MACRA Quality Payment Program: MIPS 2018

mips 2018 program

What is the Quality Payment Program?

The Centers for Medicare and Medicaid Services (CMS) recently released the final rule outlining the Quality Payment Program (QPP) for 2018. While nearly identical to 2017, there are some new changes that could have a large impact on participating practices and clinicians. How will these new changes affect you? Check out our list of FAQs and get in touch to learn how SurveyVitals can help your organization meet reporting requirements.


Who Participates?

If you bill Medicare Part B more than $90,000 in allowed charges per year and provide care for more than 200 unique Medicare patients a year, then you are part of the QPP. If you do not meet this threshold, you could be exempt from participating in the program in 2018 under the the low-volume threshold exemption.

Eligible clinicians under the program include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. If you are unsure if you are required to participate in MIPS, CMS has provided a resource to check your status by entering your NPI into an eligibility “calculator”. Additionally, the agency plans to send letters to clinicians notifying them of their eligibility in 2018.

**Note: CMS has not yet updated the QPP website and tool to reflect the 2018 performance year.

Two Tracks: Which is right for you?

There are two participation tracks in the Quality Payment Program. Most Medicare Part B clinicians and groups will fall under the Merit Incentive Payment System (MIPS) track, while a smaller percentage will qualify to participate in the Alternative Payment Models (APM) track if considered an “advanced APM.” It is important to note that those APM models which are not considered “advanced” by CMS will still participate in the MIPS track.

Learn more about APMs here.

The MIPS track

You will receive a performance-based adjustment to your Medicare fee schedule in 2020 based on your performance in 2018. The amount of the adjustment, either positive, negative or neutral, is based on an eligible clinician or group’s Composite Performance Score (CPS). The CPS is calculated using data across four categories of measurement:

  1. Quality
  2. Advancing Care Information
  3. Clinical Practice Improvement Activities (commonly referred to as Improvement Activities)
  4. Resource Use (cost)

See the weighted breakdown by category per program year below. To learn more about MIPS scoring, click here.

Calculating Your MIPS Score

How do I avoid a negative payment adjustment?

For the 2018 performance year, CMS extended a portion of the “pick your pace” program, allowing clinicians to submit just 90-days of performance data for the required measures in the Advancing Care Information and Improvement Activities categories. However, clinicians will need to report data on all required measures in the Quality category for the full performance year (12 months).

CMS will also score and measure the Cost Category for the full 12 month period as well. Since CMS gathers the Cost Category information through Medicare claims data, no additional submission mechanism is required. If you do not participate in MIPS in 2018 you could be faced with a 5% penalty.

Individual vs. Group Reporting

Eligible clinicians have the option to report as an individual, within a group, or within a virtual group. If reporting as an individual (single NPI tied to a single TIN), eligible clinicians can send individual data for each of the MIPS categories through their EHR, registry, QCDR, or via attestation and will receive a single composite performance score. CMS will also accept quality data through routine Medicare claims processing, if applicable.

Eligible clinicians can also submit data as a group, which CMS defines as a single Taxpayer Identification Number (TIN) with 2 or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their National Provider Identifiers (NPI), who have reassigned their Medicare billing rights to the TIN. Participants will be scored as a group and will receive one payment adjustment based on aggregate performance. Group-level data can be submitted for each MIPS category through the CMS web interface (optional for groups of 25+), an EHR system, registry, QCDR, or by attestation.

The third option, new to the MIPS program in 2018, is participating via a virtual group. A Virtual Group is defined as a combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of 10 or fewer eligible clinicians that elect to form a virtual group for a performance period for a year. There is currently no limit on the number of TINs that can participate in a virtual group (i.e. one provider might have multiple TINs from multiple practice locations and can form a virtual group as a solo practitioner). Virtual Groups bring additional flexibility to the program, allowing clinicians to participate in MIPS with their peers, regardless of their geographical proximity or specialty. Those wishing to participate in a MIPS Virtual Group must make a formal election with CMS by December 31, 2017. Learn more about virtual groups here.

Accepted MIPS Reporting Mechanisms

Selecting Measures

The aim of the MIPS program is to provide clinicians and groups with the flexibility to select measures that best suit their practice. Providers can select measures to report on in each category from the list of CMS-approved MIPS measures, which can be found on the QPP website here (https://goo.gl/yWMJJJ). Alternatively, clinicians and groups can select to report specialized measures in the Quality Performance Category developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDRs were established in 2014 as a part of the PQRS program and have the ability to develop and support specialty-specific measure sets that can be reported in lieu of the traditional MIPS measures. QCDR measures must be approved each year by CMS. The 2018 list of approved QCDR measures has not yet been published by the agency. Check back for updates.

Quality Category

Eligible clinicians are required to report 6 measures of their choosing for the quality category. One of those measures must be an outcome measure. If no outcome measure is available, a ‘high priority’ measure must be reported in its place. High priority measures are contained in the following domains: appropriate use, patient safety, efficiency, patient experience, and care coordination.

What are specialty measure sets?

CMS developed specialty measure sets as a part of the available MIPS measures in the Quality Category. Participating clinicians must choose six measures to report within their specialty set. If there are fewer than six Quality measures to choose from in a specialty set, the clinician or group must complete all available measures contained in the set.

Clinical Practice Improvement Activities (IA)

The IA category requires clinicians to participate in a combination of measures totaling forty points to fully satisfy reporting requirements. Activities that are weighted “high” are worth 20 points, while “medium” weighted activities are valued at 10 points. Clinicians and groups considered non-patient facing and those practices with 15 or fewer eligible providers and/or clinicians practicing in rural and health professional shortage areas may faced reduced reporting requirements. Learn more about these special exemption statuses here.

Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at info@surveyvitals.com to learn more.

Requirements or MIPS Participation by Category

Advancing Care Information

The Advancing Care Information category places an emphasis on interoperability and patient engagement with certified EHR technology. Eligible clinicians must meet five required measures in the Advancing Care Information category, with the opportunity to earn additional bonus points for up to 9 total measures. Clinicians will report based on the level of their certified electronic health record. In 2018, CMS will allow organizations to use either the 2014 or 2015 Edition CEHRT, but will grant a bonus for using the 2015 Edition CEHRT.

For anesthesia clients

In addition to supporting our clients in the Improvement Activities category, SurveyVitals anticipates being able to help anesthesia clients who utilize a Qualified Clinical Data Registry (QCDR) meet a measure in the Quality performance category. Learn more here.

  • – AQI 48 (anesthesia patient experience)

How is MIPS different in 2018?

Category 2017 2018
Low volume threshold. Clinicians that bill Medicare Part B more than $30,000 in allowed charges per year or provide care for more than 100 unique Medicare patients annually are eligible to participate in MIPS. Clinicians that bill Medicare Part B more than $90,000 in allowed charges per year or provide care for more than 200 unique Medicare patients annually are eligible to participate in MIPS.
Performance Period Adjustments Quality: 90 days Cost: 90 days Advancing Care Information: 90 days Improvement Activities: 90 days Quality: Full year Cost: Full year Advancing Care Information: 90 days Improvement Activities: 90 days
Virtual Groups No virtual groups A Virtual Group is defined as a combination of 2 or more TINS who choose to participate together in MIPS. Virtual Groups have the flexibility to work with other groups or types of practices from any location. This could open the door for more clinicians to join the program and work with their peers, regardless of their geographical proximity.
Small Practice Bonus N/A Small practices of 15 or fewer clinicians are eligible to receive five points to their score to help them meet MIPS requirements, as long as they submit data on at least one performance category in an applicable performance period.
Complex Care Bonus N/A Clinicians who provide medically complex care could be eligible to receive an adjustment by adding the average Hierarchical Conditions Category (HCC) risk score to their final score. Generally, this award is be between 1 to 3 points, based on the complexity of care provided, as determined by CMS.
EHR Requirements N/A Facility-based physicians, such as hospitalists, have the option to use facility-based scoring. CMS aligns facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set will be applied to a clinician’s Quality and Cost performance categories.
Facility-Based Physicians N/A Facility-based physicians, such as hospitalists, have the option to use facility-based scoring. CMS aligns facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set will be applied to a clinician’s Quality and Cost performance categories.

Does SurveyVitals administer CAHPS for MIPS?

Yes! SurveyVitals, with our CMS-approved vendor partner, Novaetus Inc., is ready to administer CAHPS for MIPS on behalf of your organization in 2018.

Contact us at info@surveyvitals.com to learn more about our CAHPS program.

Interested in meeting measures with SurveyVitals

Want to learn how SurveyVitals can help you prepare for MIPS? Subscribe to our MIPS update list below or email us at support@surveyvitals.com. You can also send us a message using the blue chat icon below to speak to a member of our support team.

*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.

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June 4th, 2018 Categories: Ambulatory and Outpatient Surgery, Anesthesia, CAHPS Surveys, Emergency Medicine, MIPS, Neonatology, Outpatient Practice, Radiology, Urgent Care

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MIPS 101 for Anesthesia Providers

MIPS anesthesiologist

Are you an anesthesia provider participating in the Merit-Based Incentive Payment System (MIPS)? Let us tell you how the SurveyVitals solution might help you fulfill certain reporting requirements.

What is MIPS?

The Merit Incentive Payment System (MIPS) is one of two tracks in the QPP, the quality payment incentive program implemented by CMS. A small percentage of clinicians will qualify to participate in the Alternative Payment Models (APM) track, but most anesthesiologists will fall under the MIPS track.

You will receive a performance-based adjustment to your Medicare fee schedule in 2020 based on your MIPS performance in 2018. The amount of the adjustment, either positive, negative, or neutral, is based on an eligible clinician or group’s Composite Performance Score (CPS). The CPS is calculated using data across four categories of measurement.

Who participates?

If you bill Medicare Part B more than $90,000 in allowed charges per year and provide care for more than 200 unique Medicare patients a year, then you are part of the QPP. If you do not meet this threshold, you could be exempt from participating in the program in 2018 under the the low-volume threshold exemption. To determine if you are required to participate in MIPS, CMS has provided a resource to check your status by entering your NPI into an eligibility “calculator.”

How are measures reported?

Anesthesiologists have the option to report as an individual, within a group, or within a virtual group.

Individual Single NPI tied to a single Tax Identification Number (TIN)
Group Single TIN with two or more eligible clinicians, including at least one MIPS-eligible clinician, as identified by their National Provider Identifiers (NPIs), who have reassigned their Medicare billing rights to the TIN
Virtual Group Combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of ten or fewer eligible clinicians

Reporting mechanisms vary based on reporting type and measure category. You can find more information on reporting mechanisms here.

How are measures selected?

Anesthesia providers and groups can select measures from the list of CMS-approved MIPS measures at the QPP website. Alternatively, they may select to report on Quality performance using specialized measures developed by a Qualified Clinical Data Registry (QCDR) of their choosing. QCDR measures must be approved each year by CMS. The 2018 list of approved measures can be found here.

Quality Category

Anesthesiologists are required to report on six measures of their choosing for the quality category. One of those measures must be an outcome measure.

SurveyVitals is equipped to help anesthesia clients utilizing a QCDR to meet an outcome measure (AQI48 – Patient-Reported Experience with Anesthesia) in the Quality category. You must sign a disclaimer in order to report your patient experience data to a QCDR. View the reporting checklist, quick facts, and important deadlines here.

Improvement Activities (IA) Category

Anesthesia providers are required to participate in a combination of IA measures totaling 40 points. “High-weighted” activities are worth 20 points, while “medium-weighted” activities are valued at ten points. Your SurveyVitals solution can help you satisfy measures in the IA category. Download our “Road-Map to Improvement Activities” or contact us at info@surveyvitals.com to learn more.

Reporting requirements for Improvement Activities are reduced for non-patient facing clinicians, which are defined as either:

Those considered non-patient facing must participate in one high-weighted activity or two medium-weighted activities to satisfy the Improvement Activities category (for a total of 20 points rather than 40).

Always remember to check the eligibility calculator on the QPP website to confirm you are considered non-patient facing.

Promoting Interoperability Category

The Promoting Interoperability (formerly Advancing Care Information) category places an emphasis on interoperability and patient engagement with certified EHR technology. Eligible clinicians must meet five required measures in the Promoting Interoperability category, with the opportunity to earn additional bonus points for up to 9 total measures.

Many anesthesiologists are exempt from fulfilling the Promoting Interoperability requirements due to having hospital-based special status. CMS defines a hospital-based clinician as a MIPS-eligible clinician who furnishes 75 percent or more of his or her professional services in a site of service identified by the following Place of Service (POS) codes used in HIPAA standard transactions:

Always remember to check the eligibility calculator on the QPP website to confirm you are considered hospital-based.

Cost Category

The score for the Cost category is calculated using administrative claims data. No data submission is required.

Does SurveyVitals administer CAHPS for MIPS?

Yes! SurveyVitalsis ready to administer CAHPS for MIPS on behalf of your organization in 2018. Contact us at support@surveyvitals.com to learn more about our CAHPS program.

Interested in meeting MIPS measures with SurveyVitals?

Want to learn how SurveyVitals can help you prepare for MIPS? Subscribe to our MIPS update list below or email us at support@surveyvitals.com. You can also send us a message using the blue chat icon below to speak to a member of our support team.

*Note: Information and program details are based solely upon SurveyVitals’ experience with MACRA and our interpretation of CMS rule-making and policy statements. The information presented does not reflect the views or policies of CMS or any other governmental agency and is not to be construed as practice management advice.

June 3rd, 2018 Categories: Anesthesia, MIPS

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New Data Submission Interface for Quality Payment Program

New Data Submission Interface

On January 2, the Centers for Medicare and Medicaid (CMS) launched a new data submission system for groups and clinicians participating in the Quality Payment Program.

Here are some key points:

Clinicians now submit all their 2017 performance data in the same place.

Previously, under the various CMS legacy programs, clinicians had to use multiple mechanisms to submit performance data. CMS has now consolidated the data submission process to a single access point via an online portal, making it easier for clinicians and vendors to submit data.

The submission period for the 2017 QPP performance year runs from January 2, 2018, to March 31, 2018.

For groups using the CMS Web Interface, the submission period runs from January 22, 2018 to March 16, 2018.

How to submit performance data?

To submit performance data, clinicians must visit the QPP website. Once on the QPP website, users can login by entering their EIDM User ID and password. Users may have used this ID and password in the past to login to the CMS Enterprise Portal.

If you don’t have an EIDM User ID and password, you can create an account on the CMS Enterprise website.

In the portal, clinicians have the option to choose between multiple data submission options, including Qualified Clinical Data Registries (QCDRs), qualified registries, attestation, or the CMS Web Interface.

Data can be uploaded incrementally throughout the submission period. Groups and clinicians are not required to upload all of their data at once. However, all performance data must be uploaded before the submission period deadline.

For Merit-based Incentive Payment System (MIPS) participants, real-time initial scoring updates will appear as performance data is tallied on the site. This scoring may change as new data is uploaded, or if new benchmarks take effect. Note that special status, Alternative Payment Model (APM) status, and Qualifying APM Participant status (QP), will not initially appear in each category score.

Final scores will appear after the submission period closes.

For more information about the Quality Payment Program, see our guide.

January 3rd, 2018 Categories: Anesthesia, featured, MIPS, Outpatient Practice

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Virtual Groups for MIPS 2018

MIPS Virtual Groups 2018

An important deadline is approaching for groups and physicians participating in MIPS in 2018. December 31 marks the last day for clinicians to notify CMS that they are electing to participate in a Virtual Group for MIPS 2018.

If you aren’t familiar with Virtual Groups, you aren’t alone. Virtual Groups are a brand new option for MIPS participants in 2018 (Just one of several changes that CMS is implementing – check the details in this blog post). These Virtual Groups allow clinicians from around the country to team up with each other to help satisfy MIPS requirements.

To help groups and clinicians prepare to participate in a Virtual Group in 2018, we have compiled some FAQ about the program from the final rule published by CMS.

What is a Virtual Group?

A Virtual Group is defined as a combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of 10 or fewer eligible clinicians that elect to form a virtual group for a performance period for a year. There is currently no limit on the number of TINs that can participate in a virtual group (i.e. one provider might have multiple TINs from multiple practice locations and can form a virtual group as a solo practitioner). Virtual Groups have the flexibility to work with other groups or types of practices from any location. This could open the door for more clinicians to join the program and work with their peers, regardless of their geographical proximity.

What is the deadline to notify CMS about a Virtual Group?

Individual MIPS eligible clinicians or groups electing to be in a Virtual Group must make their election prior to the start of the applicable performance period and cannot change their election during the performance period. The deadline for such an election was recently extended to December 31, 2017.

Can me or my group participate in multiple Virtual Groups?

No. Each eligible clinician or group may only elect to be in one Virtual Group at a time. In the case of a group, the election applies to all MIPS eligible clinicians (NPIs) in the group.

How are Virtual Groups identified for reporting purposes?

Each MIPS eligible clinician who is part of a Virtual Group will be identified by a unique Virtual Group participant identifier. This unique identifier is composed of a combination of the following identifiers: 1) Virtual Group identifier (established by CMS) 2) TIN number and 3) NPI number.

Are there different reporting requirements for Virtual Groups?

Virtual Groups have the same reporting requirements as other MIPS participants. There are still special exceptions for non-patient facing practices, small practices, rural practices, and practices with HSPA status. For the most part, policies that apply to regular group reporting also apply to virtual group reporting.

What are the steps to form a Virtual Group?

1. Determining eligibility – Contact TA representative

2. Executing formal written agreements – TINs comprising a virtual group must establish a written formal agreement between each member of a virtual group prior to election

3. Submitting formal election registration – On behalf of the virtual group, the official designated virtual group representative must submit an election by December 31, 2017. – Such an election will occur via email to the Quality Payment Program Service Center using the following email address: MIPS_VirtualGroups@cms.hhs.gov – Submission must include, at a minimum, information pertaining to each TIN and NPI associated with the virtual group and contact information for the virtual group representative. – Each TIN associated w/the virtual group – Each NPI associated with the virtual group – Name of the virtual group representative – Affiliation of the virtual group representative to the virtual group – Contact information for the virtual group representative – Confirmation through acknowledgement that a formal written agreement has been established between each member of the virtual group (solo practitioner or group) prior to election and each eligible clinician is aware of participating in a MIPS virtual group for an applicable performance period. – Each party must retain a copy of the virtual groups written agreement and is subject to the MIPS data validation and audit process.

4. Allocating resources for virtual group implementation and related activities

If approved to participate in a virtual group, CMS will contact your group representative via email to notify them of their status and issue a virtual group identifier for performance.

How to formally elect to participate in a Virtual Group?

CMS released a Virtual Group Toolkit to get started with the election process. It can be downloaded here.

Can SurveyVitals help meet MIPS requirements?

Yes! SurveyVitals is a CMS-certified CAHPS vendor ready to administer CAHPS for MIPS. Additionally, SurveyVitals can help organizations meet 6 different Improvement Activities to satisfy MIPS requirements. And if you are an anesthesiologist, we can also help you meet a measure in the Quality Category via QCDR reporting.

Where to start?

Schedule a demo today to learn more about how SurveyVitals can help with MIPS in 2018.

November 27th, 2017 Categories: featured, MIPS

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Do Not Miss This MIPS Reporting Deadline

MIPS 2017
Avoiding A MIPS Negative Payment Adjustment

October 2nd marks the very last day for eligible clinicians to start collecting MIPS data for partial year submission. If this fall reporting deadline is missed, clinicians and/or groups will not be eligible to receive a positive payment adjustment in 2019. Rather, they will be faced with two outcomes:

  1. Submit the minimum amount of data and receive a neutral payment adjustment
  2. Submit no data and receive a downward payment adjustment (up to -4%)

Given the flexibility of the MIPS program this year, it would be a missed opportunity for groups and clinicians to submit just 90-days of performance data to Medicare to earn a moderate positive payment adjustment – maybe even the max adjustment – in 2019. Learn more about MIPS and “Pick Your Pace” here.

MIPS Pick Your Pace

While it might seem a bit daunting if you haven’t started, there is still a short window of time for you and/or your group to select the required number of measures and get up and running before the partial submission deadline passes.

Partial Submission Pace

In order to participate in the ‘partial submission’ pace as outlined by the Centers for Medicare and Medicaid Services, eligible clinicians and groups will need to submit 90 consecutive days worth of performance data to Medicare across the following MIPS scoring categories:

For clinicians in rural or health professional shortage areas, or for those clinicians considered non-patient facing or “hospital-based,” you may face reduced reporting requirements. Learn more about these special status groups under MIPS here.

Selecting A Submission Mechanism and Measures

Submission methods may vary based on the measure. CMS has provided this chart to help groups and clinicians find the right reporting method for each category.

MIPS Submission Methods
Meeting Measures with SurveyVitals

Finally, SurveyVitals can help you meet a number of measures in the Improvement Activities category, including a high-weight activity. Additionally, SurveyVitals can submit data to your QCDR and help you administer CAHPS for MIPS. Want to learn more about meeting MIPS measures with SurveyVitals? Contact us at info@surveyvitals.com

September 15th, 2017 Categories: Anesthesia, featured, MIPS, Outpatient Practice

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8 Takeaways from CMS Proposed Rule for Changes to MIPS in 2018

MIPS Year 2 Proposed Rule
Ready or not: MIPS 2018 Proposed Rule

Not fully prepared for MIPS and feeling slightly overwhelmed? You’re not alone. According to a recent report, only 8 percent of physicians feel highly knowledgeable about the MIPS program halfway through the first performance year. Even more concerning, a reported 41 percent of physicians interviewed had never even heard of MACRA or the MIPS program. Which is why it might surprise you that the Centers for Medicare and Medicaid Services (CMS) already released a long list of changes in the proposed rule for MIPS 2018.

However, most clinicians will likely be relieved to learn of the new changes. With most of the changes aimed at aiding small practices, many of which have been struggling to adjust to the transition. CMS also opted to loosen some reporting restrictions and provide for new modes of participation in the proposed rule.

So what exactly can you expect heading into MIPS 2018? Checkout our wrap-up of key takeaways from the Proposed Rule:

1. Small practices will see some of the biggest changes

Small practices will be the most affected by the proposed changes. CMS is seeking to expand the number of clinicians who will be exempt from MIPS 2018 by increasing the low-volume threshold. In 2017, clinicians that bill Medicare Part B more than $30,000 in allowed charges per year or provide care for more than 100 unique Medicare patients annually are eligible to participate. In 2018, however, the number of clinicians exempt from MIPS will increase. The new threshold will jump to $90,000 in Part B payments or 200 unique Medicare patients annually.

2. Performance Period Adjustments

CMS is lengthening the performance period for the Quality and Cost categories from 90 days in 2017 to the full year in MIPS 2018, though CMS will not use the Cost performance scores for final score determination. For the Improvement Activities and Advancing Care Information (ACI) categories, however, the 90-day performance period will remain the same.

3. Clinicians will have the option to join Virtual Groups

Virtual groups are new to the MIPS 2018 program year. A Virtual Group is defined as a combination of 2 or more TINS who choose to participate together in MIPS. Virtual Groups have the flexibility to work with other groups or types of practices from any location. This could open the door for more clinicians to join the program and work with their peers, regardless of their geographical proximity. Learn more about Virtual Groups.

4. Small Practice Bonus

Small practices of 15 or fewer clinicians will be eligible to receive a Small Practice Bonus under the proposed rule. This bonus would add five points to a group’s score to help them meet MIPS requirements, as long as they submit data on at least one performance category in an applicable performance period.

5. Complex Care Bonus

Clinicians who provide medically complex care could be eligible to receive an adjustment by adding the average Hierarchical Conditions Category (HCC) risk score to their final MIPS 2018 score. Generally, this award would be between 1 to 3 points, based on the complexity of care provided, as determined by CMS.

6. EHR Requirements Slowed

In another reversal, CMS will allow the continued use of the 2014-edition Certified Electronic Health Record Technology in MIPS 2018, which was set to be phased out. This again is aimed at easing the burden for practices that are struggling to keep up with all the changes. Currently, many practices don’t have the resources or access to the 2015 CEHRT, which makes the transition very difficult. To encourage use of new EHR technology, CMS has proposed a scoring bonus for practices that use 2015 Edition CEHRT exclusively.

7. New Scoring Options for Facility-Based Physicians

Facility-based physicians, such as hospitalists, will have the option to use facility-based scoring for reporting. A facility-based clinician is defined as a clinician who provides at least 75 percent of their services in an inpatient hospital or emergency room setting. This includes many anesthesiologists and nurse anesthetists. Facility-based groups are defined as groups in which at least 75 percent of the individuals are facility-based clinicians. CMS hopes to align facility-based scoring with the Hospital Value-Based Purchasing (VBP) Program. The total performance score for the hospital VBP measure set would be applied to a clinician’s Quality and Cost performance categories.

8. Multiple reporting mechanisms per category allowed

For the first program year, CMS stipulated that for clinicians participating in MIPS, only one reporting mechanism is allowed per performance category (i.e. if a clinician is using a QCDR to report on a measure in the quality category, all measures in the quality category must be reported via QCDR). The Proposed Rule does away with this requirement and allows clinicians and groups to use whatever combination of reporting mechanisms that best suits their needs, regardless of category.

It is important to note that these changes to the MIPS program for 2018 are proposed changes. As a part of the federal rulemaking process, CMS is currently soliciting feedback from stakeholders and will issue a final rule in the coming months, which could include changes. Stay tuned!

To explore the proposed changes in depth, read the proposed rule here or checkout the CMS fact sheet.

Interested in learning more about SurveyVitals? Click here to sign-up for a free, no hassle product.

July 27th, 2017 Categories: Anesthesia, featured, MIPS, Outpatient Practice

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Accessing Your PQRS Feedback Report

Update: PQRS feedback reports for program year 2015 are now available (via CMS, 9/26/16). 2017 PQRS negative payment adjustment letters will be distributed shortly. Informal review will be open until November 30, 2016 at 11:59 P.M. EST.

What is PQRS?

The Physician Quality Reporting System (PQRS) is a program established and managed by the Centers for Medicare and Medicaid Services (CMS). The federal initiative aims to incentivize the reporting of quality data by individual Eligible Professionals (EPs) and group practices to Medicare by tying it to reimbursement rates. As all individual EP’s and group practices likely know by now, failing to satisfactorily report PQRS data will result in a negative payment adjustment under the Medicare Physician Fee Schedule (PFS). Those who reported satisfactorily for program year 2015 will avoid the negative 2% payment adjustment in 2017.

When will PQRS feedback reports for program year 2015 be available?

CMS announced that the PQRS feedback reports for program year 2015 will be available sometime this month, September 2016. These reports indicate whether or not your practice met all reporting requirements and if you’ll be subject to the future negative payment adjustment. Additionally, CMS announced that payment adjustment letters are projected to be sent in late summer or early fall. We recommend reviewing your feedback report as soon as made available to ensure you have enough time to properly review and request an informal review should your organization determine there was an error or CMS incorrectly assessed your practice. (Check back for updates!)

How to access your PQRS Feedback Report

To access your PQRS feedback report, you will need an Enterprise Identity Management System (EIDM) account, which can be established using the CMS Enterprise Portal at https://portal.cms.gov. Once logged in, select the “PV-PQRS” tab and the “Feedback Reports” option to view your reports. The PQRS feedback can be viewed at three different levels: provider level, reporting mechanism level, and PQRS measure level. Detailed user guides can be found on the QualityNet portal page.

Quality Resource and Usage Reports

In addition to PQRS feedback reports, Quality and Resource Use Reports(QRURs) are also made available through the CMS Enterprise Portal. These reports show performance on all of the quality and cost measures at the Taxpayer Identification Number (TIN) level. These results are used by CMS to calculate the 2017 Medicare Value-Based Payment Modifier. CMS makes two types of QRURs available: the Mid-Year QRUR and the Annual QRUR. The Mid-Year QRUR (MY-QRURs) was made available in April 2016 and was for informational purposes only. Groups of 2 or more EPs and physicians who are subject to the 2017 Value-Based Payment Modifier can use the Annual QRUR to see how the value modifier will apply to the Medicare PFS physician payments. The QRUR is for informational purposes for all other groups and solo practitioners.

Requesting an informal review

If you believe that there was an error or a negative payment adjustment was applied incorrectly, you can request an informal review of the payment adjustment determination. If the review process concludes that satisfactory reporting actually occurred, CMS will reverse the application of the negative payment adjustment. Unfortunately, the informal review decision is final. CMS has no formal appeals process in place at this time.

To submit an informal review request, visit the Quality Reporting Communication Support Page (CSP). Informal review requests for 2015 may be submitted in the fall of 2016, and CMS will announce when this page is available. Remember, the informal review period is limited so review your feedback and get your requests in as soon as the page is available.

September 21st, 2016 Categories: featured, MIPS

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Is GPRO the way to go?

At SurveyVitals, we believe there’s great value in the Qualified Clinical Data Registry (QCDR) quality data reporting option. In 2015, only Eligible Professionals (EPs) can report through a QCDR. Some great news is that CMS recently shared they’re adding a reporting option allowing group practices to report quality measure data using a QCDR for 2016. Please read below for more detail about the differences between GPRO and QCDR.

By now, everyone understands that physicians who don’t report adequate quality measures in 2015 will see a 2% penalty in 2017. There are still questions, however, about the best way to report your quality data to CMS, especially for outpatient practices. And while the date to adjust your 2015 reporting mechanism has passed, we’d like to share some information as you start thinking about your plan for 2016.

At the highest level, you must decide whether to report as an individual EP (Eligible Professionals) or as part of a group. There are pros and cons to each, although SurveyVitals® recommends the individual EP route. Among other reasons, this option allows you to submit quality data through a QCDR (Qualified Clinical Data Registry) if one exists for your specialty and avoids the CAHPS for PQRS survey.

GPRO, the Group Practice Reporting Option, is another method to submit your quality data, but has numerous CMS requirements. Here are a few things we’d like our clients to know about GPRO for 2015:

Choosing whether to report quality measures as a group or by individual can be a complicated decision when you factor in eligibility and reporting requirements, and here’s why we recommend individual reporting:

As we announced earlier this year, our Patient Satisfaction Questionnaires (APSQ, SPSQ, or HSQ), fulfills measures for many QCDRs. We’re working to get a patient satisfaction measure included in other QCDRs for 2016. We expect that the list will continue to grow, so contact us if you’d like additional information on the measures SurveyVitals can help you meet for each QCDR.

If you don’t report through a QCDR, it is still beneficial to report individually since the measures that must be reported to CMS are the same. Although some variations exist in the methods (for 2015, claims-based for individual reporting and web interface for GPRO 25+ EPs), you can avoid the CAHPS for PQRS survey requirement and its expense. Additionally, the Value-Based Payment Modifier (VM) is not affected by reporting individually since the VM is calculated by TIN.

* In late October 2015, CMS released some preliminary information regarding PQRS for 2016. From the CMS website: “CMS makes changes to the PQRS measure set to add measures where gaps exist, as well as to eliminate measures that are topped out, duplicative, or are being replaced with a more robust measure. There will be 281 measures in the PQRS measure set and 18 measures in the GPRO Web Interface for 2016. Also, as recently authorized under MACRA, CMS is adding a reporting option that will allow group practices to report quality measure data using a Qualified Clinical Data Registry (QCDR).

We’ll wait for the final 2016 PQRS webpage to become available (typically by January 1, 2016) to see how this plays out, and SurveyVitals will attempt to stay on top of these ever changing requirements in order to provide the most value to our clients. Stay tuned for more!

November 13th, 2015 Categories: CAHPS Surveys, featured, MIPS

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To GPRO, or not to GPRO, that is the question for anesthesiology providers

By now, everyone understands that physicians who don’t report adequate quality measures in 2015 will see a 2% penalty in 2017. There are still questions, however, about the best way to report your quality data to CMS, especially for anesthesiology providers. And while the date to adjust your 2015 reporting mechanism has passed, we’d like to share some information as you start thinking about your plan for 2016.

At the highest level, you must decide whether to report as an individual EP (Eligible Provider) or as part of a group. There are pros and cons to each, although SurveyVitals® recommends the individual EP route. Among other reasons, this option allows you to submit quality data through a QCDR (Qualified Clinical Data Registry) and avoid the CAHPS for PQRS survey.

GPRO, the Group Practice Reporting Option, is another method to submit your quality data, but has numerous CMS requirements. Here are a few things we’d like our clients to know about GPRO:

Choosing whether to report quality measures as a group or by individual can be a complicated decision when you factor in eligibility and reporting requirements, and here’s why we recommend individual reporting:

As we announced earlier this year, our Anesthesia Patient Satisfaction Questionnaire, the APSQ, fulfills measure #16 for NACOR, the Composite Patient Experience, and counts as an outcome measure as well. We’re also working to get a patient satisfaction measure included in other QCDRs like ABG and ASPIRE for 2016. We expect that list will continue to grow, so contact us if you’d like additional information on the measures SurveyVitals can help you meet for each QCDR.

If you don’t report through a QCDR, it is still beneficial to report individually since the measures that must be reported to CMS are the same. Although some variations exist in the methods (for 2015, claims-based for individual reporting and web interface for GPRO 25+ EPs), you can avoid the CAHPS for PQRS survey requirement and its expense. Additionally, the Value-Based Payment Modifier (VM) is not affected by reporting individually since the VM is calculated by TIN.

SurveyVitals will attempt to stay on top of these ever changing requirements in order to provide the most value to our clients. Stay tuned for more!

October 7th, 2015 Categories: Anesthesia, CAHPS Surveys, featured, MIPS

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Avoid the 2% penalty

NACOR_QCDR

An easier, more valuable way to satisfy the PQRS reporting requirement

You’re probably familiar with the burden of PQRS reporting, and know that CMS has instituted a 2% penalty (to be levied in 2017) for group practices and individual EPs (eligible professionals) who do not report adequate quality measures in 2015.

Did you know that it’s not necessary to administer the CAHPS for PQRS (an expensive, 92-question, paper-only survey) if you submit your measures through NACOR, the National Anesthesia Clinical Outcomes Registry?

NACOR, maintained by the Anesthesia Quality Institute (AQI), has been designated as a Qualified Clinical Data Registry (QCDR) by CMS. You’re required to report 9 measures across 3 domains, including 2 outcome measures.

We’re pleased to announce that your SurveyVitals solution fulfills measure #16, the Composite Patient Experience, and counts as an outcome measure as well.

Please contact us if you’d like SurveyVitals to submit your quality data to NACOR on a monthly basis.

Note: This is not an option for GPRO-registered EPs in 2015, but you can opt out of GPRO in 2016 if you choose to submit your data to NACOR in 2016.

More Info on PQRS from the CMS website

PQRS is a reporting program that uses a combination of incentive payments and negative payment adjustments to promote reporting of quality information by EPs. Read more.

More Info on QCDR Reporting for 2015

NACOR was approved as a QCDR for the CMS PQRS in 2014. Remember, for 2015, all Eligible Professionals must report on 9 measures (across 3 domains), 2 of which must be outcome measures. Read more.


July 13th, 2015 Categories: featured, MIPS

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