The Centers for Medicare and Medicaid Services (CMS) has released the Quality Payment Program (QPP) proposed rule for the 2021 performance year. To accommodate for the challenges posed by COVID-19, CMS is not proposing many significant changes to the Merit-based Incentive Payment System (MIPS) for 2021. Here are the highlights of the proposed rule for next year. For information on the current performance year, see our MIPS 2020 page.
Introduction of MIPS Value Pathways (MVPs), the new framework originally set to begin implementation in the 2021 performance year, will be postponed. CMS will continue to work on engaging stakeholders and developing the framework’s guiding principles.
CMS has proposed an APM Performance Pathway (APP), complementary to MVPs. This option would be available to MIPS APM participants only and would be composed of a fixed set of measures for each performance category. The APP performance measures would also satisfy reporting requirements for the Medicare Shared Savings Program quality scoring.
In 2021, the proposed Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.
For the 2021 performance period, CMS proposes to increase the performance threshold (maximum number of points needed to avoid a negative payment adjustment) from 45 to 50 points. There is no change to the exceptional performance threshold (number of points needed for a positive payment adjustment) of 85 points.
CMS proposes to use performance period benchmarks, rather than historical, to score quality measures. Previously, the benchmarking baseline period was the 12-month calendar year two years prior to the MIPS performance year. CMS hopes to ensure accurate and reliable data due to possible gaps in baseline data due to COVID-19. Therefore, in 2021, the agency proposes to use benchmarks from the 2021 performance period instead of the 2019 calendar year.
CMS also proposes to end the CMS Web Interface as a quality reporting option for ACOs and registered groups, virtual groups, or other APM Entities beginning with the 2021 performance period.
Minimal updates would be made to the Improvement Activities inventory. A process would also be established for agency-nominated improvement activities.
In 2021, there are no proposed changes to the requirement that at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.
CMS proposes to update existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the TPCC measure.
For the 2020 performance period only, the maximum number of bonus points available for the complex patient bonus would be 10, to account for the additional complexity of treating patients during the COVID-19 public health emergency.
You can view the full 2021 QPP Proposed Rule fact sheet here.
Last week, CMS released the final rule for the changes to the Merit-Based Incentive Payment System (MIPS). While there are only minor changes to the program in 2020, bigger changes are expected in 2021. Here are two of the big takeaways from the final rule.MIPS Value Pathways (MVPs)
CMS intends to move toward what they say would be a more streamlined MIPS program. To fulfill upon this vision, the agency intends to reduce reported complexities with data submission and confusion surrounding measure selection with a new framework they are calling MIPS Value Pathways (MVPs).
In the MVP framework, CMS intends to work with stakeholders to create sets of measure options that they say would be more relevant to clinician scope of practice and meaningful to patient care. MIPS-eligible clinicians would no longer choose their measures from a single inventory, but would instead fulfill pre-defined measures and activities connected to a specialty or condition.
At this time, CMS has not determined whether participation in MVPs in 2021 would be optional or mandatory.
Many aspects of the MVP framework are still unclear, and we will be following and providing updates as they are released by CMS. Subscribe to our MIPS newsletter to keep up to date on the MVP discussion.Qualified Clinical Data Registries (QCDR)
In the current QPP landscape, QCDRs are not required to support multiple MIPS performance categories. However, beginning in performance year 2021, QCDRs will be required to submit data for the Quality, Improvement Activities, and Promoting Interoperability categories for the entire performance year and applicable submission period.
CMS is looking to achieve alignment of similar measures across QCDRs, with an emphasis on outcome measures. Starting in 2021, this would require full measure development and testing at the clinician level prior to the time of self-nomination. Additionally, CMS would implement a set of formalized guidelines for QCDR measure rejections.
You can read more about these proposed changes in the Quality Payment Program final rule.CMS, Improvement, improvement activities, macra, MIPS, QCDR, QPP, Quality, quality category, quality payment program
Last week, CMS released the final rule for the changes to the Merit-Based Incentive Payment System (MIPS) in 2020. Changes to the program next year are minimal, but are still important to note as you head into performance year 4.Performance Category Weights
There will be no change to the performance category weights in MIPS performance year 2020.
For the 2020 performance period, the performance threshold (maximum number of points needed to avoid a negative payment adjustment) will increase from 30 to 45 points. The additional performance threshold for exceptional performance will increase from 75 points to 85.
The maximum positive payment adjustment for performance year 2020 will be increased to 9%, plus additional adjustments for exceptional performance. The maximum negative payment adjustment will be -9%.Quality Performance Category
Data completeness for performance year 2020 will increase from 60% to 70%. This means you must report on at least 70% of your total patients who meet the measure’s denominator criteria in order to receive maximum points for the measure.Improvement Activities Category
The Improvement Activities inventory has been updated for MIPS performance year 2020.
|MIPS Year 4 Changes to Improvement Activities|
Previously, a group or virtual group could attest to an improvement activity if at least one clinician in the group participated in the activity. In 2020, in order for a group or virtual group to attest to an improvement activity, at least 50% of the clinicians in the group or virtual group must perform the same activity during any continuous 90-day period in the performance year.
CMS has also made a technical correction to the definition of ‘Rural Area’ that will not change how rural clinicians are identified.
Also modified are the requirements for patient-centered medical home (PCMH) designation. CMS has removed specific examples of entity names of accreditation organizations in order to remove barriers to designation.Promoting Interoperability
Currently, hospital-based clinicians who choose to report as a group or virtual group are eligible for reweighting when 100% of the MIPS-eligible clinicians in the group meet the definition of a hospital-based MIPS eligible clinician. In the next performance year, these clinicians are eligible for reweighting when more than 75% of the NPIs in the group or virtual group meet the definition of a hospital-based MIPS eligible clinician.MIPS Performance Year 2021
Although there are no major changes to the program for 2020, bigger changes are expected in performance year 2021. Subscribe to our MIPS newsletter to stay up to date on these future changes.CMS, improvement activities, macra, MIPS, QCDR, Quality, quality category, quality payment program
Clint Allred, a full-time CRNA for Anesthesia Associates of Boise, was the grand prize winner of our recent Patient Experience Week giveaway. He is performing in the top 25% of anesthesia providers nationally. We asked Clint about his best practices for providing exceptional patient care, and we’re excited to share his responses.
Clint completed his nursing education at Weber State University in 2006, and then attended the University of Tennessee for CRNA training. He has been practicing in Boise since 2011.
What best practices do you and the staff you work with follow that you attribute to your positive scores?
Clint Allred: There is a huge push in our profession to unite with our surgeon colleagues and work toward “enhanced recovery after surgery ” protocols. We have known that there are a lot of different ways to manage the anesthetic of a patient, and each patient requires a different anesthetic. The downside to this is the fact that everyone does something different so the continuity of care is sometimes lacking.
To correct this discrepancy, we created a quality committee within our group. This committee was tasked with reviewing literature along with some of the bigger medical institutes, and then sitting down with anesthesia providers from within our group and developing some protocols for the surgeries that we provide routinely. This initiative at least put all of us on the same page to start with. These protocols deal not only with the patient during surgery, but also some interventions before surgery to improve their outcomes. Since installing these protocols, it has been incredible to see the patient, surgeon, and nurse satisfaction elevate. Every anesthetic still needs to be tailored just right, but this has really helped us be proactive in our decision prep.
What is one example of how you improved your relationship with your patients and/or the care you provide?
Clint Allred: It has amazed me how a little bit of effort goes a long way in ensuring comfort for our patients. It can be something as simple as a warm blanket in the cold metal OR, or talking with the patient on their level trying to take time to explain things.
One thing that we have instituted is in our pediatric population. The inhalational anesthetics that we use have a pungent smell. Kids really hate inhaling that odorous gas. So, we bought a bunch of Lip Smacker chapsticks and then bring the mask to the kids and let them pick out a flavor. They paint the inside of the mask with the flavor they selected and it negates that bad smell when the mask is on their face. Little things like these efforts don’t really take a cumbersome amount of time or energy. They just require a little effort and can really improve the relationship with patients.
What is one thing you avoid doing in order to provide a better experience for your patients?
Clint Allred: The biggest thing I have had to make a conscious effort to try and avoid is just going through the motions with my patients preoperatively. I have always taken pride in the quality of anesthesia care that I provide, but I realized when my son had surgery, that I really needed to change my approach to patients before they even have anesthesia. The day of surgery for patients is an overwhelming experience. Even before you get to the surgery and recovery phase, so much is thrown at them. I found that because administering anesthesia is a routine part of my life, I was just doing the bare minimum to educate and put my patients at ease. We would then whisk them away and go provide anesthesia. My experience taught me that taking an extra five minutes to sit down and talk with the patients about what they were going to experience, both for them and their family members, went a long way to easing their anxiety.
How do you best use your SurveyVitals data for your own personal improvement?
Clint Allred: SurveyVitals definitely serves as a reminder to keep those goals and changes, instituted in my own personal practice, in the forefront of my mind daily. Obviously, I won’t make everyone happy all the time. I used to just shrug my shoulders and act like it didn’t matter. However, what I did find is that when I changed my attitudes and practice – all of a sudden the SurveyVitals data meant something to me. It is a way to drive and improve my practice. I still won’t make every patient happy all the time, but I can take pride in my work and raise the bar for my patients.anesthesia, Best Practice, CRNA, Improvement, patient experience, Patient feedback, Patient Satisfaction, Quality
The final rule for MIPS 2020 outlines the changes to the MIPS program coming in 2021. Read more here.
This week, CMS released the proposed rule for Year 4 of the Quality Payment Program (QPP). Many of the Year 3 requirements will be maintained going into the 2020 performance year; we highlighted the proposed changes in our blog post here. However, there are bigger proposed changes in store for Year 5 of the QPP starting in 2021.
In the latest release, CMS expressed an intention to move toward what they say would be a more streamlined MIPS program. To fulfill upon this vision, the agency is aiming to reduce reported complexities with data submission and confusion surrounding measure selection with a new framework they are calling MIPS Value Pathways (MVPs).
Check out key takeaways below from the proposed rule on MVPs and what CMS has put forth as a very loose framework for the future of the program.
CMS is soliciting public comment on the proposed rule until September 27, 2019 at 5 PM EST.
The MVP framework would create sets of measure options that CMS says would be more relevant to clinician scope of practice and meaningful to patient care by connecting MIPS measures across the four performance categories specific to specialty or condition. It would also incorporate a set of administrative claims-based quality measures that focus on population health and provide data and feedback to clinicians. CMS says it intends to use the current MIPS specialty measure sets as a base framework for developing these new MVPs. The agency also indicated they will seek to enhance information provided to patients, with possible exploration of new forms of public reporting.
If implemented, all MIPS-eligible clinicians would no longer choose their measures from a single inventory, but would instead fulfill measures and activities connected to a specialty or condition as a part of an MVP. This means the MIPS program would no longer require the same number of measures or activities for all clinicians.
CMS anticipates that an MVP would use a single benchmark for each measure, and all clinicians and groups in the MVP would be compared against the same standard. It is proposed that scoring policies would be evaluated to ensure scoring across MVPs is equitable, so that clinicians reporting a specific MVP are not unfairly advantaged. The agency says this would eliminate the need for special scoring policies and bonuses to incent selection of high priority or outcome measures, as clinicians would be required to report all measures in the MVP.
Additionally, MVPs will focus on bundling quality measures with existing, related cost measures and improvement activities as CMS sees feasible.
It is unclear at this time exactly how clinicians and groups will be expected to report data to satisfy measures under the new MVP framework. CMS says that the current MIPS performance measure collection types will continue to be used to the “extent possible,” creating some uneasiness for clinicians and industry leaders who have invested time and resources in their current reporting mechanisms. CMS is soliciting feedback around data submission mechanisms, particularly QCDRs and their role in the program. The agency maintains that a driving force behind the proposed changes is that the flexibility of the program in years 1-3 resulted in multiple benchmarks for each measure and specialty, hindering the ability of CMS to make meaningful comparisons.
The proposed rule also emphasized an increased focus on patient reported measures, including patient experience, satisfaction and outcomes in their performance measurement. The agency anticipates the MVP framework will provide more meaningful information to patients, which will enable them to make decisions about their care and achieve better outcomes.
|CMS Example of Possible MIPS Value Pathway|
|MVP Example||Quality Measures||Cost Measures||Improvement Activities||Promoting Ineroperability|
CMS has released the final rule for MIPS 2020. Read the key takeaways here.
If you’re participating in MIPS, you’ll need to know about the changes to the program in 2020. This week, CMS released the Quality Payment Program proposed rule for the next performance year. While their goal is to maintain many of the requirements from the 2019 performance year, there are some updates to the MIPS track. Here are the highlights of the proposed changes.
In 2020, the Quality performance category weight will be reduced from 45 percent to 40 percent. The Cost category weight will increase from 15 percent to 20 percent.
The maximum negative payment adjustment will increase from -7% to -9% in 2020. Positive payment adjustments (not including exceptional performance) will increase from 7% to up to 9%.
The performance threshold–the minimum number of points to avoid a negative payment adjustment–will increase from 30 points in 2019 to 45 points in 2020. The exceptional performance threshold, which determines additional positive payment adjustments, will increase to 80 points in 2020.
A full breakdown of proposed MIPS changes can be found in the table below. CMS is accepting feedback on the proposed rule at regulations.gov through September 27, 2019 with the file code CMS-1715-P.
CMS has also proposed larger changes to the program starting in 2021. Click here to read our summary of their new proposed framework.
For more information on the current MIPS performance year and how SurveyVitals can help you fulfill your requirements, visit our MIPS page or chat with us using the blue chat icon below.
|Policy Area||Current Year 3 (Final Rule CY 2019)||Year 4 (Proposed Rule CY 2020)|
|Performance Category Weights||
|Quality Performance Category||Data Completeness Requirements
CMS seeks measures that are:
There is no formal policy for measure removal, as QCDR measures must be submitted for CMS approval on an annual basis as part of the self-nomination process.
|Data Completeness Requirements
In addition to current requirements:
In addition to current measure removal criteria:
In instances in which multiple, similar QCDR measures exist that warrant approval, we may provisionally approve the individual QCDR measures for 1 year with the condition that QCDRs address certain areas of duplication with other approved QCDR measures in order to be considered for the program in subsequent years. Duplicative QCDR measures would not be approved if QCDRs do not elect to harmonize identified measures as requested by CMS within the allotted timeframe.
QCDR Measure Rejections
|Improvement Activities Performance Category||Definition of Rural Area
Rural area means a ZIP code designated as rural, using the most recent Health Resources and Services Administration (HRSA) Area Health Resource File data set available.
Patient-Centered Medical Home Criteria
MIPS eligible clinicians who successfully participate in the study receive full credit in the Improvement Activities performance category.
Removal of Improvement Activities
Requirement for Improvement Activity Credit for Groups
|Definition of Rural Area
Rural area is proposed to mean a ZIP code designated as rural by the Federal Office of Rural Health Policy (FORHP) using the most recent FORHP Eligible ZIP Code file available.
Patient-Centered Medical Home Criteria
Please review Appendix 2 in the CY 2020 NPRM for a comprehensive look at the changes proposed to the inventory.CMS Study on Factors Associated with Reporting Quality Measures
Study year 2019 (CY 2019) is the last year of the 3-year study, as stated in CY 2019 PFS final rule (83 FR 59776). CMS will not continue the study during the 2020 performance period. Final study results will be shared at a later date.
Removal of Improvement Activities
|Promoting Interoperability Performance Category – Hospital-Based MIPS Eligible Clinicians in Groups||
A group is identified as hospital-based and eligible for reweighting when 100% of the MIPS eligible clinicians in the group meet the definition of a hospital-based MIPS eligible clinician.
A group would be identified as hospital-based and eligible for reweighting if more than 75% of the NPIs in the group meet the definition of a hospital-based individual MIPS eligible clinician.
For non-patient facing groups (more than 75% of the MIPS-eligible clinicians in the group are classified as non-patient facing) we would automatically reweight the Promoting Interoperability performance category.
No change to definition of an individual hospital-based MIPS eligible clinician.
|Promoting Interoperability Performance Category||Objectives and Measures
||Objectives and Measures
|Cost Performance Category||Measures
|Final Score Calculation: Performance Category Reweighting due to Data Integrity Issues||
|Performance Threshold / Additional Performance Threshold / Payment Adjustment||
MIPS eligible clinicians and groups may submit a targeted review request by September 30 following the release of the MIPS payment adjustment factor(s) with performance feedback.
All requests for targeted review would be required to be submitted within 60 days of the release of the MIPS payment adjustment factor(s) with performance feedback.
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?
How does your organization plan on celebrating National Healthcare Quality Week?National Healthcare Quality Week, patient experience, Quality
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.anesthesia, anesthesiologist, CRNA, diplomates, Improvement, maintenance of certification anesthesia, MOCA, Quality
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.PQRS, Quality
SurveyVitals®, an automated, cost-effective quality and patient satisfaction survey solution provider, today announced a partnership with athenahealth® through athenahealth’s ‘More Disruption Please’ program. SurveyVitals is now part of the athenahealth Marketplace offerings. Together, the companies will work to link athenahealth’s growing network of more than 67,000 health care providers with SurveyVitals to improve their patients’ perceptions of care and reduce malpractice risk.
“SurveyVitals delivers a high-value quality tool,” said Bob Vosburgh, President of SurveyVitals. “Unlike traditional paper surveys, our real-time solution truly helps providers improve patients’ perceptions of care. Patient satisfaction measures are already being incorporated into many QCDRs (Qualified Clinical Data Registries) to meet PQRS (Physician Quality Reporting System) requirements. Now is the time to establish a quality program, and we can help. We’re thrilled to be integrated with athenahealth since it allows our mutual clients to start gathering patient feedback with just a few clicks. Detailed reporting and notifications guide providers toward real improvement.”
athenahealth is a cloud-based services company with a vision to build an information backbone to help make health care work as it should. This relationship will allow SurveyVitals to spread awareness of athenahealth’s cloud-based based services to clients who are looking for an EHR partner who delivers proven clinical and financial results so providers can stay focused on care.About SurveyVitals
SurveyVitals helps improve patient care by administering automated, electronic patient satisfaction surveys on behalf of healthcare providers. They help practices and providers Get Better™. Now in their 13th year, they continue to disrupt the outdated model of expensive paper surveys that garner low response rates and provide delayed feedback. Their solution is used by thousands of providers across 58 specialties, and they have millions of surveys in their national baseline.
Read the official release.Improvement, Quality, Reduce Malpractice Risk
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