patient facing clinicians Small practices, practices located in rural areas or geographic HPSAs

13 MIPS Participation Individual Group APM Entity Group NPI A group, as defined by taxpayer identification number (TIN), would be assessed as a group practice across all four MIPS performance categories A collection of entities participating in an Alternative Payment Model

14 2017 Participation ACI Report some data 5 required measures OR Report Partial/Full Year 5 required* measures Quality 1 measure OR 6 quality measures; or 1 specialty measure set CPIA 1 measure 4 activities** * ** Participation requirements are adjusted for hospital-based MIPS eligible clinicians Participation requirements are adjusted for MIPS eligible clinicians and groups that are small practices, practices located in rural areas or geographic HPSAs, or non-patient facing

15 MIPS Categories

16 MIPS Components Quality Advancing Care Information Clinical Practice Improvement Activities Resource Use % 25% 15% 0% 50% 25% 15% 10%

17 MIPS Components Quality Advancing Care Information Clinical Practice Improvement Activities Resource Use % 25% 15% 0%

18 Key Elements of Quality Component Characteristic MIPS Quality Measures Scoring Patient Threshold 2017: 50% 2018: 60% Bonus Points Topped Out Measures Benchmarks 6 measures + 1 outcome measure; or 11 measures (GPRO Web Interface); or 1 sub-specialty/specialty measure set No CMS 1 and CMS 2 10 pt decile scale 2017 minimum of 3pts for submitting Capped at 10%; decrease over time High priority measures Scored the same as all measures Will be adjusted in future years No benchmark measures score min 3 pts

19 How the Calculation Works: An Example PERFORMANCE SCORE points Each measure scored relative to benchmark, e.g., 20 th decile = 2 points 3 point minimum + BONUS = POINTS Up to 10% X 2 End-to-end electronic reporting High priority measures CAHPS for MIPS COMPOSITE SCORE Earn 60/70 or more points and receive full 60 points in the Quality Category of MIPS Composite Score

20 Future Measure of improvement over decile Increase in outcomes measure reporting Additional specialty measure sets Measure alignment with private payers (Core Quality Measure Collaborative)

21 MIPS Components Quality Advancing Care Information Clinical Practice Improvement Activities Resource Use % 25% 15% 0%

22 Key Elements of Advancing Care Information Characteristics MIPS ACI Measures 5 measures in base score 8 additional performance measures Scoring Total possible 155 points; only 100 required for maximum Thresholds/Hardship exemptions Reweighting to Quality category Bonus points Alignment 5% for registry reporting beyond immunization registry 10% bonus points for using CEHRT for Clinical Practice Improvement Activities

23 Finalized Changes Medicaid EHR Incentive Program remains a separate program with separate reporting Submission methods remain the same 90 day reporting in 2017 and 2018 (to support CEHRT upgrade) Starting January 1, 2017, must attest for Medicare and Medicaid MU to cooperate with surveillance of CEHRT by ONC and good faith CEHRT implementation that does not inhibit health information exchange nor exhibit information blocking

24 New Advancing Care Information Structure BASE SCORE + PERFORMANCE + BONUS = SCORE POINTS COMPOSITE SCORE Makes up to 50 points of the total Advancing Care Information Performance Category Score Makes up to 90 points of the total Advancing Care Information Performance Category Score Up to 15 point of the total Advancing Care Information Performance Category Score Earn 100 or more points and receive full 25 points in the Advancing Care Information Category of MIPS Composite Score

25 New Advancing Care Information Structure BASE SCORE Makes up to 50 points of the total Advancing Care Information Performance Category Score erx 2017 ACI Transition Objectives Health Information Exchange (Create/Send Summary of Care) Security Risk Analysis Provide Patient Access (Patient Access) (2015 CEHRT/Stage 3) erx Send Summary of Care (Patient Care Record Exchange) Request Summary of Care (Patient Care Record) Security Risk Analysis Provide Patient Access (Patient Access)

26 New Advancing Care Information Structure PERFORMANCE SCORE Makes up to 90 points of the total Advancing Care Information Performance Category Score 2017 ACI Transition Objectives (2015 CEHRT/Stage 3) Provide Patient Access 20 pts Provide Patient Access 10 pts View Download Transmit 10 pts View Download Transmit 10 pts Patient-specific Information 10 pts Patient-specific Information 10 pts Secure Messaging 10 pts Secure Messaging 10 pts Health Information Exchange 20 pts Send a Summary of Care 10 pts Request/Accept a Summary of Care Medication Reconciliation 10 pts Clinical Information Reconciliation Immunization Registry Reporting 10 pts Immunization Registry Reporting Patient-generated Health Data 10 pts 10 pts 10 pts 10 pts

27 How the Calculation Works: An Example BASE SCORE + PERFORMANCE + BONUS = SCORE POINTS COMPOSITE SCORE 50 points 90 points 15 points Earn 100 or more points and receive full Attest for all 5 measures (all or nothing) Measure points accumulated by decile 0-9% = 1 point 10-19% = 2 points Etc. 5% Public Health Registry 10% CPIA Alignment 25 points in the Advancing Care Information Category of MIPS Composite Score

28 Future Considerations Minimum thresholds, measure benchmarks and/or measurement on performance improvement Measures for non-patient facing clinicians May re-weight category, but not lower than 15%

29 MIPS Components Quality Advancing Care Information Clinical Practice Improvement Activities Resource Use % 25% 15% 0%

30 Clinical Practice Improvements 94 activities available across 8 categories Each activity worth 20 or 10 points Activity must be implemented at least 90 days Expanded Practice Access (4) Population Management (16) Care Coordination (14) Beneficiary Engagement (24) Patient Safety and Practice Assessment (21) Integrated Behavioral and Mental Health (8) Achieving Health Equity (5) Emergency Preparedness and Response (2)

31 Clinical Practice Improvements: Scoring of CPIA Category MIPS eligible clinician or group 40 pts = 15% High - 20 High - 20 = 40 Small practices, practices located in rural areas or geographic HPSAs, or non-patient facing 20 pts = 15% High - 20 = 20 High - 20 Med - 10 Med - 10 = 40 Med - 10 Med - 10 = 20

32 Alternative Payment Models

33 Alternative Payment Models Reduced financial risk required to qualify as an Advanced APM 20 25% of eligible clinicians to participate in the Advanced APM track in 2018 Announced MSSP Track 1+ that will qualify as an Advanced APM in 2018 CMS plans to reopen current models to allow more participants MIPS APMs (ex MSSP Track 1) follow the MIPS APM scoring standard All eligible clinicians receive the same MIPS final score

34 Advanced APMs 2017 Advanced APMs 2017 Thresholds MSSP Track 2 MSSP Track 3 25% 20% Next Generation ACO Comprehensive ESRD Care Model CPC+ Payments Patients 5% Bonus Payment

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