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MACRA Monday: MIPS Imposes A Major Burden

Posted on August 28, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

A new study by the Medical Group Management Association has concluded that most practices find participating in the MACRA Quality Payment Program to be very challenging. The study, which focuses on regulatory burdens affecting group practices, also identifies several other rule-related challenges practices face.

In its press release, the MGMA notes that almost half of practices surveyed said they spent more than $40,000 per FTE physician each year to comply with various regulations. Nonetheless, they continue to participate in programs that reward them despite the hassles involved.

According to the research, the vast majority of respondents are participating in the Merit-Based Incentive Payment System (MIPS) this year, and 72% said they expected to exceed the minimum reporting requirements.

That being said, their success clearly hasn’t come easily, with 82% of practices rated MIPS as either “very” or “extremely” burdensome. Within MIPS, groups cite clinical relevance (80%) as their top challenge. Seventy-three percent of survey respondents said MIPS doesn’t support their practice’s clinical quality priorities.

In fact, many respondents said that complying with MIPS was like pulling teeth. Over 70% reported that they found the MIPS scoring system to be very or extremely complex, and 69% said they are very or extremely concerned that unclear program guidance will impact their ability to participate in MIPS successfully.

Eighty-four percent of respondents agreed or strongly agreed that if Medicare’s regulatory complexity were reduced, they could shift more resources to providing patient care. Their frustration is palpable, as the following anonymous comment illustrates: “The regulatory and administrative burdens have dramatically increased over the past two years. However, the biggest problem isn’t the increase itself, [it’s] that the increase is for no good purpose.”

Other programs respondents named as very/extremely taxing included national electronic attachment standards (74%), audits and appeals (69%) and lack of EHR interoperability, followed by payer use of virtual credit cards (59%).

It’s interesting to note the disconnect between the number of practices participating in MIPS (and seemingly, crushing it) and the complaints most are making about participation. Clearly, given how painful it can be to comply with the rules, most practices see their involvement as necessary from a financial perspective.

It’s unlikely that this participation it will get much easier in the near future, though. Eventually, as regulators keep taking feedback and streamlining the MIPS program, they may be able to streamline its requirements, but I wouldn’t hold my breath waiting for that to happen.

The Health Plans’ Role in Meeting MACRA Requirements – MACRA Monday

Posted on July 17, 2017 I Written By

The following is a guest blog post by Karen Way, Health Plan Analytics and Consulting Practice Lead at NTT DATA Services. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

When the Medicare Access and CHIP Reauthorization Act (MACRA) became an official federal ruling for the healthcare industry in 2015, the act replaced the previous Medicare reimbursement schedule with a new pay-for-performance program focused on quality, value and accountability. In short, the legislation rewards healthcare providers for quality of care, not quantity.

While many discuss the impact on providers, what is the health plans’ role in aiding health systems and physicians to meet MACRA requirements?

MACRA provides multiple opportunities for health plans to increase and improve collaboration with provider networks. Recommendations on how health plans can accomplish this include sharing information and services, creating new partnerships and bringing about financial awareness as the legislation continues to take effect.

Sharing Data

One of the requirements under MACRA is for providers to enhance clinical measures and data analytics to strengthen members’ experiences. Health plans can assist by recognizing where providers lack expertise in data-related facts to offer input and support where it’s most beneficial.

For example, a provider may not have as much knowledge on advanced data science, but health plans can share their predictive models and tools to strengthen analytics. Sharing advanced technical infrastructure to facilitate data exchange will enable providers to access a more complete picture of members’ profiles. In return, the picture will provide a higher quality service to individual members, as well as opportunities for health plans to continue offering tailored consulting and data support.

At its best, sharing data to improve clinical measures is a win-win scenario. The Healthcare Effectiveness Data and Information Set (HEDIS) is a tool used by more than 90 percent of America’s health plans to measure performance on important dimensions of care and service. Just as HEDIS calls for measurement, MACRA also encourages health plans to aid providers with reporting standards. Under these rules, health plans are required to record a wealth of information on members, and when shared with providers, the tide lifts all boats.

Partnering to Manage Risk

Some of the changes under MACRA are reminders for providers to be highly aware of risk management. Providers will seek strong partners with the necessary skills, experience and knowledge to ensure they do not take on risk greater than they can support. To assist, health plans should enter into risk-sharing relationships, such as value-based contracts, with high-performing providers.

Health plans should actively strive to be strong partners by enabling robust data analytics that support quantitative action plans in the areas of quality and clinical care gaps, medical cost and trend analysis, population health, as well as member-risk management. As health plans partner with providers, they should also stay flexible on potential changes to provider payments as the pay-for-performance model(s) mature over time.

Financial Awareness

Health plans also need to be aware of the financial considerations that result from increased value-based contracting for small and large providers.

Under MACRA, smaller providers and individual physicians are more likely to be exposed to potential increase in costs, which may result in additional provider considerations. As Medicare payments shrink, these providers will look to shift costs to other payers, making contract negotiations more difficult and potentially increasing unit costs for some services. Large physician groups, or those located in markets with progressive healthcare systems, will look to negotiate even higher reimbursement rates due to the potential for increased competition.

Health plans should also be aware of potential impacts beyond Medicare fee-for-service (FFS), which is the initial focus of the MACRA legislation. Pay-for-performance is likely to extend beyond Medicare FFS into other health plan lines of business, such as Medicaid or commercial plans. For example, under MACRA, Centers for Medicare and Medicaid Services stated it would consider permitting Medicaid Medical Homes to count as an alternative payment model if participating practices would risk at least four percent of their revenue in 2019 and five percent in 2020.

Why This Matters

Overall, MACRA creates a tall order as it aims to increase pay-for-performance and decrease care based on quantity. This notion is an altruistic adjustment for the health system and each party has a specific role to play to achieve the dream. But the backbone of this goal is collaboration between health plans and providers. Collaboration will result in shared clinical measures, awareness and management of risk, lower healthcare costs and, most importantly, improved patient outcomes.

The Top Three Hidden Impacts of MIPS – MACRA Monday

Posted on July 10, 2017 I Written By

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust

Independent Primary Care Practice Success and MACRA – MACRA Monday

Posted on July 3, 2017 I Written By

The following is a guest blog post by Christina Scannapiego who currently writes the technical documentation and educational content for HealthFusion MediTouch. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

Can participating in a PCMH and programs like Chronic Care Management improve your MIPS total score?

The shift to fee-for-value healthcare may feel like discouraging, foreign territory. However, if you’re already participating in value-based models like a patient centered medical home or chronic care management, your practice is more poised for success during this transition.

Chronic Care Management

The Centers for Medicare and Medicaid Services (CMS) have increased reimbursement for Chronic Care Management (CCM) services. Now, a provider has the potential to earn more than $50,000 per year under the CCM program. Patient-centered care, patient engagement and better care coordination are the core objectives of CMS. Participation in CCM could weigh heavily on your total MIPS score. CCM helps patients by extending care support beyond face-to-face appointments. Participation in this program will help you move the needle in four performance categories by extending care between office visits, controlling costs, increasing care coordination, enhancing doctor-patient relationships to help improve patient outcomes.

CCM and MACRA overlap across several MIPS components:

  • Advancing Care Information: Previously Meaningful Use, meant to achieve patient engagement and promote the electronic exchange of information, practice analytics and reporting capabilities using an EHR.
  • Quality measures: At least 30 measures including many high priority items are common to the CCM program.
  • Clinical Practice Improvement Activities: Patient engagement is one of the main objectives of both CCM and MACRA. Providing 24/7 access to clinicians and coordinating care across provider settings plays an integral part in the CCM objectives and will boost your score in this performance category.
  • Cost: Although providers aren’t responsible for reporting data in this performance category, participating in CCM can lower costs due to preventable hospitalizations from poor medication adherence and care transitions to other providers. Patients with multiple chronic conditions can often pose the highest costs in healthcare. Effectively managing the care of patients will ultimately benefit their overall well-being and the health of your practice.

Patient Centered Medical Home

The PCMH model was established to help deliver patient-centered care through care coordination, preventative services, population health management and extended access to care services. This model thrives from robust patient engagement, which is one of MACRA’s most important goals. MIPS scoring methods favor those participating in PCMH by automatically scoring providers with 100% in the Advancing Care Information performance category. PCMH recognized practices will also likely get credit in the Advancing Care Information performance category because of their experience with NCQA standards.

The importance of both CCM and PCMHs in the new healthcare regime have placed primary care physicians in a unique and opportune position; one in which the independent provider stands to find success amidst change. The impact of MACRA on healthcare is “monumental” and “herculean,” said the Director of Provider Innovation Strategies at DST Health Solutions in her presentation, “The Role of PCMH Under MACRA.” MACRA isn’t a momentary, passing legislation — it’s had bipartisan support from the beginning and it’s here to stay. Luckily for PCHM and CCM participators, this new legislation and enormous impact becomes more manageable.

About the Christina Scannapiego:
Christina Scannapiego has been a technical, health and lifestyle writer for more than 10 years. Christina currently writes the technical documentation and educational content for HealthFusion MediTouch, an Electronic Health Records software platform. HealthFusion and its MediToch cloud software suite is a subsidiary of Quality Systems/next Gen. MediTouch is comprised of a range of web-based software solutions for physicians, medical practices and billing services.

2018 QPP Proposed Rule: What it Means for MIPS & Quantifying the Impact on Specialty Practices – MACRA Monday

Posted on June 26, 2017 I Written By

The following is a guest blog post by Justin Barnes, Board Advisor at iHealth Innovations. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

The Centers for Medicare and Medicaid Services (CMS) recently released a Proposed Rule highlighting recommended updates to the 2018 reporting period of the Quality Payment Program (QPP). Like flexibilities extended in 2017, the proposal seeks to further reduce reporting burdens on small practices and rural providers in the program’s second-year reporting period.

Merit-based Incentive Payment System (MIPS) reporting track updates include:

  • Increased low-volume exemption thresholds (<200 patients or <$90,000 in payments)
  • New virtual group options for solo practitioners and groups with 10 or fewer Eligible Clinicians
  • Extending “pick your pace” flexibilities into 2018
  • Postponing introduction of the Cost category to MIPS composite scores
  • Factoring MIPS performance improvements into quality scores
  • Permissions for facility-based providers to report through the facility where they do most of their work instead of the practice
  • Permitting the use of 2014 CEHRT in 2018 reporting

The Rule introduces new MIPS bonus point opportunities for:

  • The use of 2015 CEHRT
  • The care of complex patients

Recommendations also extend small practice relief including:

  • Up to 5 bonus points for practices with 15 or fewer Eligible Clinicians
  • Hardship exemption for Advancing Care Information category measures
  • Additional points on Quality measures that don’t meet completeness requirements

Comments on the Proposed Rule are due by August 21, 2017. Physicians have until October 2, 2017, to begin collecting performance data for the inaugural 2017 MIPS reporting period.

Calculating MIPS: The Financial Impact on Specialty Practices

Results from a crowdsourced survey fielded by Black Book Research among nearly 9,000 physician practices from February through April of 2017 reveal that 94 percent of physician participants were unaware or unsure of how to predict their 2017 MIPS performance scores. Seventy-seven percent of practices with three or more clinicians reported intentions to purchase MIPS compliance technology solutions by the fourth quarter of this year, largely driven by an inability to independently determine earning potential under MACRA.

Orthopedics, cardiology and radiology are among the highest incentivized specialties under MIPS. To help specialty practices quantify the fiscal impact MIPS poses, we evaluated average Medicare earnings by specialty to establish the MIPS calculations below. These estimates are based on bare minimum earnings and losses that could be greater for practices with larger Medicare patient populations and/or more physicians. (Calculations are strictly illustrative estimates.)

Cardiology Practices
Estimated average payment adjustment for a 5-clinician cardiology practice in 2019 alone: $43,601
Number of cardiology-specific QPP measures: 20

Orthopedics Practices
Estimated average payment adjustment for a 6-clinician orthopedics practice in 2019 alone: $34,603
Number of orthopedics-specific QPP measures: 21

Radiology Practices
Estimated average payment adjustment for a 6-clinician radiology practice in 2019 alone: $30,117
Number of radiology-specific QPP measures: 22

Note: The above projections assume the full incentive and penalty will be paid out as outlined in the MACRA law. However, the positive and negative payment adjustments will be scaled so the program is budget neutral. This means that the positive payment adjustments will have to be offset by penalties.

Navigating the Transition to MIPS
As clinicians prepare for reporting under MIPS, establishing specialty-specific expertise on financial, clinical and technical objectives can help practices thrive rather than just survive.

Tips as you for prepare for MIPS:

  • Know your reporting options and pick your path.
  • Choose measures that play to the strengths of your specific specialty practice. Review your current billing codes and Quality and Resource Use Report to help determine these areas.
  • Do a technology asset inventory to make sure you can track the required CQMs.
  • Customize your EHR for track your selected measures or ID an outsource vendor to assist.
  • Work towards minimum reporting requirements to avoid a penalty with a stretch goal to report on the full required measures to maximize positive adjustment earnings potential.

Additional resources:
QPP website
An overview and support documentation is available at the CMS QPP website here.

MIPS EDU Program
A new “Quality Payment Program in 2017: Pick Your Pace Web-Based Training” course with Continuing Education Credit is available through the Learning Management System. Learn more here.

2017 CMS-Approved Qualified Clinical Data Registries
Additional specialty-specific measures are available via approved 2017 QCDRs to meet MIPS reporting requirements. Options for cardiology, radiology and orthopedic practices are included. Learn more here.

About the Author:
Justin Barnes is a nationally recognized business and policy advisor who serves as Chairman Emeritus of the HIMSS EHR Association as well as Co-Chairman of the Accountable Care Community of Practice. As Board Advisor with iHealth, Justin assists providers with optimizing revenue sources and transitioning to value-based payment and care delivery models. Justin has formally addressed Congress and the last three Presidential Administrations on more than twenty occasions on the topics of MACRA, value-based medicine, accountable care, interoperability, consumerism and more. He is also host of the weekly syndicated radio show “This Just In.” Justin can be found on Twitter at @HITAdvisor.

New Eligibility Exclusions in the MACRA Final Rule – MACRA Monday

Posted on October 17, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

Last week on Friday, we posted the various resources available for the MACRA Final Rule. As you can imagine, one weekend isn’t nearly enough time to process what’s in the final rule. It’s going to take weeks to really get through it all. In fact, we might take a few weeks off from MACRA Monday to process it all.

That said, we wanted to do a quick post this MACRA Monday to talk about the new eligibility requirements and thresholds in the MACRA final rule. For reference, here’s our previous post that looked at MIPS eligibility in the MACRA proposed rule.

In the final rule, it looks like there are still 3 categories of exceptions: new doctors, low medicare volume and participation in an advanced APM. The big change in the MACRA final rule is what is considered low medicare volume. In the proposed rule it said, “$10,000 and providers care to 100 or fewer Medicare patients in a year.” Note the “and” in that requirement. In the MACRA final rule it excludes doctors with less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients.” Note the “or” and the move from $10k in Medicare volume to $30k in Medicare volume.

With these three exceptions, Andy Slavitt sent the following tweet:

I quickly commented, “Now you’re going to get the small practices complaining that they were excluded from the incentives. #MACRA #CantWin” CMS’s MACRA executive summary says that they considered allowing those that were below these levels to opt into MIPS if they desired, but they “determined that it was inconsistent with the statutory MIPS exclusion based on the low-volume threshold.” I think the complaining for not being allowed to participate will be pretty minimal. 4% of such a small volume of Medicare won’t be that impactful for most.

There’s the start of our analysis of the MACRA final rule. A good first step to knowing if you qualify to participate in MACRA. Let us know if there are changes in the final rule that you’ve noted or that are bothering you. We’d love to hear them in the comments.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Overview of the Advancing Care Information Category in MIPS – MACRA Monday

Posted on October 3, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

In our last edition of MACRA Monday we covered 3 of the 4 categories that are part of MIPS: Quality Performance, Resource Use (Cost), and the new Clinical Practice Improvement Activities Category. This week we’ll be covering the details of the 4th category known as Advancing Care Information.

The Advancing Care Information category is probably one you’ve heard about since it’s the replacement for the well known meaningful use program. One change that will be available in the Advancing Care Information category that wasn’t available in meaningful use is that you may participate as an individual or as a group. It’s also worth noting that the Advancing Care Information category makes up 25% of the total MIPS composite score.

One thing that can be a little confusing about MIPS is that the Advancing Care Information category has a score within a score. Advancing Care Information makes up 25% of the MACRA score, but in order to calculate how much of the 25% you’ll receive you have to figure out how many points you receive in the Advancing Care Information category. This chart illustrates how the points will be calculated:
advancing-care-information-scoring-for-macra
As you can see from this chart, your base score, performance score, and any bonus points will be used to calculate whether you receive the full 25% for your MIPS composite score or not.

The base score requires that you report your participation in the following items:

  • Protecting PHI
  • ePrescribing
  • Patient Access
  • Patient Engagement
  • HIE
  • Public Health and Clinical Data Registry Reporting

The good thing about the base score is that you’ll receive full credit for each item if you submit the reports for each item. There’s no threshhold required.

The performance score focuses on the following areas:

  • Patient Electronic Access
  • Coordination of Care through Patient Engagement
  • HIE

Unlike the base score, the performance score will need to achieve certain performance in order to receive points. You’ll also notice that these three areas indicate CMS’ efforts to focus on patient access and health data exchange.

A few other high level things to note for the Advancing Care Information category. First, they’ve removed the “All or Nothing” approach that existed in the EHR (Meaningful Use) program. Second, they’ve removed redundant measures to try and streamline the program. Third, they’ve eliminated CPOE and CDS objectives. Finally, they’ve reduced the number of required public health registries.

As you can see from the list above, this will not be that different than meaningful use. So, if you’ve been participating in meaningful use, then advancing care information won’t be a huge obstacle. If you haven’t been participating in meaningful use, well then you have some work to do.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Details for 3 MIPS Performance Categories – MACRA Monday

Posted on September 19, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

Last week we got a bit side tracked on MACRA Monday as we covered the news about modifications to the MACRA timeline. That seems to be a welcome change. As we mentioned at the end of our post on the MIPS performance categories and MIPS composite score, now we’re going to start diving into the details of those performance categories starting with: Quality Performance, Resource Use (Cost), and the new Clinical Practice Improvement Activities Category.

Quality Performance Category
This category is a replacement for PQRS, but is a reduction from 9 to only 6 measures. Plus, there is no longer a domain requirement. MIPS also expands the program to include close to 300 measures. To combat this explosion of options, they’ll also be offering specialty specific measure sets so that each specialty can more easily identify the measures that might be best for their specialty.

The Quality Performance category makes up 50% of the MIPS composite score.

Resource Use (Cost) Category
The resource use category is also often called the cost category and is a replacement of the value based modifier. The great part of the resource use category is that there is no data submission required to report your work in this category. Instead, this MIPS category will be calculated based on your Medicare claims. MACRA will add 40+ episodic specific measures so providers have more options to participate in this category.

The Resource Use (Cost) category makes up 10% of the MIPS composite score.

Clinical Practice Improvement Activities Category
The CPIA (Clinical Practice Improvement Activies) category that is the new category created as part of MACRA. It will include 90+ activities to choose from and you must participate in a minimum of one activity. Small practices (ie. 15 or fewer professionals) can participate in 2 activities and receive full credit for CPIA. Practices participating as a Patient Centered Medical Home (PCMH) also receive full credit for this category. Participation in an APM gives you 50% credit.

The Clinical Practice Improvement Activities category makes up 15% of the MIPS Composite Score.

That’s the general overview for these three MIPS performance categories. We’ll cover the Advancing Care Information category next week since it’s a bit more complicated.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Modifications to the MACRA 2017 Reporting Period #PickYourPace – MACRA Monday

Posted on September 12, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

As we mentioned near the start of the MACRA Monday series, many were predicting a delay or at least a modification to the MACRA timeline. While we’re still waiting for the MACRA final rule to come out with the official changes, Andy Slavitt, Acting Administrator of CMS, has announced some of the changes that will be in the MACRA final rule. Here’s the introduction to why they’re making these changes to MACRA (or the Quality Payment Program as they like to call it now):

We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

It’s comforting to many to know that they hear doctors pleas for help with all the reporting. We’ll see if the changes in the MACRA final rule will be enough.

As part of the announcement, Andy Slavitt said that the MACRA and MIPS program will still begin on January 1, 2017 with payment adjustments (ie. incentives or penalties) being paid in 2019 like we’d noted before. However, CMS now plans to provide multiple options to eligible physicians and other clinicians to avoid the negative payment adjustments in 2019.

There will now be 4 options available:

Option 1 – Test the Quality Payment Program.
For this option, you just have to submit “some data” to the Quality Payment Program and you’ll avoid the negative payment adjustment. Basically, CMS just wants to make sure you’re connected and ready to participate in future years. While you won’t get a negative payment adjustment, you always won’t get a positive adjustment either. It will be interesting to see what the final rule defines as “some data.” I expect it will be pretty minimal.

Option 2 – Participate for part of the calendar year.
This option allows you to submit information for a reduced number of days in 2017. In other words, your performance period could start after January 1, 2017 and you could just do MIPS reporting for part of the year. This would qualify you for a small positive payment adjustment. I’ll be interested to see the details in the MACRA final rule which outlines how much smaller the payment adjustment will be and how it will be calculated.

Option 3 – Participate for the full calendar year.
This option is basically what’s in the MACRA proposed rule. You can take part for the full 2017 calendar year and potentially qualify for a modest positive payment adjustment. CMS suggests that many will be ready for this. We’ll see if that’s the case given the compressed timeline from when the final rule is published and the release cycles of EHR software companies.

Option 4 – Participate in an Advanced Alternative Payment Model in 2017.
It seems that participation in an Advanced APM is the same as the proposed rule. Of course, if you’re participating in an Advanced APM, then you avoid the penalties and don’t have to worry about MIPS. Nothing new there.

It’s no surprise that fewer penalties and looser requirements has been applauded by many in the healthcare community. It’s pretty rare that people complain about a loosening of government regulation and wish they would require more. Personally, I think the changes are a good thing. CMS will still be able to get data from organizations that participate for the full year. Hopefully, they’ll use that to guide any modifications for future years. However, they also aren’t penalizing those organizations who won’t be fully ready in 2017 because of the short timelines.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

MIPS Performance Categories and the MIPS Composite Score – MACRA Monday

Posted on August 29, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of MACRA.

As mentioned, next up we’re going to cover the 4 MIPS performance categories. Each of these categories are listed in the graphic below and will contribute to what is called your MIPS Composite Score.
MIPS Performance Categories

At first, these four new category names might be confusing, but here’s the translation you need to know for each category that will illustrate how MIPS really just rolls up three existing programs and adds one new program as follows:

  • Quality Performance Category – PQRS Replacement
  • Resource Use (Cost) Category – Value Based Modifier Replacement
  • Clinical Practice Improvement Activities Category – New
  • Advancing Information Category – Meaningful Use (EHR Incentive Program) Replacement

I’m not sure why the government thought we needed new names for each program, but they decided that was the best route. Maybe they wanted to leave the past behind and move forward without the baggage that exists with the previous names. Regardless, 3 of the 4 MIPS performance categories are programs that most of you probably already know about. There are slight changes with each of the 3 programs (PQRS, Value Based Modifier, and Meaningful Use) under MIPS which we’ll cover in a future part of this series. In most cases, each of those 3 programs was simplified under MIPS.

In order to determine your MIPS Composite Score, each provider will receive a score on a 100 point scale. Each of the 4 performance categories contributes to the 100 point scale and have been weighted as follows:
MIPS Performance Categories Weighting - Year 1

Yes, that means that if you are already doing PQRS (Quality) and Meaningful Use (Advancing Care Information), then you’ll be well positioned for 75% of the points for the MIPS composite score. If you’re only doing PQRS, you’re still in a position to get 50% of the MIPS composite score without too many changes from what you’re doing today. Of course, that assumes you continue those efforts under the modified MIPS requirements in 2017. If you’re not doing PQRS, meaningful use, or value based reimbursement, then you’ll have some serious work to do in order to not be penalized under MIPS.

Once CMS calculates your MIPS composite score, they’ll compare that score against the threshold to determine the adjustment received. Speaking hypothetically, let’s say the MIPS threshold was set at 64 and your MIPS Composite Score was 64. Then, you wouldn’t receive an increase or decrease to your reimbursement. Of course, if you scored above a 64, then you’d receive a bonus payment. If you score below a 64, you’d be penalized.

CMS has said they intend to publish the benchmarks and thresholds prior to 2017. Given the short time frame, this is going to be a real challenge and is likely another reason why it’s possible that MACRA could be delayed. However, it’s good to know that they’re planning to publish the MIPS threshold in advance so practices can plan accordingly. The great part of this scoring system is that unlike meaningful use which was all or nothing, this scoring gives providers credit for partial performance.

It’s worth also noting that the MACRA program must be budget neutral. So, if more providers are getting penalized than are getting incentives, the HHS Secretary will use a scaling factor to increase the incentives paid to participating providers that qualify. HHS also has $500 million available separate from the normal incentive payments to reward exceptional performance. I have yet to see details on this, but it will be interesting to watch and see what they use as the criteria for exceptional performance. I wonder how much higher of a composite score you’ll need above the threshold to be considered an exceptional performer.

Next week we’ll start going through each of the performance categories at a high level and discuss the changes made to each program that’s been rolled into MIPS and the new Clinical Practice Improvement Activities category.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.