1. QUALITY PAYMENT PROGRAM OVERVIEW OF OCTOBER 2016 FINAL RULE
PURDUE HEALTHCARE ADVISORS

2. PY2016 Meaningful Use & PQRS Deadlines
BEFORE WE GET STARTED…
PY2016 Meaningful Use & PQRS Deadlines
MU Attestation Deadlines (EPs & Hospitals)
Medicare: Monday, March 13th by 11:59pm EST
Indiana Medicaid: Monday, May 1st
PQRS Submission Deadlines (EPs)
EHR Direct or DSV (QRDA I or III): Monday, March 13th by 8:00pm EST
QRDA III: Monday, March 13th by 8:00pm EST
CMS Web Interface: Friday, March 17th, by 8:00pm EST
Qualified Registries or QCDRs: Friday, March 31st by 8:00pm EST
IQR/eCQMs Submission Deadline (Hospitals)
Monday, March 13th by 11:59pm EST

3. WHAT IS MACRA?
April 2015
Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) was signed:
Repeals the Medicare Part B Sustainable Growth Rate (SGR) formula used for determining Medicare payments for provider services; aka “doc fix”
Establishes new framework rewarding providers for providing high quality care
Combines existing quality reporting programs into a new, singular system
October 2016
CMS issued Final Rule putting into place key parts of the MACRA:
Establishes the Quality Payment Program (QPP), with 2 distinct paths:
Merit-Based Incentive Payment System (MIPS)
Advanced Alternative Payment Models (Advanced APMs or AAPMs)

4. And that means…?
The QPP changes the way Medicare pays clinicians for Part B services!
Offers financial incentives for providing high value care
Payment adjustments and bonuses begin in 2019
Most Medicare Part B clinicians will participate in MIPS. Some (~5-8% nationally) will become qualified participants (QPs) through participation in an Advanced APM (AAPM).

5. PROGRAMMATIC “NESTING DOLLS”
Medicare Access & CHIP Reauthorization Act (MACRA)
Quality Payment Program (QPP)
Merit-Based Incentive Payment System (MIPS) or
Advanced Alternative Payment Models (AAPMs)

6. HOW WILL THE QPP AFFECT ME?

7. IMPORTANT DATES

8. MERIT-BASED INCENTIVE PAYMENT SYSTEM

9. MIPS
PROGRAM BASICS

10. WHAT IS MIPS?
Sunsets multiple autonomous Medicare Part B quality reporting programs*, combining into a single & improved program
These “legacy programs” will phase out over the next 2 years:
2016 is the last performance year for each program
2018 is the last payment adjustment years for each program
Medicare EHR Incentive Program
(MU)*
Physician Quality Reporting System (PQRS)
Value-Based Payment Modifier (VM)
*MACRA & QPP does not alter or remove the Medicaid EHR Incentive Program

11. WHAT IS MIPS?
MIPS MU
PQRS VM IA
This new, single program is based facets from the legacy programs:
Quality (PQRS/VM-Quality Program)
Cost/Resource Use (VM-Cost Program)
Advancing Care Information (Medicare MU)
Improvement Activities (New Category)
Affects “traditional Medicare” (i.e. Part B), shifting payments to performance-based system based on these 4 categories
Flexibility within categories allow clinicians to choose activities & measures most meaningful to them
These standards align with AAPM reporting standards when possible

12. Performance Years & Payment Years
WHEN IS MIPS?
Performance Years & Payment Years

13. Performance Years & Payment Years
WHEN IS MIPS?
Performance Years & Payment Years
First performance year begins in 2017, with accompanying payment adjustments in 2019
2 year lookback, just as in current Medicare MU, PQRS, and VM programs
Performance period is one full calendar year*
2017 = Pick Your Pace
*see “Pick Your Pace”

14. Impacts on Eligible Clinicians
HOW DOES MIPS AFFECT ME?
Impacts on Eligible Clinicians
Financial Implications
Two types of impacts defined by the MACRA
Small, inflationary adjustment to Part B Fee Schedule (annually)
Payment adjustments to clinicians, based on performance (MIPS composite performance score)
Reputational Implications
Physician Compare
CMS publishes clinician-identifiable performance measures via the Physician Compare site
Each eligible clinician’s overall MIPS scores, along with each category score, & comparison to peers nationally

15. PAYMENT ADJUSTMENTS

16. MIPS PAYMENT ADJUSTMENTS
Methodology
The Composite Performance Score (CPS) accounts for:
Weights of each performance category
Exceptional performance
Flexibility of measures for various categories of clinicians (e.g. specialty, individual or group reporting)
Special circumstances for small practices, rural practices, and non-patient-facing MIPS eligible clinicians
CPS is compared to the MIPS Performance Threshold to determine the adjustment percentage the eligible clinician receives

17. MIPS PAYMENT ADJUSTMENTS
Medicare Part B Payments
Adjustments applied on a linear sliding scale

18. MIPS PAYMENT ADJUSTMENTS
Medicare Part B Payments
Positive (+) adjustments applied on a linear sliding scale:
Payment Year
Base Adjustment (up to)
2019
4x%
2020
5x%
2021
7x%
2022+
9x%
x is capped at 3.0
Neutral (=)
Performance Threshold
Negative (-) adjustments applied on a linear sliding scale:
Payment Year
Base Adjustment (up to)
2019
-4%
2020
-5%
2021
-7%
2022+
-9%

19. MIPS PAYMENT ADJUSTMENTS
Base Payment Adjustments
Adjustments applied 2 years after performance year (e.g adjustment is based on 2017 performance year)
Performance Threshold is mean or median of the composite score for all MIPS providers
Linear adjustment based on CPS, as compared to Performance Threshold
Scoring is either positive (+), negative (-), or neutral (=)
Highest performers eligible for Exceptional Performance Bonus
Additional payment adjustment of +10% for MIPS providers with CPS ≥ “additional performance threshold”
Additional Performance Threshold is defined as the 25th quartile of possible values above the Performance Threshold.
CPS ≤ 25% of the performance threshold will result in a maximum negative adjustment of -4%

20. MIPS PAYMENT ADJUSTMENTS
Transition Year 2017
Correspond to Pick Your Pace options of Test the QPP, Partial and Full Participation Years
Final score of 70 or above qualify for the exceptional performance score

21. ELIGIBILITY & PICK YOUR PACE IN 2017
1:00p-1:50p Breakout Session with Allison Bryan-Jungels

22. PERFORMANCE CATEGORIES & SCORING

23. 2017 MIPS PERFORMANCE CATEGORIES
Transition Year
Annual assessment of Medicare Part B providers in 4 weighted performance categories
Quality
Cost
Advancing Care Information
Improvement Activities
Composite Performance Score is then assigned, based on scale
Performance decrees payment adjustments, which increase over time

24. QUALITY Performance Category Year 1 Weighting: 60%
Choose which measures on which to be evaluated
Select 6 measures
1 outcome measure (or high priority measure, if outcome measure is not available)
Select from individual measures or a specialty set
>300 quality measures to choose
List of Quality Measures available on the Quality Payment Program’s Quality website
Key Changes from PQRS Program
Reduced reporting from 9 measures to 6, with no NQS Domain requirement
Emphasis on outcomes measures

25. QUALITY Category Scoring
Select 6 measures, a specialty set, or CMS Web Interface measures and report a minimum of 90 days
Participation for >90 days makes it easier for a clinician to meet case volume and receive more than 3 points
Receive 3-10 points on each measure
Based on performance against benchmarks
Failure to submit performance data for a measure = 0 points
Bonus points are available
*Maximum number of points = # of required measures x 10

26. RESOURCE USE (COST) Performance Category Year 1 Weighting: 0%
No reporting requirement for clinicians in 2017
CMS will still provide feedback
Weighting will be assigned as early as 2018
CMS calculates based on claims
Uses previously established measures reported in the QRUR
Assessment completed on all available resource use measures (as applicable to the clinician)
Can be risk-adjusted to reflect certain external factors
Will be compared to resources used to treat similar care episodes and clinical condition groups across practices
Key Changes from Value Modifier Program
Adding 40+ episode specific measures to address specialty concerns

27. Category Scoring (moving forward)
RESOURCE USE (COST)
Category Scoring (moving forward)
No Submission Requirement
Clinicians assessed via claims data
Can earn a maximum of 10 points per episode cost measure
No bonus points available

28. IMPROVEMENT ACTIVITIES
Performance Category
IA Categories:
Expanded Practice Access
Population Management
Care Coordination
Beneficiary Engagement
Patient Safety & Practice Assessment
Participation in an APM
Achieving Health Equity
Emergency Response & Preparedness
Integrated Behavioral & Mental Health
Year 1 Weighting: 15%
90+ IAs in 9 subcategories
Minimum selection of 1 IA to not receive zero score
Additional credit available for more activities
List of IA Inventory available on the Quality Payment Program’s IA website
Practices engaged with PHA may already be participating in activities that provide IA credit!
Full category credit for PCMH-recognized practices
1 high activity credit for GLPTN (TCPI) participation
Multiple medium activities associated with H3 participation
Medium activity credit for Implementation of formal QI methods (Lean services)

29. SPECIAL CONSIDERATIONS
No Clinician or Group has to attest for more than 4 IAs
Special Considerations for:
Groups of 15 or less, rural, or HPSA regions
Attest participation in up to 2 activities (20 pts)
Non-Patient Facing
APMs
Certified Medical Homes

30. IMPROVEMENT ACTIVITIES
Category Scoring
Activities weighted at:
Medium = 10 pts
High = 20 pts
Alternate weights:
Medium = 20 pts
High = 40 pts
(for clinicians in small, rural, underserved practices, or with non-patient facing clinicians)

31. ADVANCING CARE INFORMATION
Performance Category
Year 1 Weighting: 25%
Participate as an individual or as a group
5 required objectives
Flexible scoring for all measures
Scoring based on key measures of HIT interoperability & info exchange
Promotion of care coordination for better patient outcomes
Key Changes from Medicare MU Program:
No “all or nothing” and threshold measurement
Removal of “one-size-fits-all” perspective
Removal of redundant measures
Removal of CDS and CPOE objectives
Reduction of public health reporting measures

32. MIPS & MEDICAID MU PROGRAM
MIPS does not change the requirements under the Medicaid EHR Incentive Program!!
If you are participating in Medicaid MU:
You must still comply with the established requirements under that program
And also have Medicare Part B claims, then you will report to BOTH programs

33. TWO MEASURE SETS AVAILABLE
2017 Transition Year
Two Measure Sets Available, depending on CEHRT Edition
2017 ACI Transition Objectives & Measures
ACI Objectives & Measures
2014 Edition CERHT
2014/2015 Combination CERHT
Combination of both measure sets
2015 Edition CERHT
Description of each objective can be found on the Quality Payment Program website

34. 2017 ACI Transition Objectives & Measures (2014 Edition CEHRT)

35. ACI Transition Objectives & Measures
(2015 Edition CEHRT*)
*required in 2018

36. ADVANCING CARE INFORMATION
Scoring Methodology
Base Score – Report all required objectives
Report either a 1 in numerators/denominators and “yes” for each measure
Failure to report all required objectives results in an ACI category score of zero
Performance Score – Report additional measures
Building from base, report additional measures to achieve the highest score possible
Additional percentage points assigned based on performance rate
Bonus Score – Maximum of 10%
Improvement Activities utilizing CEHRT
Reporting to one or more public health or clinical data registry

37. ADVANCING CARE INFORMATION
Category Scoring
Earn up to 155% maximum, which is capped at 100% to earn full category scoring
Base score must be fulfilled or 0 score is assigned for entire ACI category

38. SPECIAL CONSIDERATIONS
2017 Transition Year
Hospital-based eligible clinicians may choose to report under ACI
Clinicians facing significant hardships that are unable to report can apply to have the category score weighted at 0%
If an objective/measure is not applicable to a clinician, CMS will reweight the category score to 0% and reassign the 25% weighting to other categories

39. COMPOSITE PERFORMANCE SCORE
2017 Transition Year
Unified scoring system converts measures and activities to a points system
Eligible clinicians know in advance what is needed to achieve top performance
Partial credit is available

40. REPORTING METHODS

41. REPORTING OPTIONS Individual or Group Individual Group
Under an NPI number and TIN combination where payments are reassigned
Group
2 or more clinician NPIs who have reassigned billing rights to a single TIN
Clinicians participating as a group are assessed as a group across all 4 MIPS categories
As an APM Entity

42. REPORTING METHODOLOGY
Quality
Cost
Advancing Care Information
Improvement Activities
Year 1 Weighting
No Weighting
Individuals
QCDR
Qualified Registry
EHR
Administrative Claims (no submission required)
Claims
Administrative Claims
(no submission required)
Attestation
Groups
CMS Web Interface (Groups of 25+)
CAHPS for MIPS Survey

43. READY TO PARTICIPATE IN MIPS?
Preparing for 2017
Use CEHRT certified to the 2014 Edition or 2015 Edition standards.
CEHRT should be ready to capture information for the MIPS ACI category & certain measures for the Quality category
Consider reporting options available to you, and what option fits your situation best.
Consider using a qualified clinical data registry or other registry to extract and submit your quality data
Check in on the QPP website routinely
Review the MIPS measures to choose to submit
Explore measures and activities to best fit your practice

44. NEED HELP IMPLEMENTING THE QPP?
Resources
CMS Quality Payment Program Website* (
“Where to go for Help”
QPP Overview
Small Practice Fact Sheet
Send Questions to:
Purdue Healthcare Advisors (
Monday-Friday, 8:30a-5:00p EST
Closed on University Holidays

45. PRESENTER INFO: NATALIE STEWART, MBA Senior Advisor, Quality Services
(765)