How to Avoid the MIPS Penalty: Practice Improvement Activity
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1 How to Avoid the MIPS Penalty: Practice Improvement Activity September 2017 Michele Stanek, MHS In Partnership with Alliant Quality South Carolina Office of Rural Health Center for Practice Transformation
2 Quality Payment Program Medicare Physician Reimbursement QPP MIPS MIPS APM APM MIPS (Merit-Based Incentive Program): Based on fee-for-service Performance score based on value FFS payment adjusted based on performance score APMs (Alternate Payment Models): Moves to population-based and episode-based payment Requires shared two-sided risk Incentives for organizations to move towards APMs (bonus) Source:
3 Merit-Based Incentive Program Each physician or eligible professional or group will receive a composite performance score: 0-100; score will determine reimbursement Final Score (0-100) Quality 60% Cost 0% Advancing Clinical Information 25% Improvement Activities 15% Source:
4 MIPS Quality: 6 performance measures (1 outcome); or one specialty-specific or subspecialty-specific measure set; (PQRS) ACI: 5 required measures of EHR functionality & how well you are using EHR/HIT/HIE; no longer pass/fail (MU); 6 optional measures that provide bonus points Resource Use: Claims-based; total per capita cost per attributed beneficiary & Medicare spending per beneficiary (VBPM); Performance Year % to 30% by 2021; finalizing episode-based measures PIA: 92 practice improvement activities high and medium activities
5 Pick Your Pace Transitional Year Source: Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-presentation.pdf
6 Pick Your Pace Transitional Year Source: Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-presentation.pdf
7 Transitional Year Submit 1 Improvement Activity TO AVOID A PENALTY Deadline to Start: OCTOBER 2, 2017
8 Practice Improvement Activities Practices must attest to the completion of approved practice improvement activities for a minimum of 90 days 92 approved practice improvement activities Activities rated as either high and medium activities Complete one improvement activity to avoid a MIPS penalty. Must start by October 2, 2017 Source: Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-presentation.pdf
9 Action Create at Improvement Team Review list of 92 eligible clinical practice improvement activities Practice working on PCMH or PCSP select activities that align with medical home development work Prioritize activities that involve use of EHR Select activities What aligns with Clinical Quality measures and ACI measures What are you currently doing? What resources are available to support IA? Where your pain points? What aligns with other strategic objectives? What activities will give you ACI bonus points? Identify practice support opportunities Apply QI methods Set Aim Select measures Select improvement strategy Test strategy
10 ACI/PIA Bonus Points Source: Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-presentation.pdf
11 Form a team Improvement Team 3-6 members (2-3 if small practice) Roles: Provider champion Day-to-Day leader System leader IT leader Other (Front Desk Staff) Meet 2x per month to get started regular meetings Accountable for deliverables Practice transformation and clinical practice improvement CANNOT be done by one person
12 Practice Improvement Activities Reimbursement Opportunity Source:
13 Practice Improvement Activities Alignment with Other Requirements Source:
14 Practice Improvement Activities Assistance from External Partner DHEC DSME Program Reimbursement Opportunity Source:
15 Everyone in health care should have two jobs: to do the work and to improve how the work is done. - Maureen Bisognano President, IHI
16 Quality Improvement Quality Improvement formal approach to the analysis of performance and systematic efforts to improve it Ensures changes are for the better/positive Incremental vs. breakthrough Multiple stakeholders/perspectives Best practices & Innovation
17 Science of Improvement Utilize a method for performance improvement based on science of improvement: Model for Improvement (IHI) Six Sigma (GE) Lean (Toyota) Balanced Scorecard
18 Practice Improvement Model for Improvement 3 Powerful Questions What are we trying to accomplish Set Goal/Aim How will we know that a change is an improvement Select Measures What changes can we make that will result in improvement Improvement Strategies Test the change/implement improvement strategy using PDSA cycle
19 Improvement Activity
20 Aim Statements Example: XYZ practice will improve its diabetes care for adult (18-64 y.o. age) by implementing planned care. increasing the percentage of patients a self management goal by 20% from 43% to 63% within the next 3 months Increasing the percentage of patients with controlled diabetes by 10% from 30% to 40% within the next 3 months
21 If you cannot measure it, you cannot improve it Lord Kelvin
22 Practice Improvement Model for Improvement 3 Powerful Questions What are we trying to accomplish Set Goal/Aim How will we know that a change is an improvement Select Measures What changes can we make that will result in improvement Improvement Strategies Test the change/implement improvement strategy using PDSA cycle
23 Process: Measures % of patients with at least one A1c test within the past 12 months % of patients with a dilated retinal exam within the past 12 months Outcome: % of patients whose most recent blood pressure measurement < or = 130/80 mm/hg % of patients whose most recent A1c < 8.0%
24 Measuring Change
25 Practice Improvement Model for Improvement 3 Powerful Questions What are we trying to accomplish Set Goal/Aim How will we know that a change is an improvement Select Measures What changes can we make that will result in improvement Improvement Strategies Test the change/implement improvement strategy using PDSA cycle
26 R&D Rip Off and Duplicate
27 Improvement Strategies Provider-focused performance feedback report Provider education Audit and feedback Provider reminders/prompts Coordination of care Care-team focused clinical pharmacist visits Nursing education Care manager Care team member feedback Patient-focused - Diabetes self management class Patient education Promotion of standing order Chronic disease class Patient reminders System-directed standing order Standing orders/protocols Point-of-care decision support Coordination of care with specialists Group visit
28 Improvement Strategy XYZ Practice Aim: Diabetic neuropathy is a frequent serious complication for our patients with diabetes. XYZ practice will improve its diabetes care for adult (18-64 y.o. age) by increasing the percentage of patients with diabetic foot exam within the past 12 months by 20% from 43% to 63% within the next 3 months Improvement Strategies: Foot sticker on intake form for all patients with diabetes Sign reminding patients to remove shoes and socks Ensure that all rooms have monofilament Develop electronic prompt for foot exam Standardize data entry for foot exam.
29 PDSA #3 Plan: Nurses will identify all patients with diabetes and request that their shoes and socks be removed when they room the patient Do: Nurse XX reviewed all patient charts prior to each session and identified all patients with DM and requested they remove their shoes and socks for during 3 ½ day clinic session during week of April 15 th Study: 6/12 patients with diabetes had their shoes and socks removed when provider entered room; 6/6 patients with shoes and socks removed had a foot exam completed at visit; 4/6 patient without shoes and socks removed had foot exam completed at visits; Provider felt that visual prompt was effective reminder to complete foot exam; Nurse did not feel like it added time to intake; however, it was difficult to identify patients with diabetes Act: Develop new system for identifying patients with diabetes; Create signage reminding patients to remove shoes and socks if they have diabetes
30
31 R&D Rip-Off & Duplicate
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33 Change Packages/Tools
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35
36
37 Resources: Patient Self-Management Implementation Guide: Self-Management Support: ment_support_toolkit_for_clinicians_2012_update.pdf
38 Initial Training Slide Deck is available from SCORH upon request
39 Attestation Attestations will be completed to CMS portal (Not Yet Available)
40 Attestation Start Date of Improvement Activity Baseline Measurement (if applicable) 55% of Schedule II drugs were checked in Drug Monitoring program (IA_PSPA_6) 10% of patients with CHF had a completed SM Plan (Action Planning Tool) (IA_BE_17) Listing and description of improvement strategies (PDSA cycles) Care Coordination (IA_CC_7) Conducted initial staff training on 10/6/17 on care coordination Developed training topic list and training schedule Provided follow-up training on Transitional Care Management on 12/3/17 Remeasurement/Improvement (if applicable) 80% of Schedule II drugs were checked in Drug Monitoring program (IA_PSPA_6) 24% of patients with CHF had a completed SM Plan (Action Planning Tool) (IA_BE_17) 3 Trainings on Care Coordination held
41 Contact Information 107 Saluda Pointe Dr Lexington, SC Phone: Fax:
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