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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.

Bill Could Cut Meaningful Use Reporting Period Drastically

Posted on April 25, 2016 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.

A bill has been filed in Congress that would slash the Meaningful Use reporting period from one year to 90 days. This seems to be a challenge to CMS, which has reportedly held firm in the face of pressure to cut the reporting period on its own.

Supporters of the bill, which is backed by a broad coalition of industry trade groups, argue that a 365-day reporting period is unduly burdensome for providers, and will become even more awkward as MACRA requirements fall into place. Cutting the reporting period “will continue the significant progress providers are making to harness the use of technology to succeed in new payment and care delivery models,” argued a coalition of such groups in a letter sent to CMS last month.

That being said, it’s not clear how the structure of Meaningful Use incentives will play out under MACRA. So the reporting period change may or may not be as relevant as it might have been before the MACRA rules were set to be announced.

CMS leaders have said that the upcoming Merit-Based Incentive Payment System (MIPS) – which will probably fall in place under MACRA in 2017 — is designed to unify incentive payments. Specifically, it integrates existing MU, PQRS and Value-Based Payment Modifier programs. MIPS payments will be based on a weighted score rating providers on four factors: quality (30%), resource use (30%), Meaningful Use (25%) and clinical practice improvement activities (15%). This suggests that a focus on reporting requirements is probably a matter of closing the barn door after the horse has left the stable.

On the other hand, since Meaningful Use isn’t going away completely, maybe cutting the reporting period required is necessary. If providers are being rated on a set of factors of which MU is just a part, reporting for an entire year could certainly impose an administrative burden. Why set providers up to fail by forcing them to overextend their resources on reporting?

I believe that reducing Meaningful Use requirements is a sensible step to take at this point. While there are probably those who would argue the point, I submit that MU has been pretty successful in motivating providers to rethink their relationship with HIT, and has even help a subset to completely rethink how they deliver care. Now, it’s time to move the ball forward, to a more holistic approach that goes beyond regulating care processes.

Admittedly, it’s possible that cutting the reporting period, or otherwise shifting the emphasis away from regulating HIT use, might cause some providers to slack off in some way. But to my way of thinking, that’s a risk we need to take. After investing many billions of dollars on promoting smart HIT use, we have to assume that we’ve done what we can, and focus on smart quality measures. With any luck, the new measures will work better for everyone involved.

Unlocking EHR Data to Accelerate Clinical Quality Reporting & Enhance Renal Care Management

Posted on March 18, 2015 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.

The following is a guest blog post by Christina Ai Chang from DaVita and Vaishali Nambiar from CitiusTech Inc.
Christina and Vaishali
When healthcare providers began achieving Meaningful Use (MU) — the set of standards, defined by CMS, that allows for providers to earn incentive dollars by complying with a set of specific criteria — a health IT paradox emerged. The reports required for incentive payments are built on data the EHR captures, however, EHRs don’t typically have built-in support for automated reporting. This places a time-intensive manual burden on physicians as they report for MU quality measures. In other words, a program intended to increase the use of technology inadvertently created a new, non-technical, burden. The need to manually assemble information for reports also extended to the CMS Physician Quality Reporting System (PQRS) incentive program. As with many providers, EHR reporting shortcomings for these CMS programs severely impacted the kidney care provider, DaVita Healthcare Partners, Inc. (DaVita).

As one of the largest and most successful kidney care companies in the United States, DaVita has constantly focused on clinical outcomes to enhance the quality of care that it provides to its patients. In its U.S. operations that include 550 physicians, DaVita provides dialysis services to over 163,000 patients each year at more than 2,000 outpatient dialysis centers. These centers run Falcon Physician, DaVita’s nephrology-focused solution that largely eliminates paper charting by capturing data electronically and providing a shared patient view to caregivers within the DaVita network.

Falcon Physician serves DaVita very well in its design: renal-care specific EHR capabilities and workflows to support patients with chronic kidney disease (CKD). However, federal incentive programs like MU and Physician Quality Reporting System posed their own challenges. Falcon, like most EHRs, did not have the sophisticated data processing and analytics capabilities needed to meet the complex clinical quality reporting mandated by these programs. With limited built-in support for automated reporting, DaVita physicians had to manually calculate denominators and complete forms for submission to CMS for quality measures reporting, typically taking five to six days per report. With the organization averaging 800 encounters per physician each month, this placed a highly time-intensive and manual burden on physician offices. In addition, manual reporting often resulted in errors, since physician offices had to manage ten or more pieces of data to arrive at a single measure calculation, and do that over and over again.

The Need to Automate Reporting – But How?

To address the time and accuracy issues, DaVita recognized it would need to unlock the data captured by the EHR and use an effective data analytics and reporting tool. To begin evaluating options, the organization put together a team to explore two potential paths: creating a proprietary reporting capability within the EHR, or integrating a third-party solution.

It became clear that proprietary development would be challenging, mainly because of the technological expertise that would be needed to build and maintain sufficiently advanced analytics capabilities. It would require special skillsets to build the rules engine, the data mapping tools, and the visualizations for reporting. In addition, DaVita would need to maintain a clinical informatics and data validation team to assess the complex clinical quality measures, develop these measures, and test the overall application on an ongoing basis. Further, DaVita would also need to get this functionality certified by CMS and other regulatory agencies on a periodic basis.

While looking for a third-party solution that could easily integrate with Falcon, DaVita came across CitiusTech, whose offerings include the BI-Clinical healthcare business intelligence and analytics platform. This platform comes with pre-built apps for multiple reporting functions, including MU and PQRS. Its application programming interface (API) simplifies integration into software like Falcon. The platform aligned closely with DaVita’s needs, and with a high interest in avoiding the expense, time and skillset hiring needed to build a proprietary reporting function, the organization decided to move forward with third-party integration.

Accelerated Implementation and Integration

Implementation began with a small proof of concept that delivered a readily scalable integration in fewer than six weeks. DaVita provided the database views and related data according to the third-party solution’s specifications. This freed DaVita not just from development, but also from testing, installation, and configuration of the platform; thereby, saving time and money, and creating a more robust analytics platform for DaVita’s physicians. In the end, going with an off-the-shelf solution reduced implementation time and cost by as much as two-thirds.

Integration with the third-party platform enabled DaVita’s Falcon EHR system to completely automate the collection and reporting of clinical quality measures, freeing up tremendous physician time while improving report accuracy. With additional capabilities that go beyond solving the reporting problem, the new solution translates EHR data into meaning performance dashboards that assist DaVita physicians in the transition to pay-for-performance medicine.

The platform with which DaVita integrated is ONC-certified for all MU measures for eligible professionals (EPs) and eligible hospitals (EHs). Falcon was able to leverage these certifications and achieve both MU Stage 1 and Stage 2 certification in record time. This also enabled Falcon to accelerate its PQRS program and offer PQRS reporting and data submission capabilities.

Automated Reporting and Dashboards in Action        

Today, hundreds of DaVita physicians use the upgraded EHR, and the integrated business intelligence and analytics function eliminates the need for these doctors to perform manual calculations for MU and PQRS measures. Where manually creating reports used to take five to six days, pre-defined measure sets now complete reports and submit data almost instantly.

With the manual reporting problem solved, DaVita’s physicians now take automation for granted. What they see on a daily basis are the quality-performance dashboards. These dashboards give them a visual, easily understood picture of how they’re doing relative to quality measures, and the feedback has been extremely positive. Many powerful reporting features are highly appreciated, such as key measurements appearing in red when it’s time to change course in care provision to meet a particular measure. Such information, provided in real-time with updates on a daily basis, has led to very strong adoption of the new reporting capabilities among physicians.

Currently, DaVita is working to develop a benchmarking tool that can rate all physicians within a location. The focus on quality-measurement rankings relative to their peers, with drill-downs to specific indicators such as hypertension and chronic kidney disease progression, will allow physicians to focus on enhancing care delivery.

Unlocking data located in the EHR has helped DaVita comply with MU and PQRS. In the coming years, the upgraded EHR will help physicians comply with evidence-based guidelines and optimize increasingly complex reimbursement requirements.