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MACRA Quality Payment Program: Preparing for MIPS

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What is the Quality Payment Program?
The Centers for Medicare and Medicaid Services (CMS) recently released the final rule outlining the new Quality Payment Program (QPP)—the biggest change Medicare has seen in its 50 years and one that will affect more than 600,000 medical professionals. The rule establishes a flurry of new reporting requirements and overhauls the way the federal government reimburses clinicians. The QPP combines and sunsets three big CMS programs: Meaningful Use, the Physician Quality Reporting System, and the Value-Based Payment Modifier. How will this new program affect your practice? Checkout our list of FAQ’s 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 $30,000 in allowed charges per year and provide care for more than 100 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 2017 under the low-volume threshold exemption.

Eligible clinicians under the program include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists.

CMS has indicated that the list of eligible clinicians will expand in future program years and will likely include: physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, and dietitians /nutritional professionals.

Two Tracks: Which is right for you?
Under the new rule, there are two tracks. Most all Medicare Part B clinicians and groups will fall under the Merit Incentive Payment System (MIPS) track, while a smaller percentage will qualify for the Alternate Payment Models (APM) track if they are 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 program. Not sure if you qualify as an advanced APM? See the list of CMS-approved APM models for program year 2017.

Exemptions to participating in MIPS:
– If you are an advanced APM
– If 2017 is your first year participating in Medicare
– If you fall below the low-volume threshold

When does the program start?

January 1, 2017 will mark the official start of the transition year for the Quality Payment Program. CMS is giving clinicians the option to start anytime between January 1 and October 2, 2017. During the transition year, providers must report at least something to avoid a negative payment adjustment in 2019 (more on that below). The final day to submit data to satisfy reporting requirements for the 2017 program year is March 31, 2018.
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The MIPS track

You will receive a performance-based adjustment to your Medicare fee schedule starting in 2019 based on your performance in 2017. The amount of the adjustment, either positive or negative, 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 (replacing PQRS)
2. Advancing Care Information (replacing Meaningful Use)
3. Clinical Practice Improvement Activities (commonly referred to as Improvement Activities)
4. Resource Use (replacing Value-Based Payment Modifier)

The Quality category is weighted more heavily during initial program years while the Resource Use category will not be included in your 2017 score, but will be included in future years. See the weighted breakdown by category per program year below.

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How do I avoid a negative payment adjustment in 2019?

In the final rule, CMS outlined what they call “pick your pace,” which allows eligible clinicians to avoid, at least for a year, having to comply with all reporting requirements contained in MIPS right away. During the transition year, you have four options which are listed in the table below. If you submit no performance data for 2017, you could be faced with up to a negative 4% adjustment.

SurveyVitals recommends submitting data for a continuous 90-day reporting period during the transition year as this option not only allows you to avoid a negative payment adjustment in 2019, it gives you the opportunity to earn a performance-based bonus and fully prepare for subsequent program years. Often, these federal programs can overwhelm practices trying to meet new requirements. Take this transition year as an opportunity to assess your practice and what will work best for you to maximize reimbursement under MIPS.

Individual vs. Group Reporting

Eligible clinicians have the option to report as an individual or within a 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, or QCDR and will receive a single composite performance score. CMS will also accept quality data through routine Medicare claims processing.

Eligible clinicians can also submit data as a group, which CMS defines as a set of clinicians sharing a common TIN, regardless of specialty or practice site. 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 (groups of 25+), an EHR system, registry, or QCDR. However, if groups elect to submit data via the CMS web interface, they must register to do so by June 30, 2017.

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Meeting Measures

Under the MIPS Quality category, clinicians have more flexibility to select measures that best suit their practice than they did in PQRS. In a notable change, clinicians must report fewer measures and no longer have to choose measures across a required set of National Quality Strategy (NQS) domains. Instead, clinicians can now report measures most relevant to their specialty, regardless of NQS domain. Additionally, CMS removed the requirement to report a cross-cutting measure for program year 2017.

Clinicians can select measures from the following:
MIPS measures
Specialty measure sets (quality category)
– Non-MIPS QCDR measures, which can be used in some categories in lieu of the traditional measures via your QCDR. (CMS has not yet released the list of approved QCDR measures and plans to do so in spring of 2017 for the initial performance period and no later than January 1 for future performance periods). Check back for updates.

Quality Category

Eligible clinicians are required to report 6 measures of their choosing in 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.

If reporting via a specialty measure set, clinicians must choose at least six measures to report within the set, including one outcome measure. If no outcome measure is available, clinicians must report a high priority measure. If the measure set has fewer than six measures, clinicians will be required to report all available measures contained in the set.

Groups electing to submit quality data via the CMS Web Interface face a higher reporting threshold and will be required to report 11 quality measures.

See the list of MIPS Quality measures.

Clinical Practice Improvement Activities (IA)

The IA category is new to the program, and requires clinicians to participate in four medium-weighted activities or two high-weighted activities to fully satisfy reporting requirements. Groups with 15 or fewer eligible providers and/or clinicians practicing in rural and health professional shortage areas will only have to report on one high-weighted activity or two medium-weighted activities.

Measuring the patient experience has been weighted more heavily under the MIPS program than in previous years and is deemed a ‘high priority’ measure if reported. Your SurveyVitals solution can help you meet more than enough measures in the IA category and can even submit data on your organization’s behalf. Contact us at info@surveyvitals.comto learn more about meeting IA measures with SurveyVitals.

See the list of IA activities.

Resource Use

Resource Use is replacing the Value-Based Payment Modifier program. No data submission is required for compliance with the Resource Use category. Your organization’s score in this category is calculated using administrative claims data. During the 2017 transition year, CMS will not include the Resource Use category as a part of your composite performance score, but will start in 2018 to phase it in.

Advancing Care Information

Advancing Care Information is replacing the Meaningful Use program with 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 and bonus points for up to 9 total measures. In the transition year, there are two options for measures. Clinicians will report based on the level of their certified electronic health record.

2014 Certified EHR: If you’re reporting via EHR Technology certified to the 2014 Edition, you have two options:
Option 1: 2017 Advancing Care Information Transition Objectives and Measures. See the list of measures.
Option 2: Combination of the two measure sets

2015 Certified EHR: If you’re reporting via EHR technology certified to the 2015 Edition, you have two options:
Option 1: Advancing Care Information Objectives and Measures. See the list of measures
Option 2: Combination of the two measure sets

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. CMS has not yet released the list of approved QCDR measures, but expects to do so in the spring of 2017. Check back for updates.

Do I have to run CAHPS for MIPS?

No. Under the new program, participation in CAHPS for MIPS—previously CAHPS for PQRS—is optional for both clinicians reporting as individuals or for group reporting, no matter the size of the group. The increased flexibility under MIPS allows clinicians to forego participation in CAHPS, and, instead, identify clinical measures in their specialty to optimize their scores in the quality category.  Why get delayed feedback through CAHPS when you can get immediate, statistically valid feedback for a fraction of the cost of a CMS-certified vendor? Let us help you address the patient experience in the Improvement Activities category with your SurveyVitals solution and satisfy reporting requirements. 

Interested in meeting measures with SurveyVitals?
Want to learn how SurveyVitals can help you prepare for 2017? 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.


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