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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.

Who’s Eligible for MIPS? – MACRA Monday

Posted on August 22, 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.

In years 1 and 2 of MACRA, those that are eligible to participate are going to be very similar to past programs. However, the secretary does have the option in year 3 to look at expanding the program to include other healthcare providers that don’t meet the initial requirements. You can see this illustrated in the graphic below.
MIPS Eligibility

There are three exceptions to the above graphic. The first exception is if you’re a first year partipant in Medicare Part B. This gives these doctors time to get up to speed before they’re required to participate in MIPS. They will have to participate in year two. There is also a MIPS exception for low volume providers. If you’re a provider that has Medicare billing charges that are less than or equal to $10,000 and providers care to 100 or fewer Medicare patients in a year, then you are not required to participate in MIPS. The third exception is those providers that are already participating as an advanced APM (see what we wrote about Advanced APM eligibility for more details) are not allowed to participate in MIPS. Here’s a summary of these exceptions:
Not Eligible for MIPS

If all of this Advanced APM and MIPS eligibility is confusing to you, here’s a flow chart which will walk you through the process of knowing whether you’re an advanced APM, whether you must participate in MIPS or whether you’re not subject to MIPS:
APM or MIPS - Where Do You Fit Into MACRA

Next up, we dive into the details of MIPS and the 4 MIPS categories.

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

MIPS Overview – MACRA Monday

Posted on August 15, 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.

The Merit-based Incentive Payment System or MIPS as we now know it is going to be a big part of most practices future. As we mentioned previously, most practices will be participating in the MIPS program as opposed to the APM program under MACRA. Here’s a quick overview of the MIPS program. Over the next months, we’ll be diving deeper and deeper into the details of MIPS.

MIPS replaces 3 programs that will likely be familiar to most readers: PQRS, the Medicare EHR Incentive Program (Better known as meaningful use), and the Value-Based Payment Modifier (VBM). The last one might not be as familiar to people, but PQRS and Meaningful Use are likely very familiar. In future posts, we’ll dive into the changes to these programs that come as they’re rolled into MIPS.

It’s worth noting that these programs will continue to run in their current from through 2018. Plus, the Medicaid EHR Incentive Program and the Medicare EHR Incentive Program for Hospitals will continue. Along with rolling the 3 current programs into MIPS, MACRA also adds a new program to MIPS called the Clinical Practice Improvement Activities (CPIA).

The first performance period for MIPS is 2017 with MIPS adjustments happening in 2019. At least that’s the way it’s listed in the proposed rule. Many are suggesting that there’s no way that MIPS will be for all of 2017. They argue that it has to be either delayed or moved to a 90 day reporting period (which is basically a 9 month delay). We’ll see what they finally decide when the MACRA final rule finally comes out.

The potential MIPS adjustments to your Medicare Part B payment are 4% in 2019 and grow to 9% in 2022. Remember that these adjustments can be both positive and negative based on how well you participate in the MIPS program. We’ll dive into the MIPS Composite Score that determines your MIPS payment adjustment in a future post. Here’s a charge which illustrates the MIPS timeline and incentives:
MIPS Incentives and Penalties
That’s all for our MIPS overview. Next up we’ll dive into who is eligible for MIPS and who is not eligible for MIPS.

You can see how if you’re already participating in PQRS, Meaningful Use, and the Value-Based Modifier, then you are well positioned to do well in MIPS. This will become even more clear when we discuss the weighted scoring that each of these pieces of MIPS receives. Of course, if you haven’t been participating in these programs, then MIPS will definitely be a pretty big hill to climb.

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