MIPS SIMPLIFIED SCORING
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1) MIPS aims to simplify physician benchmarking and scoring by consolidating existing quality reporting programs into a single program called MIPS. It will include measures of quality, clinical practice improvement activities, advancing care information, and resource use. 2) Approximately 95% of providers will participate in MIPS. Scores will be publicly reported, with winners receiving bonuses and penalties funding the bonuses. 3) MIPS scoring involves assigning point values to performance in each category, with the largest weights on quality (50%) and advancing care information (25%). Higher performance will result in positive payment adjustments while low performance may result in penalties.
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MIPS SIMPLIFIED SCORING
- 1. MIPS SIMPLIFIED SCORING Strategic Healthcare Partners, LLC 1
- 2. MEMORABLE FACTOIDS 2 1. ≈95% of providers will participate in MIPS 2. MIPS is budget neutral. Losers’ penalties pay winners’ bonus 3. Congressional Lawmakers sought to “simplify” physician benchmarking 4. AHIP & CMS already agreed to harmonize quality metrics 5. MIPS scores will be publicly available 6. An Advanced Alternative Payment Model (APM) is a generic term to describe 2- sided risk based arrangements April 2015 • MACRA passed via bipartisan support April 2016 • Proposed Rule Released November 2016 • Final Rule Released January 1, 2017 • Reporting Year 1 Begins
- 3. ACRONYM GUIDE 3 ACI – Advancing Care Information (Formerly Meaningful Use) AHIP – American Health Insurance Plans APM – Advanced Alternative Payment Model CCM – Chronic Care Management (CPT 99490) CERHT – Certified Electronic Health Record Technology CPIA – Clinical Practice Improvement Activities CPOE – Computerized Provide Order Entry (E-Prescribing) CPS – Composite Performance Score HIE – Health Information Exchange MACRA – Medicare Access and CHIP Reauthorization Act of 2015 MSPB – Medicare Spending Per Beneficiary MSSP – Medicare Shared Savings Program PCMH – Patient Centered Medical Home SDOH – Social Determinants of Health TCM – Transitional Care Management (CPTs 99495-6) QPP - Quality Payment Program QCDR – Qualified Clinical Data Registry
- 4. MACRA STATUS UPDATE 9/8/16 4 1 Test Program: Submit any data to avoid negative payment adjustment 2 Participate for part of year for a “small positive adjustment” 3 Participate for the entire year for a “moderate positive adjustment” 4 Avoid MIPS via Advanced Alternative Payment Model (APM) CMS announced 4 Options for MIPS Key Take Away: If you can, participate for the entire year.
- 5. ≈95% PROJECTED TO PARTICIPATE IN MIPS 5 0% 20% 40% 60% 80% 100% Solo 2-9 physicians 10-24 physicians 25-99 physicians 100+ physicians MIPS Estimated Economic Impact 2019 % Eligible Clinicians MIPS Penalty % Eligible Clinicians MIPS Bonus *Estimations prior to recent update nullifying negative penalties in 2019
- 6. Category Formerly Known As: Year 1 Weight Scoring Methodology Quality PQRS 50% • Each measure 1-10 points compared to historical benchmark • 0 points for non-reported measure • Bonus Points available • Measures are averaged for total categorical score Advancing Care Information Meaningful Use 25% • Base score of 50% points achieved by reporting at least one unique patient for each measure • Performance score of up to 80% points • Public Health Reporting Bonus Point • 100% points = Full Credit Clinical Practice Improvement Activities N/A 15% • 10 Point “medium weight” activities & 20 Point “high-value” activities available • 60 Points = Full Credit Resource Use Value- Modifier 10% • Similar Scoring to Quality Category • No Reporting Necessary! 6 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization Key Take-Away: Quality & ACI Take priority. MIPS COMPOSITE SCORE SUMMARY
- 7. QUALITY PERFORMANCE Each measure is converted to a decile point scale (1-10) Zero points for a non-reported measure Bonus points Total Points 7 Total Points Total Possible Points Quality Composite Performance Score Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 8. Decile 1 2 3 4 5 6 7 8 9 10 Possible Points 1.0-1.9 2.0-2.9 3.0-3.9 4.0-4.9 5.0-5.9 6.0-6.9 7.0-7.9 8.0-8.9 9.0-9.9 10 8 QUALITY PERFORMANCE • CMS publishes deciles based on national performance in baseline period • Eligible clinician’s performance is compared to baseline • If performance on a measure is clustered together (i.e. 70% of respondents are within 3 deciles, the midpoint decile will be assigned to all providers in this cluster) Decile 1 2 3 4 5 6 7 8 9 10 Possible Points 1.0-1.9 2.0-2.9 3.0-3.9 4.0-4.9 5.0-5.9 6.0-6.9 7.0-7.9 8.0-8.9 9.0-9.9 10 % of Providers 0% 2% 3% 5% 10% 80% All 80% of these providers will receive the midpoint decile of 8 points
- 9. QUALITY PERFORMANCE- BONUS POINTS • Earn up to a possible 10% “extra credit” in bonus points • 1 bonus point for other “high priority” measures (up to 5%) • 1 bonus point for each measure reported using CEHRT (up to 5%) • 2 bonus points awarded for additional outcome/patient experience • Not available for claims 9 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 10. Measure Measure Type # of Cases Points Based on Performance Total Possible Points (10 x Weight) Quality Bonus Points for High Priority Quality Bonus Points for EHR Measure 1 Outcome Measure using CEHRT 20 4.1 10 0 (Required) 1 Measure 2 Process using CEHRT 21 9.3 10 1 Measure 3 Process using CEHRT 22 10 10 1 Measure 4 Process 50 10 10 Measure 5 High Priority- Patient Safety 43 8.5 10 1 Measure 6 (Missing) Cross-Cutting N/A 0 10 Acute Composite Admin. Claims 10 Not scored: below minimum sample size Chronic Composite Admin. Claims 20 6.3 10 Total Points All Measures N/A 48.2 70 1 3 10 QUALITY PERFORMANCE SCORING EXAMPLE Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization Key Take-Away: Know your measures. Include 1 Outcome & 1 Cross-Cutting Measure. Consult CMS’ Core Set Measures.
- 11. QUALITY PERFORMANCE 11 52.2 Total Points 70 Possible Points 74.6% Quality Score 48.2 Points 1 Bonus Point for high priority measure 3 bonus points for CEHRT Reporting 52.2 Total Points Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 12. ADVANCING CARE IMPROVEMENT 12 Base Score Performance Score Bonus Point Composite Score Represents 50 Points of ACI Score Represents 80 Points of ACI Score Up to 1 Point of ACI Score 100 Points = Full Credit in ACI Category Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 13. ACI BASE SCORE 13 Protect PHI (Required) CPOE (E-Prescribing) Patient Electronic Access (Patient Portal) Coordination of Care Through Patient Engagement Health Information Exchange Public Health/Clinical Data Registry Reporting (Required) To receive full credit of the base score, physicians will need to report one unique patient in each category Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 14. ACI BASE SCORE PROPOSED EXAMPLES 14 Protect PHI •Security Analysis (Required) Electronic Prescribing •CPOE Public Health and Clinical Data Registry Reporting •Immunization Registry Reporting (Required) •Syndromic Surveillance Reporting (Optional) •Electronic Case Reporting (Optional) •Public Health or Clinical Data Registry Reporting (Optional) Coordination of Care Through Patient Engagement • View, Download, and Transmit (VDT)* • Secure Messaging* • Patient-Generated Health Data* Health Information Exchange • Exchange Information with Other Clinicians* • Exchange Information with Patients* • Clinical Information Reconciliation* Patient Electronic Access • Patient Access to PHI* • Patient-Specific Education* * = Proposed Performance Score Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 15. ACI PERFORMANCE SCORE 15 Patient Electronic Access Coordination of Care Through Patient Engagement Health Information Exchange Physicians will be proportionally scored against their peers in terms of patient engagement with these objectives Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization Key Take-Away: Get creative to encourage patients to utilize patient portal.
- 16. CLINICAL PRACTICE IMPROVEMENT ACTIVITIES: SUMMARY 90+ proposed activities categorized as “high” 20 point activities or “medium” 10 point categories Full credit is achievement of 60 points Patient-Centered Medical Home (PCMH) guarantees full credit APM participation receives a minimum of half credit 16 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 17. CPIA REPORTING OPTIONS 17 Individual Reporting Attestation QCDR Qualified Registry Electronic Health Record Administrative claims (if technically feasible, no submission required) Group Reporting Attestation QCDR Qualified Registry Electronic Health Record CMS Web Interface (Groups of 25+) Administrative claims (if technically feasible, no submission required) Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 18. CPIA SUBCATEGORIES 18 Expanded Practice Access Beneficiary Engagement Population Health Management Patient Safety and Practice Assessment Care Coordination Participation in an APM, including a medical home model These 6 subcategories proposed in NPRM Achieving Health Equity Emergency Preparedness and Response Integrated Behavioral & Mental Health These 3 subcategories are required in MACRA Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 19. CPIA EXAMPLESExpanded Practice Access 24/7 Access to Care team Telehealth Patient Experience used for QI Projects Population Health Management Participation in systemic anticoagulation program Participation in a QCDR Monitor health conditions Care Coordination Participate in Transforming Clinical Practice Initiative Closing the referral loop Timely HIE with patients & providers Beneficiary Engagement Collect & utilize patient experience data Beneficiary Training for self- management Patient portal 19 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization 20 points! Full Credit = 60 points 10 points!
- 20. Patient Safety & Assessment Opioid Management Use of Surgical Checklists STEPS Forward Program Achieving Health Equity Timely care for Medicaid patients Participate in State Innovation Model activities Screen for SDOH Emergency Response Participate in Disaster Medical Assistance teams Participate in domestic or international humanitarian work Integrated Behavioral & Mental Health Co-location of mental health services in clinical settings Depression Screening Substance abuse prevention & treatment 20 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization 10 points! 20 points! Full Credit = 60 points CPIA EXAMPLES
- 21. CPIA SCORING SUMMARY 21 50 Total CPIA Points 60 Points 83% CPIA Score Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization Participate in TCPI Telehealth Use of Surgical Checklists Patient Portal 50 Total CPIA Points 83% x 15% weight for CPIA = 12.5 points towards MIPS Composite Score 20 Point Activity 10 Point Activity
- 22. CPIA SPECIAL SCORING CONSIDERATIONS 22 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization • Non-patient facing eligible clinicians, small practices (15 or fewer professionals), rural practices, and clinicians in geographic health professional shortage areas: • 1st activity earns 50% of the 60 points • 2nd activity earns 100% of the 60 points • APM participation automatically earns 50% of the 60 points • PCMH’s receive 60 points
- 23. RESOURCE UTILIZATION: KEY CHANGES Value Modifier • 6 Measures; Total per capita costs for all attributed beneficiaries • Medicare spending per Beneficiary (MSPB) • Total per capita cost measures for 4 condition- specific groups (COPD, CHF, CAD, Diabetes) • Attribution to group practice (TIN) Proposed MIPS Resource Use Category • 2 of the 6 VM measures; Total per capita costs for all attributed beneficiaries • Medicare spending per Beneficiary (MSPB) • Removes total per capita cost for the 4 condition-specific groups • Proposes up to 41 other episode-based measures • Attribution to group (TIN) or individual TIN or NPI 23 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 24. RESOURCE UTILIZATION: KEY CHANGES - ATTRIBUTION Value Modifier • 2-step process for claims-based measures Proposed MIPS Resource Use Category • Expansion of primary care services to align with MSSPs: • Inclusion of CCM & TCM coding • Exclusion of nursing visits occurring in SNF 24 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 25. RESOURCE UTILIZATION: KEY CHANGES - MSPB Value Modifier • MSPB measures care around a hospitalization • Adjusted for IP DRG & a separate adjustment is applied to specialty composition of group practice • Minimum of 125 cases to be “reliably” measured Proposed MIPS Resource Use Category • Individual cases measured the same • 2 technical adjustments for MIPS: • Modified individual case aggregation • Removed specialty adjustment • Two adjustments make MSPB more at the smaller case volume • 20 cases is the proposed threshold for episode-groups 25 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 26. Resource Use Type of Measure # of Cases Performance Measure Performance Threshold Points Based on Decile Total Possible Points M1 MSPB 20 $15,000 $13,000 4.0 10 M2 Total Per Capita 21 $12,000 $10,000 4.2 10 M3 Episode 1 22 $15,000 $18,000 5.8 10 M4 Episode 2 10 $11,000 $9,000 Below Case Threshold N/A M5 Episode 3 0 N/A N/A No attributed cases N/A M6 Episode 4 45 $7,000 $10,000 8.3 10 Total 22.3 40 26 RESOURCE USE SCORING SAMPLE Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 27. RESOURCE USE SCORING Each measure is converted to decile points (1-10) (Only Includes Case Volumes >20) Total Points 27 22.3 points 40 possible points 55.8% Resource Use Score Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization
- 28. Category Formerly Known As: Year 1 Weight Scoring Methodology Quality PQRS 50% • Each measure 1-10 points compared to historical benchmark • 0 points for non-reported measure • Bonus Points available • Measures are averaged for total categorical score Advancing Care Information Meaningful Use 25% • Base score of 50% points achieved by reporting at least one unique patient for each measure • Performance score of up to 80% points • Public Health Reporting Bonus Point • 100% points = Full Credit CPIA N/A 15% • 10 Point “medium weight” activities & 20 Point “high-value” activities available • 60 Points = Full Credit Resource Use Value- Modifier 10% • Similar Scoring to Quality Category 28 Quality Advancing Care Information Clinical Practice Improvement Activities Cost: Resource Utilization MIPS COMPOSITE SCORE SUMMARY
- 29. TRANSFORMING CLINICAL PRACTICE IMPROVEMENT GRANT 29 • CMS $685 million awarded to equip >140,000 clinicians with tools needed to: • Improve Care Quality • Increase Patients’ access to information • Assist in FFS>FFV Transformation • Population Health IT Infrastructure • Caravan Health • Also known as “National Rural Accountable Care Consortium” • Active in 43 states • Uses “Lightbeam” Population health Solution • Compass PTN • Iowa Health Collaborative-Partnered with GHA • Active in 6 states • Uses “Telligen” Population Health Solution
- 30. TRANSFORMING CLINICAL PRACTICE IMPROVEMENT GRANT 30 Patient’s chief complaints determines care Systemically assess all patient health needs Care is determined by today’s problem Care is determined by proactive care plan Traditional Approach Transformed Practice Care varies by scheduled time Care is standardized according to evidence-based guidelines Patients are responsible for coordinating their own care A TEAM of professionals coordinate patient care What? How? When? Who? Via Population Health Infrastructure
- 31. QUESTIONS? 31
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