Secrets to Beating the Curve MIPS & MACRA Secrets to Beating the Curve

Measured Against the Performance Standard for MIPS Rules in Effect Now Will Adjust Payment in 2019 It’s Almost 2018! (Don’t Plan to Quit 12/31/2018) Measured Against the Performance Standard for MIPS

How Do We Start TOGETHER Get psychologically prepared Most don’t want, some don’t like, but that ABSOLUTELY does NOT MATTER Get physically prepared It’s going to take MORE TIME & Money Let’s DO IT, Let’s Do It RIGHT, and Let’s Do It TOGETHER

MACRA Medicare Access & Chip Reauthorization Act of 2015 Move from Volume-based fee-for-service pay to Value-based incentive pay Quality Payment Program (Designed to “FIX” cost control issues) Revenue Neutral!

MIPS and Advanced APMs Merit-based Incentive Payment System All Clinicians EXCEPT, 1st year, Below Threshold ($30K & 100 patients) & Certain Advanced APMs [Hospitals, and Facilities] {Rural Providers & Less than 15} Participation Years 1 & 2 Physicians, PAs, NPs, Clinical nurse specialists, Certified registered nurse anesthetists Everyone else get ready!

MIPS and Advanced APMs Most are MIPS! Advanced Alternative Payment Models Only QP and Advanced APM , partial for non-QP Taking the place of Physician Quality Reporting System (PQRS), Value-based Payment Modifier, and EHR or Meaningful Use Most are MIPS! (About 100,000 out of 600,000 w/ 50K margin of Error)

(It’s the CMS.gov Website) First Things First Check National Provider Identifier (NPI) https://qpp.cms.gov/participation-lookup (It’s the CMS.gov Website) Check Reimbursement & Patient Population for Medicare Part B Most Providers are MIPS, could be MIPS APM Advanced APMs Risk/Benefit Analysis

Critical Dates Full Participation 2017 Report for 90 days after January 1, 2017 Submit some data in 2017 (Neutral) 1 Quality or 1 Improvement or 4-5 Required Advancing Care Start by October 2, 2017 Performance Data due March 31, 2018

MIPS Submission Methods Administrative Claims EHRs Qualified Clinical Data Registries QCDR and Qualified Registries CMS Web Interface (only Groups of 25+ & already Registered) CAHPS for MIPS Survey (Consumer Assessment of Healthcare Providers and Systems (Groups & already Registered) Attestation

How to REPORT www.VisualizeHealth.Co Visualize Health CMS has a list of QCDR and Qualified Registries for MIPS Reporting (can submit all!) 100 entities on the list, ONE (1) QCDR is based here in Middle Tennessee Visualize Health www.VisualizeHealth.Co It appears there is one registry out of Knoxville (Some of them do not support ALL measures, so be Careful!)

Question About ACOs Some Accountable Care Organizations (ACOs) indicate MIPS Reporting is not necessary …WRONG! (There are Some ACOs Qualifying at Advanced APMS) Get it in writing! Without indemnity, may be no recourse

Initial Gain or Loss + or – 4% (with Fee Schedule up .5% thru 2019) Incentive increasing to 9% by 2022 (additional Fee Schedule up.25%MIPS and .75% for Advance APMS from 2026) Opportunity for Advanced AMPs to earn an additional 5% (Not MIPS) Must be a Risk Component to the Provider Or Special Group New Quality Measures- Yea!!

Composite Performance Score (CPS) Each Improvement Category is assigned a weight or value as a percentage of 100% Quality 60% (Replaces PQRS) Advancing Care 25% (Replaces EHR & Meaningful Use) Clinical Practice Improvement 15% (NEW) Cost 0% (Replaces Value-based Modifier) Cost is not utilized in 2017 reporting This should change in the future

Quality = 60% Report up to 6 Quality Measures 168 High Priority Measures (Reporting the minimum may have negative impact later) Including 1 Outcome Measure Readmissions or Potentially Avoidable Events 60 Points 90 days QCDR, Qualified Registry, EHR, and Claims

Advancing Care Info = 25% 2 Tracks- Objectives & Measures or Transition Fulfill Required Measures Security Risk Analysis (HIPAA & HITECH) ePrescribe Patient Access Summary of Care Request/Accept Summary of Care 15/11 Measures depending upon Transition option 50 base +90 performance +15 bonus = 155 points possible, but capped at 100%

Advancing Care Info Up to 9 Measures for Additional Credit (7 for Transition) Eligible Improvement Activities Certain Activities Apply for Base & Performance 100 Points 90 Days FOR BONUS -Public Health, Clinical Data, CEHRT QCDR, Qualified Registry, EHR, and Attest

Improvement Activities = 15% Report 4 Improvement Categories 92 Improvement Categories 9 Subcategories 14 High Weighted Only need 2, or 4 Medium Weighted Double points for less than 15 or Rural 40 Points 90 days QCDR, Qualified Registry, EHR, and Attest

Clinical Practice Improvement Activities Actually 40 Now

Improvement Activities Already added More Improvement Measures Try for high weighted measures first Do not do the MINIMUM Do not do NOTHING Remember, we are doing it TOGETHER, so just reach out, get some help, and get ‘er done!

CPS (Composite Point Score) If Quality is 42 of 60 points or .7 (70%) x 60% = 42 points If ACI is 50 of 100 points or .5 (50%) x 25% = 12.5 points If IA is 30 of 40 points is .75 or (75%) x 15% = 11.3 points (rounded up from 11.25) Cost = (14 of 20 points) x 0% weight x 100 = 0 points Total MIPS points = 42 + 12.5 + 11.3 + 0 = 65.8

Cost 0-30% Currently, Cost is set at Zero for 2017 and 2018 Approximately 40 cost measures 20 Points Claims Based Reporting

Advanced APMs Certified Electronic Health Record Technology (CEHRT) Quality Measures like MIPS expanded Medical Home Model (100% of IA for MIPS) or bear more than nominal Risk for $ Losses MIPS APM gets Special APM Scoring Too

($20,000 to comply MIPS vs. $200,000 potential Loss) Advanced APMs Subset of APM, so most APMs will report MIPS Advanced = RISK (Only 13 Made the List) Few Models and Provider is required to Reimburse CMS for Missed Targets Qualify for Extra 5% reimbursement Depending on volume, may not be worth risk ($20,000 to comply MIPS vs. $200,000 potential Loss)

Secrets to Beating the Curve MIPS & MACRA Secrets to Beating the Curve

1. Just Do It thanks NIKE 2. Get Help 3. Submit Something 4. Do Not Submit the Minimum 5. Look at the Measures and Go for the High Weighted ones 6. Reap the Rewards

Public Service Announcement (PSA) Reminder: 60 Day Reimbursement Rule Reporting and Returning SELF-Identified Overpayments Medicare Parts A & B Within 60 days of identification or at Cost Report Medicare Parts C and D are covered under a different rule (sort of) Through the exercise of Due Diligence Meaning What? Six (6) year lookback period

Julie-Karel(JK) Elkin, Member & CCO Data Privacy & Security Team Spicer Rudstrom PLLC 615.425.7355 (office) 615.504.6300 (cell) jkelkin@spicerfirm.com