1. Strategies for Achieving High Scores in MIPS Performance Categories
Padma Taggarse, MMI, MBA Executive Director, Physician Office Quality
Kari Vanderslice, MBA, PCMH, CCE
Health Informatics Specialist
Health Services Advisory Group (HSAG)
September 29, 2017
MIPS = Merit-Based Incentive Payment System

2. Disclosure
I have nothing to report, nor are there any real or perceived conflicts of interest, implied or expressed, in the following presentation. Padma Taggarse, MMI, MBA Kari Vanderslice, MBA, PCMH, CCE

3. Agenda Welcome Overview of MIPS scoring
Performance measure: special considerations
Technical assistance and resources
Questions and answers

4. HSAG: Your Partner in Healthcare Quality
HSAG is the Medicare Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Arizona, California, Florida, Ohio, and the U.S. Virgin Islands.
HSAG has been committed to improving healthcare quality for more than 35 years.
QIN-QIOs in every state/territory are united in a network under the Centers for Medicare & Medicaid Services (CMS).
The Medicare QIO Program is the largest federal program dedicated to improving healthcare quality at the community level.

5. HSAG’s QIN-QIO Territory
Nearly 25 percent of the nation’s Medicare beneficiaries
Drives quality by providing technical assistance, convening LANs, collecting and analyzing data for improvement
Works on initiatives to improve patient safety, reduce harm, improve clinical care
Engages healthcare providers, stakeholders, and beneficiaries to improve health quality, efficiency, and value.
HSAG is the Medicare QIN-QIO for Florida, California, Ohio, Arizona, and the U.S. Virgin Islands.

6. Overview of MIPS Scoring

7. What Will Determine My MIPS Score?**
The MIPS final score will factor in four weighted categories:
MIPS
Final Score
Advancing Care Information
Quality
Cost
Improvement Activities
Many of you are probably wondering what will make up the MIPS final score. The score factors in performance in 4 weighted categories:
quality, resource use, clinical practice improvement activities, and use of certified electronic health record (EHR) technology.
Most of these categories aren’t new to clinicians, who may have seen them before in programs such as PQRS.
** Beginning in 2018
Source: The Centers for Medicare & Medicaid Services

8. What Are the Performance Category Weights?
Weights are assigned to each category based on a 1 to 100 point scale.
2017 Transition Year Performance Category Weights:
Cost
Improvement Activities
Advancing Care Information
Quality
60% 0%
15%
25%
Source: The Centers for Medicare & Medicaid Services

9. How Much Can MIPS Adjust Payments?
Based on a composite performance score, clinicians will receive +/- or neutral adjustments up to the percentages below.
+7%+9%
+4%+5%
Adjusted Medicare Part B payment to clinician
+/-
Maximum Adjustments
-4% -5%
-7%
So what does this payment adjustment look like? MIPS will adjust payments positively OR negatively based on a composite performance score for each clinician. The potential maximum adjustment percentage begins at +/- 4% in 2019 and will increase each year from 2019 to In 2022, the adjustment will be as high as +/- 9% [TRANSITION]
-9%
The potential maximum adjustment percent will increase each year from 2019 to 2022
onward
MIPS
Source: The Centers for Medicare & Medicaid Services

10. Connecting Final Score to Payment Adjustment
3+ points avoids the negative payment adjustment.
70+ points gains access to $500 million bonus pool for exceptional performers.
Source: The Centers for Medicare & Medicaid Services

11. MIPS Reporting and Submission Methods
What Do I Need to Know? 11

12. Individual vs. Group Reporting
Options
Individual
Group
2. As a Group
a) 2 or more clinicians (NPIs) who have reassigned their billing rights to a single TIN*
b) As an Alternative Payment Model (APM) Entity
1. Individual—Under a National Provider Identifier (NPI) number and Tax Identifying Number (TIN) where they reassign benefits
* If clinicians participate as a group, they are assessed as a group across all four MIPS performance categories.
Source: The Centers for Medicare & Medicaid Services

13. Submission Methods Individual Group Quality
Qualified Clinical Data Registry
(QCDR)
Qualified Registry
EHR
Claims
QCDR
Administrative Claims
CMS Web Interface
CAHPS for MIPS Survey
Improvement Activities (IA)
Attestation
Advancing Care Information (ACI)
CAHPS = Consumer Assessment of Healthcare Providers and Systems
EHR = electronic health record
Source: The Centers for Medicare & Medicaid Services 30

14. To Group or Not to Group Report as an individual Report with a group
If you report as an individual, your payment adjustment will be based on your performance.
Report with a group
Each eligible clinician participating in MIPS via a group will receive a payment adjustment based on the group's performance.
Source: The Centers for Medicare & Medicaid Services

15. MIPS Reporting and Participation Period
What Do I Need to Know? 15

16. MIPS: Partial Participation for 2017
Submit 90 days of 2017 data to Medicare
May earn a positive payment adjustment
Submit a Partial Year
“So what?”—If you are not ready on January 1, you can start anytime between January 1 and October 2.
Need to send performance data by March 31, 2018
Source: The Centers for Medicare & Medicaid Services

17. MIPS: Full Participation for 2017
Submit a full year of 2017 data to Medicare
May earn a positive payment adjustment
Best way to earn largest payment adjustment is to submit data on all MIPS performance categories +%
Key takeaway:
Positive adjustments are based on the performance data on the performance information submitted, not the amount of information or length of time submitted.
Submit a Full Year
Source: The Centers for Medicare & Medicaid Services

18. Bonus Payments and Reporting Periods
MIPS payment adjustment is based on data submitted. Clinicians should pick what's best for their practice. +%
Submit a Full Year
Submit a Partial Year
Full year participation
Is the best way to get the maximum adjustment
Gives you the most measures to choose from
Prepares you the most for the future of the program
Partial participation (report for 90 days)
You can still achieve the maximum adjustment
Source: The Centers for Medicare & Medicaid Services

19. Performance Measure: Special Considerations

20. MIPS Scoring for Quality (60 Percent of Final Score in Transition Year)
Select 6 of the approximately 300 available quality measures (minimum of 90 days)
Or a specialty set
Or CMS Web Interface measures
Quick Tip:
Easier for a clinician who participates longer to meet case volume criteria needed to receive more than 3 points.
Bonus points are available
2 points for submitting an additional outcome measure
1 point for submitting an additional high-priority measure
1 point for using CEHRT to submit measures electronically end-to-end
Clinicians receive 3 to 10 points on each quality measure based on performance against benchmarks.
Failure to submit performance data for a measure = 0 points.
Source: The Centers for Medicare & Medicaid Services

21. Use Benchmarks to Maximize Your Incentive
Each measure is assessed against its benchmark.
Benchmarks are specific to the type of submission mechanism: EHRs, QCDRs/registries, CAHPS, and claims.
Benchmarks are based on actual performance data submitted to PQRS in 2015, except for CAHPS.
Source: The Centers for Medicare & Medicaid Services

22. Choose Submission Methods
Sample: Quality benchmarks for influenza
Points depend on submission method.
If 45 percent performance, note the difference:
Decile 3
Decile 4
Decile 5
Decile 6
Decile 7
Decile 8
Decile 9
Decile 10
Claims
22.64–31.75
31.76–43.13
43.14–54.68
54.69–66.38
66.39–77.47
77.48– 92.03
92.04–99.99
100
EHR
11.22–18.57
18.58–24.99
25.00–31.84
31.85–38.92
38.93–47.86
47.87–59.99
60.00–79.01
>= 79.02
Registry/ QCDR
11.57–21.39
21.40– 31.39
31.40–41.31
41.32–51.13
51.14–62.04
62.05–74.27
74.28–91.83
>= 91.84
If 45%, Claims falls into Decile 5
EHR falls into Decile 7
Registry/QCDR in Decile 6
Source: The Centers for Medicare & Medicaid Services

23. Number of Points Assigned for the 2017 MIPS Performance Period
Table 1: Using Data in Benchmark to Estimate Points (For Non-Inverse Measures)*
Decile
Number of Points Assigned for the 2017 MIPS Performance Period
Below Decile 3
3 points
Decile 3
3–3.9 points
Decile 4
4–4.9 points
Decile 5
5–5.9 points
Decile 6
6–6.9 points
Decile 7
7–7.9 points
Decile 8
8–8.9 points
Decile 9
9–9.9 points
Decile 10
10 points
*For inverse measures, the order would be reversed. Where Decile 1 starts with the highest value and decile 10 has the lowest value.
Source: The Centers for Medicare & Medicaid Services

24. Choose Your Measures
Bang for buck: Measures that meet more than one MIPS performance category
Example: Immunizations
Quality: Measure ID #110 Influenza
IA: Activity ID IA_CC_6
Participation in a QCDR
Promote use of standard practices, tools and processes for quality improvement to document vaccinations
ACI: Immunization Registry Reporting
Active Engagement
Performance score weight: 10 percent
Source: The Centers for Medicare & Medicaid Services

25. Other Measures Documentation and Reconciliation of Medications
Tobacco Use Screening and Cessation
Opioid Management
Closing the Referral Loop
Source: The Centers for Medicare & Medicaid Services

26. MIPS Performance Category: Cost
No reporting requirement; 0 percent of final score in 2017
Clinicians assessed on Medicare claims data
CMS will still provide feedback on how you performed in this category in 2017, but it will not affect your 2019 payments.
Keep in mind:
Uses measures previously used in the Physician Value-Based Modifier program or reported in the Quality and Resource Use Report (QRUR)
Only the scoring is different
Source: The Centers for Medicare & Medicaid Services

27. MIPS Scoring for IA (15 Percent of Final Score in Transition Year)
Total points = 40
Activity Weights
Medium = 10 points
High = 20 points
Alternate Activity Weights*
Medium = 20 points
High = 40 points
*For clinicians in small, rural, and underserved practices or with non-patient facing clinician groups
Full credit for clinicians in a patient-centered medical home, Medical Home Model, or similar specialty practice
Source: The Centers for Medicare & Medicaid Services

28. IA Tips 14 high-weighted activities 13 activities include QCDRs
1 needed for practice with 15 or fewer clinicians
2 needed for practice with 16 or more clinicians
13 activities include QCDRs
For group reporting, only 1 MIPS-eligible clinician (EC) in a TIN must perform the Improvement Activity for the TIN to get credit.
Source: The Centers for Medicare & Medicaid Services

29. IA Tips: Implement and Document
Implement activities for at least 90 days
Review activities in detail.
Ask for team input.
Discuss how to implement activities.
Decide how to document activities, if audited.
Document steps taken to implement IA
Differs depending on Improvement Activities chosen
Document Policy
Agreement (TCPI, QIN-QIO)
Keep for minimum of 6 years electronically and on paper.
Receive 10 percent bonus points in ACI category by submitting using your certified EHR technology (CEHRT).
TCPI = Transforming Clinical Practice Initiative
Source: The Centers for Medicare & Medicaid Services

30. IA Tips: Access Provide patient access using CEHRT-patient portal
ACI: Provide Patient Access
Base score requirement
Plus, Performance Score Weight Up to 20 percent
IA: Activity ID IA_EPA_1—high weight
Provide 24/7 access to ECs or groups who have real-time access to patient's medical record.
Source: The Centers for Medicare & Medicaid Services

31. MIPS Performance Category: ACI (25 Percent of Final Score in Transition Year)
Earn up to 155 percent maximum score, which will be capped at 100 percent.
ACI category score includes:
Required Base score (50%)
Performance score (up to 90%)
Bonus score
(up to 15%)
50%
90%
15%
Keep in mind: You need to fulfill the Base score or you will get a zero in the Advancing Care Information Performance Category.
Source: The Centers for Medicare & Medicaid Services

32. MIPS Scoring for ACI (25 Percent of Final Score in Transition Year)
Base score (worth 50 percent of ACI score)
Clinicians must submit a numerator/denominator or Yes/No response for all required measures.
Performance score (worth up to 90 percent of ACI score)
Report up to 9 ACI Measures OR up to ACI Transition Measures
Bonus score (worth up to 15 percent of ACI score)
Receive 5 percent for reporting on Public Health and Clinical Data Registry Reporting measures
Receive 10 percent for CEHRT to report certain IA
ACI Performance Category Score =
Base Score Performance Score Bonus Score
Quick Tip: Maximum score cannot exceed 100%
Source: The Centers for Medicare & Medicaid Services

33. Tips for ACI Success Schedule the 2015 EHR upgrade immediately.
Understand the scoring methodology to maximize your score.
Use high-functioning EHR for every possible process.
Adopt patient-centric workflows.
Emphasize preventive care.
Perform daily team huddles.
All clinicians and staff members should continue to suggest patient portals for every use to increase Patient Access to Information, HIE, Secure Messaging, and Patient Education.
HIE = Health Information Exchange
Source: The Centers for Medicare & Medicaid Services

34. Pursue Interfaces With EHR
MIPS bonus points
ACI—Immunization Registry 10 percent
ACI—Specialized (Clinical Data) Registry 5 percent
Quality - End-to-end electronic reporting
1 bonus point for each measure using CEHRT
Up to 10 percent of the possible performance points in the Quality category
1 bonus point for each measure using CEHRT in end-to-end electronic reporting
**For each measure totaling up to 10% of the possible performance points in the Quality category.
Source: The Centers for Medicare & Medicaid Services

35. Maximize Electronic Exchange of Information
Identify two or three trading partners of high referral or transfer of care volume.
Apply effort to exchange in 2017 because MIPS 2018 will require more.
2015 CEHRT version has 2 requirements:
Send Summary of Care
Request/Accept Summary of Care
1. Send Summary of Care
“For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider-(1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record.”
2. Request/Accept Summary of Care
“For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or retrieves and incorporates into the patient's record an electronic summary of care document.”
Source: The Centers for Medicare & Medicaid Services

36. Countdown to MIPS Data Submission

37. Technical Assistance and Resources

38. What Support Is Available to Clinicians?
Full-service, expert help
Quality Payment Program (QPP) Service Center
QIN-QIOs
QPP—Small, Underserved, and Rural Support (QPP-SURS)
TCPI
APM Learning Networks
Self-service
QPP Online Portal
In closing –
HSAG is here to help with MIPS.
[insert slide 17]
CMS-awarded QPP Service Center for practices in Arizona.
Source: The Centers for Medicare & Medicaid Services

39. Thank you! 40

40. CMS Disclaimer
This material was prepared by Health Services Advisory Group, the Medicare Quality Improvement Organization for Arizona, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services, with additional adapted material from Telligen, the QIN-QIO for Colorado, Iowa, and Illinois. The contents presented do not necessarily reflect CMS policy. Publication No. AZ-11SOW-D 41