MIPS, Scoring and Submission Methods. David H. Smith, MBA HIT Project Manager

Transcription

1 MIPS, Scoring and Submission Methods David H. Smith, MBA HIT Project Manager

2 HealthInsight Our business is redesigning health care systems for the better HealthInsight is a private, non-profit, community based organization dedicated to improving health and health care in the western United States.

3 Mountain-Pacific Quality Health We are the Medicare Quality Innovation Network- Quality Improvement Organization (QIN-QIO) for Montana Guam Wyoming American Samoa Hawaii The Commonwealth of the Alaska Northern Mariana Islands

4 Today s Presentation Scoring MIPS Quality ACI Improvement Activities Costs - forthcoming Submission Solo Group Strategies for selection Timelines

5 Scoring Quality 60 percent Advancing Care Information 25 percent Improvement Activities 15 percent Costs (0 percent of score, not required this year 2017) Quick review on what we think is coming

6 The MIPS Pie Improvement Activities 15% 2017 Advancing Care Information 25% Quality 60%

7 The MIPS Pie Improvement Activities 15% Cost 10% 2018 Quality 50% Advancing Care Information 25%

8 The MIPS Pie 2019 Cost 30% Quality 30% Improvement Activities 15% Advancing Care Information 25%

9 Sample Category Total Limit Actual Percent Weight Score Possible Quality Multiple 100% 50 50% methods fraction extra points ACI 155/ % % IA 40/40 or 100% 20/40 50% /20 Costs 0/0 Total 62.5

10 MIPS Quality Scoring Quality Scoring based on benchmarks, set up with deciles Three points for submitting each measure, up to 10/measure if in 10 th decile See benchmarks document Extra point for outcome/high priority measures, in addition to six measures Include at least one outcome measure

11 Deciles Deciles what they aren t and what they are: The decile could be anywhere on the spectrum from x+0% to x-100 percent A quality measure reporting at 45 percent is not necessarily in the fourth decile 45 percent could be in the third decile or the eighth decile depending on the performance of others

12 Examples of Scoring Quality in MIPS Within 3rd decile: 3+ points toward MIPS quality Within 1st decile: 3+ points toward MIPS quality Within 4th decile: 4+ points toward MIPS quality Within 5th decile: 5+ points toward MIPS quality Within 8th decile: 8+ points toward MIPS quality Within 2th decile: 3+ points toward MIPS quality

13 Example: Poor Control of A1C Measure_Name Measure _ID Submission_ Method Diabetes: Hemoglobin A1c Poor Control 1 Claims Outcome Y Diabetes: Hemoglobin A1c Poor Control 1 EHR Outcome Y Registry/QCD Diabetes: Hemoglobin A1c Poor Control 1 R Outcome Y Decile 3 Decile 4 Decile 5 Measure_ Benchm Type ark Decile 3 Decile 4 Decile 5 Decile 6 Decile 7 Decile 8 Decile Decile 6 Decile Using Claims submitted method, how many points for 15%? 2. Using EHR method, how many points for 20%? 3. Using Registry method, how many points for 15%? Decile Decile Decile Topped Out Decile Topped 10 Out <= 4.00 No No <= No Claims <= 4.00 No EHR No Registry/QCDR <= No

14 Quality Scoring Scenarios Solo It Depends Most submit six or more measures. (Claims, EHR, QCDR, QR, Attestation) for full consideration of measures/support Many claims based measures are topped out Suggest evaluating benchmarks. Consider custom QCDRs if clinically relevant, ideally, more than 20 providers submitting measures so benchmarks can be set. Also, consider where those benchmarks may be for performance reasons. Not all measures in each Specialty Measure Set will be applicable to all clinicians in a given specialty. If the set includes less than six applicable measures, the eligible clinician should only report the measures that are applicable.

15 Note Specialty Measure Sets

16 Note One of the Specialties w/< 6 Measures.

17 Equation for Scoring Quality (60% towards MIPS) If you re in traditional MIPS, quality counts towards 60 percent of your total score. (lower in AAPMs where costs may also count)

18 Scoring Advancing Care Information Three components Core Performance Bonus

19 MIPS Category: Advancing Care Information (ACI) 25 percent of Final Score in 2017 Promotes patient engagement and the electronic exchange of information using certified EHR technology Replaces the Medicare EHR Incentive Program (a.k.a. Meaningful Use) Greater flexibility in choosing measures In 2017, there are two measure sets for reporting: ACI for those using 2015 edition CEHRT 2017 Transition for 2014 edition CEHRT

20 MIPS Category: Points Possible Maximum Possible 155 Points. 100 will get you to the full 25 points as part of the total score for MIPS. Base Score 50 points Performance 90 points Bonus 15 points Choose to submit up to nine measures for a minimum of 90 days for additional credit. Bonus Credit for Public Health and Clinical Data Registry Reporting Measures

21 Base 50 Points Perform each of these with a yes/no or at least one in the numerator to demonstrate participation. Any year 2014 or 2015 Certified Product Security Risk Analysis eprescribing Provide Patient Access (+ Performance) Send Summary of Care (+ Performance) Request/Accept Summary of Care Record (+ Performance) 2017 version or for 2014 cert product users Security Risk Analysis eprescribing Provide Patient Access (+ Performance) Health Information Exchange (+ Performance)

22 Performance 90 Points Any Year 2014/2015 Certified Products Provide Patient Access 10 pts Send a Summary of Care 10 pts Request/Accept Summary of Care 10 pts Patient Specific Education 10 pts View Download Transmit 10 pts Secure Messaging 10 pts Patient Generated Health Data 10 pts 2017 if on 2014 certified product only Provide Patient Access 20 pts Health Information Exchange 20 pts View, Download, Transmit 10 pts Patient Specific Education 10 pts Secure Messaging 10 points Medication Reconciliation 10 pts Immunization registry 0 or 10 points Clinical Information Reconciliation 10 pts Immunization registry reporting 0 or 10 pts

23 Bonus 15 Pts Requirements for Bonus Score (report to 1 or more of the public health and clinical data registries) 5 points Syndromic Surveillance Registry Reporting Electronic Case Reporting Public Health Registry Reporting Requirements for Bonus Score (report to 1 or more of the public health and clinical data registries) 5 points Syndromic Surveillance Registry Reporting Specialized Registry Reporting Clinical Data Registry Reporting 10 points options below 10 points options below Report certain improvement activities Report certain improvement activities Advancing Care Information Calculator.xlsx

24 Improvement Activity Scoring 40 Points for groups > 15 providers 20 Points required for groups < 15 providers High 20 Points Medium 10 Points

25 Scenarios Larger groups will typically have several improvement activities happening in their system. Finding improvement activities that are supported by 1+ providers give credit to the whole group

26 Full Support for Improvement Activities Patient Centered Medical Home (PCMH) State-based PCMH (if approved like Oregon s PCPCH)

27 Sample Category Total Limit Actual Percent Weight Score Possible Quality Multiple 100% 50 50% methods fraction extra points ACI 155/ % % IA 40/40 or 100% 20/40 50% /20 Costs 0/0 Total 62.5

28 Submission Methods NEXT TOPIC Submission Methods Group and Solo submission options Your TIN may be choosing a method for you If working in multiple TINs, or if you have your own clinic aside from employment, you may need to report for each TIN Providers moving from other TINs may utilize reporting from other domains

29 Submission Methods EHR Qualified Registry QCDR Attesta tion Web Interface (June 30 groups only) CAHPS (June 30 groups only, counts as 1) Quality X X X X X X Claims Advancing Care Info. Improvement Activities X X X X X X X X X X Costs X

30 Group Providers CMS Web Interface (only available to groups with 25 or more eligible clinicians) Qualified Clinical Data Registry (QCDR) Qualified Registry Electronic Health Record (EHR) CAHPS for MIPS Survey (only available to groups with 2 or more eligible clinicians) Attestation ACI and IA only (not quality)

31 Submission Methods EHR Qualified Registry QCDR Attesta tion Web Interface (June 30) CAHPS (June 30 groups only) Claims Quality X X X X X X Advancing Care Info. Improvement Activities X X X X X X X X X X Costs X

32 Strategies for Selection You can only use one submission method per category in 2017 Possibly changing to multiple methods per category in future years per 11 days old proposed rule on 2018 MIPS

33 Timelines June 30, three days from now Deadline for Web Interface Deadline for CAHPS

34 QCDR Quality ACI Improvement Activity If using custom or registry measures, confirm that enough providers will report Confirm your chosen QCDR/s support this, or arrange for optional method of submission. Confirm your chosen QCDR/s support this, or arrange for optional method of submission. Confirm that benchmarks are or will be available. Evaluate value of submitting more measures to your organization and to your specialty area.

35 QCDR Suggestions Measures submitted may not be official MIPS measures but can count. Suggestions: Consider appropriateness to your specialty You may get a score higher than 3 for your performance within deciled averages if others submit (over 20), suggest confirming with vendor Suggest confirming average reporting rates will be available

36 Qualified Registry Solo Quality ACI Improvement Activity If using custom or registry measures, confirm that enough providers will report Confirm that benchmarks are or will be available. Evaluate value of submitting more measures to your organization and to your specialty area. Confirm your chosen QR/s support this, or arrange for optional method of submission. Confirm your chosen QR/s support this, or arrange for optional method of submission.

37 Qualified Registry Suggestions Measures are on the list w/information regarding benchmarks Consider if benchmarks exist Consider using measures that support state-based initiatives if you are in primary care for 2/1 reporting benefit Example: SBIRT, or alcohol and substance abuse measures have applicability to state based reports in places like Oregon

38 Electronic Health Record Quality ACI Improvement Activity Evaluate measures Obvious benefits to utilizing ACI for EHR submission. Improvement Activities may be more difficult to prove, confirm. Advantages of using EHR vendor to submit EHR real time knowledge of where your measures are at, possibly daily, or at least monthly or quarterly in most cases Up to date information Some vendors may share in mutual benefits of improving quality Consider measures submission benefits to performance rankings in benchmarks. Some methods of submission are easier to achieve

39 Administrative Claims Quality ACI Improvement Activity Claims data can be difficult to confirm for many quality measures, and more difficult to compete in with standard measures. Not applicable. N/A

40 Attestation Quality ACI Improvement Activity N/A Consider probability of error Helpful if one more than one EHR Consider data validation to support improvement activities if audited

41 Web Interface Quality ACI Improvement Activity 15 measures Vendor submission options Ability to support improvement activities using this method.

42 Upcoming Webinar Series July 11 Improving Your Score All sessions will be held at 1-2 p.m. MT Register at

43 Questions This material was prepared by HealthInsight, the Medicare Quality Innovation Network-Quality Improvement Organization for Nevada, New Mexico, Oregon and Utah, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 11SOW-D

44 How to Ask a Question

45 For More Information Contact a QPP Expert in Your State Mountain-Pacific Quality Health Please contact us for assistance! QualityPaymentHelp@mpqhf.org Montana Amber Rogers arogers@mpqhf.org (406) Wyoming Brandi Wahlen bwahlen@mpqhf.org (307) Alaska Preston Groogan pgroogan@mpqhf.org (907) Region/Senior Account Manager Sharon Phelps sphelps@mpqhf.org (307) Hawaii and Territories Cathy Nelson cnelson@mpqhf.org (808) Visit us online at

46 For More Information Contact a QPP Expert in Your State HealthInsight QPP Support Call: qpp@healthinsight.org Web: Nevada Aaron Hubbard Call: ahubbard@healthinsight.org New Mexico Ryan Harmon or Danielle Pickett Call: or rharmon@healthinsight.org or dpickett@healthinsight.org Oregon David Smith Call: dsmith@healthinsight.org Utah Brock Stoner Call: bstoner@healthinsight.org