Celebrate National Healthcare Quality Week with SurveyVitals!

October 21-27 is National Healthcare Quality Week. This week is dedicated by the National Association for Healthcare Quality to celebrating the contributions professionals have made to improve healthcare quality.

At SurveyVitals, we understand the value of improving patient safety and outcomes, performance and process improvement, and utilizing data analysis to drive improvement. In fact, these are the things that have shaped our solution. Since 2002, we have built into our system tools and features that help our clients make data-driven decisions to provide the highest quality of care to their patients. We have worked with industry experts and listened to the needs of our clients to be sure our solution helps achieve quality improvement goals.

We want to thank all of our clients for your hard work in providing a higher quality of care and better patient experience. Did you know there are a few ways you can celebrate with SurveyVitals?

  • Recognize top performers with SurveyVitals’ Friday kudos emails (SPSQ only), which spotlight weekly top performing staff members in your organization.
  • Celebrate your organization’s Top 10% Awards. These awards represent exceptional work toward higher healthcare quality and deserve special recognition! Top 10% Awards are awarded quarterly and annually to practices who rank in the top 10% for composite score for APSQ and SPSQ surveys.
  • Try out Challenge Mode in your portal. Issue a challenge to providers in your organization in any questions or question areas. Offer special recognition for whoever tops the leaderboard. Nothing encourages a higher quality of care quite like a bit of friendly competition!
  • Enroll providers in bi-weekly positive kudos emails.
  • Share your verified ratings online! With the new Public Review feature, you can proudly display verified patient ratings and comments to show the community the level of care you provide.

How does your organization plan on celebrating National Healthcare Quality Week?

October 25th, 2018 Categories: featured, Patient Experience, Product Features

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CMS Releases 2019 MIPS Proposed Rule Changes

Are you participating in MIPS? If so, you should know that there are going to be some changes to the program in 2019. CMS has been collecting stakeholder feedback about MIPS over the past couple years, which they’ve used to continue to develop the program. While MIPS will look very familiar next year, there are a few possible changes that could have a big impact on you and your organization. Here are some of the highlights from the new proposed rule:

New clinician types

CMS proposed to add the following clinician types to MIPS:

  • Physical therapist
  • Occupational therapist
  • Clinical social worker
  • Clinical psychologist

Clinician types that were eligible to participate in 2018 remain in the program for the 2019 performance year.

Some groups and clinicians could choose to opt-in

Clinicians and groups would have the choice to opt-in to MIPS if they met or exceeded one or two, but not all three, of the low-volume threshold criterion.

Expanded low-volume threshold

The low-volume threshold would have an additional category in 2019, so that groups and clinicians would qualify to be excluded if from MIPS if they met any of these three criterion:

  • Have less than or equal to $90k in Part B allowed charges for covered professional services
  • Provide care to 200 or less beneficiaries
  • Provide 200 or less covered professional services under the Physician Fee Schedule (PFS)
More flexible submission mechanisms

Individual clinicians would be able to submit a single measure via multiple collection types, such as MIPS CQM, eCQM, QCDR measures and Medicare Part B claims measures. They would be scored on the data submission with the greatest number of measure achievement points.

Additionally, groups and virtual groups would be able to use multiple collection types.

Unchanged performance period

In the proposed rule, the MIPS performance period would remain the same in 2019 as in 2018:

  • Quality Category: 12 months
  • Cost Category: 12 months
  • Improvement Activities: 90 days
  • Promoting Interoperability: 90 days

Those are some key takeaways for what to expect heading into year 3. A full breakdown of each proposed MIPS changes can be found in the table below.

CMS is currently accepting feedback on the proposed rule at regulations.gov. The 60-day comment period will end on September 10, 2018. It is expected CMS will release the final rule in late fall. Check the SurveyVitals blog for updates or subscribe to our MIPS list here.

For more information about how SurveyVitals can help you complete your MIPS requirements, email us at info@surveyvitals.com or sign up for a quick overview. Also feel free to chat with us using the blue chat icon in the bottom-right corner of your screen at anytime.

Policy Area Current Year 2 (Final Rule CY 2018) Year 3 (Proposed Rule CY 2019)
MIPS Eligibility Eligible clinician types include:
  • Physician
  • Physician assistant
  • Nurse practitioner
  • Clinical Nurse specialist
  • Certified registered nurse anesthetist
  • A group that includes such professionals (required by statute)
Eligible clinician types include:

Eligible clinician types remain the same as Year 2 with the following additions:

  • Physical therapist
  • Occupational therapist
  • Clinical social worker
  • Clinical psychologist
Low-Volume Threshold (LVT)
  • To be excluded from MIPS, clinicians and groups must meet one of the following two criterion: have ≤ $90K in Part B allowed charges for covered professional services OR provide care to ≤ 200 beneficiaries.
  • The low-volume threshold would include a third criterion for determining MIPS eligibility
  • To be excluded from MIPS, clinicians or groups would need to meet one of the following three criterion: have ≤ $90K in Part B allowed charges for covered professional services, provide care to ≤ 200 beneficiaries, OR provide ≤ 200 covered professional services under the Physician Fee Schedule (PFS)
  • Opt-in
  • Not Applicable
  • Starting in Year 3, clinicians or groups would be able to opt-in to MIPS if they meet or exceed one or two, but not all, of the low-volume threshold criterion
  • MIPS Determination Period Low Volume Threshold Determination Period:
    • First 12-month segment: Sept. 1, 2016 to Aug. 31, 2017 (including a 30-day claims run out)
    • Second 12-month segment: Sept. 1, 2017 to Aug. 31, 2018 (including a 30-day claims run out)
    • Note: If a clinician or group is identified as not exceeding the LVT during this time, they will be excluded regardless of the results of the second 12-month analysis
    Hospital-Based MIPS eligible clinician:
    • MIPS eligible clinician furnishing 75% or more of covered professional services in POS 19, POS 21, POS 22, or POS 23 based on claims for a period prior to the performance period
      • Claims will be used from September 1 of the calendar year, 2 years preceding the performance period through August 31 of the calendar year preceding the performance period; if not feasible, claims from a 12-month period close to this period will be used
    ASC-Based MIPS eligible clinician:
    • MIPS eligible clinician furnishing 75% or more of covered professional services in POS 24 based on claims for a period prior to the performance period
      • Claims will be used from September 1 of the calendar year 2 years preceding the performance period through August 31 of the calendar year preceding the performance period; if not feasible, claims from a 12-month period close to this period will be used
    Now referred to as MIPS Determination Period:
    • Created a streamlined and consistent “MIPS determination period” for different categories of clinicians, which will be used to determine the low-volume threshold and the following special statuses: non-patient facing, small practice, hospital-based, and ASC-based
      • First 12-month segment: Oct. 1, 2017 to Sept. 30, 2018 (including a 30-day claims run out)
      • Second 12-month segment: Oct. 1, 2018 to Sept. 30, 2019 (does not include a 30-day claims run out)
    • Hospital-based MIPS eligible clinician determinations would be based on claims from the MIPS determination period
    • ASC-based MIPS eligible clinician determinations would be based on claims from the MIPS determination period
    Virtual Groups In general, group policies apply to virtual groups, except:
    • A virtual group will be considered a small practice if it contains 15 or fewer clinicians
    • A virtual group will be designated as rural or HPSA practice if more that 75% of the NPIs billing under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA
    • A virtual group will be considered non-patient facing if more than 75% of the NPIs billing under the virtual group’s TINs meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period
    Virtual group election
    • Must be made by December 31 of the calendar year preceding the applicable performance period, and cannot be changed during the performance period
    • The election process can be broken into two stages: Stage 1 (which is optional) pertains to virtual group eligibility determinations, and stage 2 pertains to virtual group formation

    To meet the eligibility requirements, each member of a virtual group must establish a formal written agreement prior to an election

    • A designated virtual group representative must e-mail a virtual group election to MIPS_VirtualGroups@cms.hh s.gov by December 31 of the calendar year prior to the start of the applicable performance period
    Virtual group policies remain the same as Year 2, with the following change:
    • Beginning with 2019 the virtual group eligibility determination period aligns with the first segment of data analysis under the MIPS eligibility determination period.
      • For example: Oct. 1, 2017 to Sept. 30, 2018 (including a 30-day claims run out)
    Virtual Group election is the same as Year 2, with the following change:
    • As part of the virtual group eligibility determination period, TINs would be able to inquire about their TIN size prior to making an election during a 5- month timeframe, which would begin on August 1 and end on December 31 of a calendar year prior to the applicable performance period. TIN size inquiries would be made through the Quality Payment Program Service Center. Technical assistance resources already available to stakeholders would continue to be available

    The requirement for virtual groups to have a formal written agreement between each member of a virtual group remains the same for Year 3

    • For 2019, a designated virtual group representative must e-mail a virtual group election to MIPS_VirtualGroups@cms.hhs.g ov by December 31 of the calendar year prior to the start of the applicable performance period
    MIPS Performance Period Minimum Performance Period for each Performance Category:
    • Quality: 12-months
    • Cost: 12-months
    • Improvement Activities: 90-days
    • Promoting Interoperability: 90-days
    Minimum Performance Period for each Performance Category:
    • Same performance periods as in Year 2
    Quality Performance Category Weight to final score:
    • 50% in Year 2
    • The Quality performance category may be reweighted
      • If a score cannot be calculated due to no applicable and available measures
      • Due to extreme and uncontrollable circumstances

    For individual eligible clinicians, one submission mechanism must be selected:

    • Claims
    • QCDR
    • Qualified registry
    • EHR
    Groups and Virtual Groups must use one submission mechanism:
    • QCDR
    • Qualified registry
    • EHR
    • CMS Web Interface (groups of 25+)
    • CMS-Approved Survey Vendor for CAHPS for MIPS
    Data Completeness Requirements
    • Claims: 60% of Medicare Part B patients for the performance period
    • QCDR/Registry/EHR: 60% of clinician’s or group’s patients across all payers for the performance period
    • CMS Web Interface: Sampling requirements for Medicare Part B patients
    • CAHPS for MIPS Survey: Sampling requirements for Medicare part B patients
    Topped-Out Measures:

    Definition: if measure performance is so high and unvarying that meaningful distinctions and improvement in performance can no longer be made. QCDR measures would not go through the comment and rulemaking process to remove topped out measures. Policies include:

    • Finalized 4-year lifecycle for identification and removal of topped out measures
    • Scoring cap of 7 points for topped out measures
    • Policies to identify, remove and cap scoring for topped out measures do not apply to CMS Web Interface measures
    • Policy does not apply to CAHPS for MIPS Summary Survey Measures (SSMs)
    • 6 measures identified for scoring cap for topped out measures
    Measures Impacted by Clinical Guideline Changes:
    • No requirements
    Bonus Points: High-Priority Measures (after first required measures)
    • 2 points for outcome, patient experience
    • 1 point for other high priority measures which need to meet data completeness, case minimum, and have performance greater than 0
    • Capped bonus points at 10% of the denominator of total Quality performance category
    Bonus Points:End-to-End Electronic Reporting:
    • 1 point for each measure submitted using electronic end-to-end
    • Capped at 10% of the denominator of total Quality performance category points
    Improvement Scoring – Full Participation:
    • Eligible clinicians must fully participate (i.e., submit all required measures and have met data completeness criteria, and for performance year
    • The quality improvement percent score is 0 if the eligible clinician did not fully participate in the quality category for the current performance period
    • If the eligible clinician has a previous year Quality performance category score less than or equal to 30%, we would compare 2018 performance to an assumed 2017 Quality category score of 30%
    Weight to final score
    • 45% in Year 3
    • Maintain the same reweighting criteria for the Quality Performance category

    In Year 3, individual eligible clinicians would be able to submit a single measure via multiple collection types (e.g. MIPS CQM, eCQM, QCDR measures and Medicare Part B claims measures) and be scored on the data submission with the greatest number of measure achievement points

    Groups and Virtual Groups would be able to use multiple collection types.
    • The Quality performance category would be scored if groups submit data using multiple collection types (e.g. MIPS CQM, eCQM, QCDR measures, and Medicare Part B claims measures)
    • CMS Web Interface cannot be scored with other collection types other than the CMS approved survey vendor measure and/or administrative claims measures
    Data Completeness Requirements:
    • The same data completeness requirements as Year 2, with the following change:
    • For groups registered to report the CAHPS for MIPS survey, there is an additional policy. If the sample size was not sufficient, the total available measure achievement points (the denominator) would be reduced by 10 points and the measure would receive zero points
    Topped-Out Measures:
    • The definition and lifecycle for topped out measures remain the same for Year 3, although additional factors may affect the time a topped-out measure remains as such
    Measures Impacted by Clinical Guideline Changes:
    • In response to clinical guideline or other changes, impacted measures will be given a score of 0 and the Quality performance category denominator would be reduced by 10. If this situation occurs the clinician would be required to submit data for one less measure (i.e. 5 measures instead of 6)
    Bonus Points: High-Priority Measures (after first required measure)
    • Same as Year 2, with the following change:
    • Discontinue high priority measure bonus points for CMS Web Interface Reporters
    Bonus Points: End-to-End Electronic Reporting:
    • Same as Year 2.
    Improvement Scoring – Full Participation:
    • Same as Year 2
    Cost Performance Category Weight to final score:
    • 10% in Year 2
    Measures:
    • Two measures: Total Per Capita Cost and Medicare Spending Per Beneficiary (MSPB)
    • Derived from Medicare claims
    • Reliability threshold of 0.4
    • Case minimum of 20 for total per capita cost and 35 for MSPB
    Measure Attribution:
    • Plurality of primary care services rendered by the clinician to determine attribution for the total per capita cost measure
    • Plurality of Part B services billed during the index admission to determine attribution for the MSPB measure
    • Added two CPT codes (99487 and 99489 describing complex chronic care management) to list of primary care services used to determine attribution under the total per capita cost measure
    Scoring Improvement:
    • Improvement scoring added to the Cost performance category scoring methodology with a maximum cost improvement score of 1 percent;
    • However, the Bipartisan Budget Act of 2018 delayed consideration of improvement in the Cost performance category until the 2024 payment year (based on the 2022 performance year). As a result, there will be no improvement scoring in Year 2 MIPS payment year.
    Calculating the Cost Score:
    • Cost Achievement Points/Available = Cost Performance Category Percent Score
    • The percent score cannot not exceed 100%
    • The Bipartisan Budget Act of 2018 delayed consideration of improvement in cost until the 2024 MIPS payment year (based on the 2022 performance year)
    • We will not calculate a Cost performance category score if the eligible clinician is not attributed any Cost measures, because of case minimum requirements or the lack of a benchmark
    Weight to final score:
    • 15% in Year 3
    Measures:

    The Total Per Capita Cost and MSPB measures will be the same as in Year 2, with the following changes:

    • 8 episode-based measures will be added to the list of Cost measures
    • Case minimum of 10 for procedural episodes and 20 for acute inpatient medical condition episodes
    Measure Attribution

    Same as Year 2 with the following changes:

    • For procedural episodes, we will attribute episodes to each MIPS eligible clinician who renders a trigger service as identified by HCPCS/CPT procedure codes
    • For acute inpatient medical condition episodes, we will attribute episodes to each MIPS eligible clinician who bills inpatient evaluation and management (E&M) claim lines during a trigger inpatient hospitalization under a TIN that renders at least 30 percent of the inpatient E&M claim lines in that hospitalization
    Scoring Improvement
    • Cost performance category percent score will not take into account improvement until the 2024 MIPS payment year
    Calculating the Cost Score:
    • Same as Year 2
    Facility-Based Quality and Cost Performance Categories Measurement:
    • Not Applicable
    Applicability – Individual:
    • Not Applicable
    Applicability – Group:
    • Not Applicable
    Attribution
    • Not Applicable
    Election
    • Not Applicable
    Benchmarks
    • Not Applicable
    Assigning MIPS Category Scores:
    • Not Applicable
    Scoring Improvement:
    • Not Applicable
    Scoring – Special Rules:
    • Not Applicable
    Measurement:
    • For facility-based scoring, the measure set for the fiscal year Hospital Value-Based Purchasing (VBP) program that begins during the applicable MIPS performance period will be used for facility-based clinicians
    Applicability – Individual:
    • MIPS eligible clinician furnishes 75 percent or more of their covered professional services in inpatient hospital, on-campus outpatient hospital, as identified by POS code 22, or an emergency room, based on claims for a period prior to the performance period
    • Clinician must have at least a single service billed with the POS code used for the inpatient hospital or emergency room
    Applicability – Group:
    • Facility-based group is one in which 75 percent or more of the MIPS eligible clinician NPIs billing under the group’s TIN are eligible for facility-based measurement as individuals
    Attribution:
    • A facility-based clinician is attributed to the hospital at which they provide services to the most Medicare patients
    • A facility-based group is attributed to the hospital at which a plurality of its facility-based clinicians are attributed
    • If unable to identify a facility with a VBP score to attribute a clinician’s performance, that clinician is not eligible for facility-based measurement and will have to participate in MIPS via other methods
    Election:
    • Automatically apply facility-based measurement to MIPS eligible clinicians and groups who are eligible for facility-based measurement and who would benefit by having a higher combined Quality and Cost score
    • No submission requirements for individual clinicians in facility-based measurement but a group must submit data in the Improvement Activities or Promoting Interoperability performance categories in order to be measured as a group under facility-based measurement
    Benchmarks:
    • Benchmarks for facility-based measurement are those that are adopted under the Hospital VBP program of the facility for the year specified
    Assigning MIPS Category Scores:
    • Both the Quality performance category score and Cost performance category score for facility-based measurement are reached by determining the percentile performance of the facility determined in the VBP program for the specified year and awarding a score associated with that same percentile performance in the MIPS Quality and Cost performance category scores for those clinicians who are not scored using facility-based measurement
    Scoring Improvement:
    • Given that improvement is already captured in the distribution of the MIPS performance scores that is used to translate a Hospital VBP Program Total Performance Score into a MIPS Quality performance category score, there is no additional improvement scoring for facility-based measurement for either the Quality or Cost performance category
    Scoring – Special Rules:
    • Some hospitals do not receive a Total Performance Score in a given year in the Hospital VBP Program, whether due to insufficient quality measure data, failure to meet requirements under the Hospital IQR Program, or other reasons. In these cases, we would be unable to calculate a facility-based score based on the hospital’s performance, and facility-based clinicians would be required to participate in MIPS via another method
    Improvement Activities Performance Category Weight to final score:
    • 15% in Year 2
    Improvement Activities Inventory
    • Initial inventory established based on research, environmental scan and priorities
    • In Year 2, the Annual Call for submitting Improvement Activities, was established
    Improvement Activities Inventory Submission Timeline
    • Submissions at any time during the performance period to create an Improvement Activities Under Review (IAUR) list; submissions received by March 1st will be considered for inclusion in the following calendar year
    CMS Study on Burdens
    • Study purpose, participation credit and requirements and study procedures updated from Year 1 establishment
    Scoring: PI Bonus
    • Certain improvement activities will qualify for a bonus under the PI performance category
    Weight to final score
    • 15% in Year 3
    Improvement Activities Inventory
    • In Year 3, the timeframe for the Annual Call for Activities and the improvement activities inventory would be modified
    • Modifications include the addition of one new criteria in this category, “Include a public health emergency as determined by the Secretary,” and the removal of, “Activities that may be considered for a Promoting Interoperability bonus”
    • Adding 6 new Improvement Activities
    • Modification of 5 existing Improvement Activities
    • Removal of 1 existing Improvement Activity
    Improvement Activities Inventory Submission Timeline
    • Improvement activity nominations received in Year 3 will be reviewed and considered for possible implementation in Year 5 of the program
    • The submission timeframe/due dates for nominations would be from February 1st through June 30th, providing approximately 4 additional months to submit nominations
    CMS Study on Burdens
    • The CMS study title would be changed to, “CMS Study on Factors Associated with Reporting Quality Measures”
      • The sample size would be increased to 200 MIPS eligible clinicians with focus group requirements for only a subset of study participants
    • We are also proposing to limit the focus group requirement to a subset of the 200 participants, and require that at least one of the minimum of three required measures be either an outcome or a high priority measure
    Scoring: PI Bonus
    • In Year 3, the Promoting Interoperability bonus will be removed
    Promoting Interoperability (PI) Performance Category Weight to final score:
    • 25% in Year 2
    Note: Performance category name changed to Promoting Interoperability. Reweighting:
    • Reasons to reweight the PI category to 0% include:
    • Nurse practitioner, physician assistant, clinical nurse specialist, or certified registered nurse anesthetist
    • Significant hardship (e.g. lack of internet, extreme and uncontrollable circumstances, small practice)
    • 50% or more of patient encounters occurred in practice locations where no control over the availability of CEHRT
    • Non-patient facing
    • Hospital-based
    • ASC-based
    • Automatic reweighting for extreme and uncontrollable circumstances
    • Even if the category could be reweighted
    • MIPS eligible clinicians using decertified EHR Technology, exception available for no more than 5 years
    • For any of the above reasons, if a MIPS eligible clinician reports PI (formerly ACI) measures and objectives, they will be scored like other MIPS eligible clinicians and the PI performance category will not be reweighted to 0%
    Certification Requirements:
    • Eligible clinicians may use either the 2014 or 2015 Edition CEHRT or a combination of the two; one-time bonus of 10 percentage points in if using only 2015 Edition CEHRT
    Scoring:
    • Performance category score is comprised of the base, performance, and bonus score
    • Clinicians must complete the base score requirements in order to receive a score in the category
    Objectives and Measures
    • Two measure set options for reporting based on the clinician’s CEHRT edition (either 2014 or 2015).
    Weight to final score:
    • 25% in Year 3
    Reweighting
    • Reweighting of the Promoting Interoperability performance category remains the same as Year 2 and extends to additional clinician types (physical therapists, occupational therapists, clinical social workers, and clinical psychologists)
    Certification Requirements
    • Eligible clinicians must use 2015 Edition CEHRT in Year 3
    Scoring:
    • Eliminating base, performance, and bonus scores
    • Proposing a new scoring methodology
    • Performance-based scoring at the individual measure-level. Each measure would be scored based on the MIPS eligible clinician’s performance for that measure based on the submission of a numerator or denominator, or a “yes or no” submission, where applicable
    • The scores for each of the individual measures would be added together to calculate the score of up to 100 possible points. If exclusions are claimed the points for measures will be reallocated to other measures
    Objectives and Measures
    • One objectives and measure set based on the 2015 Edition CEHRT
    • Four objectives: e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange
    • Clinicians are required to report certain measures from each of the four objectives, unless an exclusion is claimed
    • Proposing to add two new measures to the e-Prescribing objective: Query of Prescription Drug Monitoring Program (PDMP) and Verify Opioid Treatment Agreement
    Final Score General Performance Category Weights in Year 2:
    • Quality: 50%
    • Cost: 10%
    • PI: 25%
    • IA: 15%

    If a MIPS eligible clinician is scored on fewer than two performance categories, a final score equal to the performance threshold will be assigned and the MIPS eligible clinician will receive an adjustment of 0%

    Small Practice Bonus
    • A bonus of 5 points is added to the final score for MIPS eligible clinicians, groups, virtual groups and APM Entities that meet the definition of small practice and submit data on at least one performance category in the 2018 performance period
    General Performance Category Weights in Year 3
    • Quality: 45%
    • Cost: 15%
    • PI: 25%
    • IA: 15%

    If a MIPS eligible clinician is scored on fewer than two performance categories, a final score equal to the performance threshold will be assigned and the MIPS eligible clinician will receive a payment adjustment of 0%

    Small Practice Bonus:
    • The small practice bonus will now be added to the Quality performance category, rather than in the MIPS final score calculation
    • Add 3 points in the numerator of the Quality performance category for MIPS eligible clinicians in small practices who submit data on at least 1 quality measure
    MIPS Payment Adjustments Application of Payment Adjustment to Medicare Paid Amount:
    • Finalized that for each MIPS payment year, the MIPS payment adjustment factor, and if applicable, the additional MIPS payment adjustment factor, are applied to Medicare Part B payments for items and services furnished by the MIPS eligible clinician during the year
    • However, the Balanced Budget Act of 2018 changed this so that the MIPS adjustment factors will apply to ‘covered professional services’ under the physician fee schedule beginning with the 2019 payment year
    • Finalized application of the payment adjustment to the Medicare paid amount
    Final Score/2020 payment adjustment
    • For individual eligible clinicians, we will use the final score associated with the TIN/NPI used during the performance period
    • For groups submitting data using the TIN identifier, we will apply the group final score to all the TIN/NPI combinations that bill under the TIN during the performance period
    • For eligible clinicians in a MIPS APM, we will assign the APM Entity group’s final score to all APM Entity Participant National Provider Identifiers associated with the APM Entity
    • For eligible clinicians that participate in APMs for which the APM scoring standard does not apply, we will determine a final score using either the individual or group data submissions
    • If a MIPS eligible clinician is not in an APM Entity and is in a virtual group, the MIPS eligible clinician would receive the virtual group final score over any other final score
    Application of Payment Adjustment to Medicare Paid Amount
    • Same as Year 2
    Final Score/2021 payment adjustment:
    • Remains the same as Year 2, with one change. MIPS eligible clinicians in a group practice who qualify for a group final score will have a modified determination period to include:
      • 15-month window that starts with the second 12-month determination period (October 1 prior to the MIPS performance period through September of the current MIPS performance period)
    • Proposed policy to assign a weight of 0% to each of the four performance categories and a final score equal to the performance threshold when:
      • MIPS eligible clinician joins an existing practice (TIN) in the final three months of the performance period year and the practice is not participating in MIPS as a group
      • MIPS eligible clinician joins a practice that is a newly formed TIN in the final three months of the performance period year
    Performance Threshold / Payment Adjustment
    • Performance Threshold is set at 15 points
    • Additional performance threshold set at 70 points for exceptional performance
    • MIPS eligible clinicians receive a payment adjustment and, if applicable, an additional payment adjustment, determined by comparing final score to performance threshold and additional performance threshold
    • A final score at or above the performance threshold receive a zero or positive payment adjustment and a score below the performance threshold receive a negative adjustment
    • As required by statute, the maximum negative payment adjustment is -5 percent positive payment adjustments can be up to 5% (but they are multiplied by a scaling factor to achieve budget neutrality)
    • The additional payment adjustments for exceptional performance starts at 0.5% and goes up to 10% x scaling factor not to exceed 1
    • Performance Threshold is set at 30 points
    • Additional performance threshold set at 80 points for exceptional performance
    • As required by statute, the maximum negative payment adjustment is -7 percent. Positive payment adjustments can be up to 7% (but they are multiplied by a scaling factor to achieve budget neutrality)
    • The additional payment adjustment for exceptional performance shall be applied in the same way as in 2018 for scores at or above the additional performance threshold

    *The contents of this table were originally published by CMS in the Proposed Rule for the Quality Payment Program Year 3.

    August 27th, 2018 Categories: featured, MIPS

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    SurveyVitals Awarded CMS Approval to Administer HCAHPS

    approved hcahps vendor

    BOISE, ID (Press Release) – SurveyVitals, Inc., a healthcare analytics company specializing in digital patient experience surveys, announced their approval by the Centers for Medicaid and Medicare Services (CMS) to administer the HCAHPS survey. The company becomes one of only 28 certified vendors in the nation.

    “This approval is significant in that it allows us to provide a truly end-to-end patient experience solution for our hospital clients,” said Bob Vosburgh, CEO of SurveyVitals. “With our current digital infrastructure, HCAHPS was really the only missing piece.”

    Hospitals are required to administer the HCAHPS survey as a part of the federal Value Based Purchasing program, which is a determinant of Medicare reimbursement. CMS also assigns hospitals a public star rating using HCAHPS survey results as a part of its consumer-facing initiative, Hospital Compare.

    “Hospitals relying on traditional paper survey models alone continue to find that it’s simply too expensive and not yielding enough meaningful data to drive their quality improvement programs,” continued Vosburgh. “Our streamlined solution offers these groups significant savings without sacrificing quality or reporting features.”

    By pairing HCAHPS with SurveyVitals’ pre-existing digital offerings, hospitals have the ability to meet all of their patient experience needs with a single vendor. The SurveyVitals full hospital solution includes:

    • Seamless, automated data transfer
    • Patient survey administration, including both HCAHPS and digital experience surveys to the entire patient population
    • Real-time, online reporting portal for administrator and provider users
    • Actionable, provider-specific experience data for providers such as hospitalists, anesthesiologists, emergency room physicians, as well as nursing staff
    • Automated alert system and provider improvement resources
    • Reputation management tools to drive SEO and potential patients to medical facilities

    In addition to HCAHPS, SurveyVitals is certified to administer the Merit-Based Incentive Payment System CAHPS (CAHPS for MIPS) , Accountable Care Organization CAHPS (ACO CAHPS), Outpatient and Ambulatory Surgery CAHPS (OAS CAHPS), Hospice CAHPS, Home-Health CAHPS (HHCAHPS), In-Center Hemodialysis CAHPS (ICH CAHPS), and Patient-Centered Medical Home CAHPS (CAHPS PCMH).

    CAHPS is a program and registered trademark of the U.S. Agency for Healthcare Research and Quality.

    About SurveyVitals

    SurveyVitals inspires positive change in healthcare by providing real-time, actionable patient feedback to providers and organizations through innovative technology. With intuitive, in-depth reporting via online client portals, SurveyVitals provides the tools needed to succeed in today’s rapidly changing healthcare landscape. The solution supports more than 16,000 providers operating across 85 specialties.

    Contact

    Interested in learning more about SurveyVitals? Request more information or schedule a free, no-obligation demo here or call us at 972-442-1484.

    June 7th, 2018 Categories: featured

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    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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    Working MOCA 2.0? SurveyVitals Can Help

    MOCA 2.0 anesthesia

    The redesigned MOCA 2.0 (Maintenance of Certification in Anesthesiology) allows anesthesia diplomates to complete a variety of new activities to meet the Part 4 Quality Improvement requirement. Diplomates are required to earn a minimum of 50 points during their ten-year MOCA 2.0 cycle by choosing and completing quality improvement activities most relevant to their practice.

    Where does SurveyVitals come in?

    You may be able to use the SurveyVitals solution to fulfill the requirement by completing an improvement plan based on A) 360 professional reviews, or B) patient experience of care surveys. The point value for this activity is 1 point per hour spent on the activity, for a total of up to 25 points.

    SurveyVitals’ Anesthesia 360° solution offers surveys for patients, practitioners, administrators, surgeons, and peers to give you a comprehensive look at patient and professional satisfaction.

    Don’t know where to start? Your survey dashboard provides a detailed visual of areas scoring the lowest and receiving the most low-score alerts, allowing for quick identification of improvement opportunities. SurveyVitals’ robust reporting options allow you to easily track and measure improvement in these areas over time based on near real-time patient feedback.

    How can I attest to meeting this requirement?

    Diplomates must attest to the activity on the American Board of Anesthesiology (ABA) website using the ABA-approved template found here. Your SurveyVitals data can be used to summarize both the Data Summary and the Change in Practice.

    More information about the MOCA 2.0 Part 4 requirement can be found on the ABA website.

    June 1st, 2018 Categories: Anesthesia, Product Features

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    New research finds unverified patient reviews an unreliable guide

    Unverified online patient reviews do not always correlate with actual patient experience, according to a new study published by the Mayo Clinic.

    Can you trust what people say about doctors online?

    That’s the question that researchers from the Mayo Clinic set out to answer when they started collecting data from online patient reviews in 2014. The results of the study, which were released in the April edition of the Mayo Clinic Proceedings, corroborate what physicians have been saying for a long time: Unverified online reviews often present an inaccurate depiction of physicians and their practices.

    Here’s what happened.

    Researchers collected online patient reviews for two groups: 113 physicians who had received at least one negative online review (<50% of possible score), and 113 physicians who had never received any negative online reviews. The researchers then tracked these physicians’ performance over the next several months using verified, tested patient satisfaction surveys. (similar to SurveyVitals’ 360° Survey Solution).

    After analyzing the verified patient satisfaction scores, the results were clear: There was no correlation between negative online reviews and patient satisfaction scores.

    So to answer the original question-

    No, you can’t always trust what people are saying about doctors online.

    Why it’s important.

    In the digital age, online reputation is paramount to success. Not sure about that? Check out this study that found 54% of millenials look online before choosing a doctor.

    Online reviews can create a ripple effect that impacts everything from choosing a doctor to perception of care received. As patients approach healthcare with an evolving consumer mindset, and as the healthcare industry shifts toward a pay for performance model, negative perceptions will inevitably damage an organization’s bottom line.

    The unsettling part is that in most cases anyone can go online and write these reviews, regardless of whether or not they’ve ever interacted with the physician. This exacerbates the problem that the loudest voices on the internet tend to be the most upset, creating an unbalanced portrayal that isn’t necessarily representative of a practice’s entire patient population.

    The researchers at the Mayo Clinic encapsulated this issue best when they wrote, “Perhaps the time has come for improved mechanisms to support health care organizations and their physicians to allow a more qualified and verified form of PSS scores to be included online in an attempt to overcome often single and unsubstantiated online reviews by open source online websites.”

    So what can we do?

    The best way to protect your organization’s online reputation is to share your verified patient ratings with the world. SurveyVitals’ Provider Widget is the easiest way to share and promote your verified reviews.

    Here’s how it works.

    The Provider Widget displays actual feedback from actual patients. Instead of unreliable, unverified reviews from strangers on the internet, the Provider Widget automatically gathers data from the patient population as they submit their patient experience surveys.

    provider widget patient reviews

    Ultimately, the verified reviews give patients the confidence they need in choosing a provider to treat them. SurveyVitals’ Provider Widget shows ratings from not just a few, but often from thousands of verified patient to generate a trustworthy source of information.

    Harnessing the power of actual patient ratings creates a competitive advantage against peers who rely on unverified reviews. Patients who see the ratings on the Provider Widget know that they are getting an accurate representation of their provider’s performance.

    Provider Widget

    How to set up the Provider Widget.

    If you aren’t currently utilizing the SurveyVitals solution, schedule a demo to learn more about how SurveyVitals can help your organization with patient experience surveys, CAHPS surveys, MIPS Improvement Activities, the Provider Widget, and more.

    If you are already running the SurveyVitals solution, please contact your support team or email support@surveyvitals for help setting up your widget.

    By providing the information and tools to help people make informed decisions, we can work toward making a better healthcare systems for both physicians and providers. Better insights can lead to better outcomes for everyone involved.

    April 6th, 2018 Categories: featured, Outpatient Practice, Patient Experience, Product Features, Reputation Management

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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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