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MIPS and APM GURDEV SINGH MD CPHIMS CIO, Renal Care Organization
COO, Global Nephrology Solutions WILLIAM A. ELLERT, MD, MSN, FAAFP Chief Medical Officer Tenet Healthcare, Arizona
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Disclosure Gurdev Singh MD, CPHIMS
Has no relationships with any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients. Additional Disclosure: Founder and Executive member of RCO Analytics, a healthcare analytics company that offers services to Nephrologists to help improve quality and cost. Founder and Executive member of Global Nephrology Solutions, a physician practice management company.
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Disclosure of Financial Relationships
William A. Ellert, M.D. Has no relationship with any entity producing, marketing, re-selling, or distributing health care goods or services consumed by or used on, patients. Additional Disclosure: Member of the Board of Directors of Circle the City, a not-for-profit charitable organization which cares for the homeless during times of illness.
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The Quality Payment Program
The Quality Payment Program policy will: Reform Medicare Part B payments for more than 600,000 clinicians Improve care across the entire health care delivery system Clinicians have two tracks to choose from: OR The Merit-based Incentive Payment System (MIPS) If you decide to participate in traditional Medicare, you may earn a performance-based payment adjustment through MIPS. Advanced Alternate Payment Models (APMs) If you decide to take part in an Advanced APM, you may earn a Medicare incentive payment for participating in an innovative payment model.
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What is the Merit-based Incentive Payment System?
Quality Payment Program What is the Merit-based Incentive Payment System? Combines legacy programs into single, improved reporting program PQRS VM EHR Legacy Program Phase Out Last Performance Period PQRS Payment End 2016 2018
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What are the Performance Category Weights?
Quality Payment Program What are the Performance Category Weights? Weights assigned to each category based on a 1 to 100 point scale Transition Year Weights Quality 60% Cost 0% Improvement Activities 15% Advancing Care Information 25%
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MIPS Performance Category: Quality
Quality Payment Program MIPS Performance Category: Quality Category Requirements Replaces PQRS and Quality Portion of the Value Modifier Select 6 of about 300 quality measures (minimum of 90 days to be eligible for maximum payment adjustment); 1 must be: Different requirements for groups reporting CMS Web Interface or those in MIPS APMs Outcome measure OR High-priority measure—defined as outcome measure, appropriate use measure, patient experience, patient safety, efficiency measures, or care coordination May also select specialty-specific set of measures
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MIPS Scoring for Quality (60% of Final Score in Transition Year)
Quality Payment Program MIPS Scoring for Quality (60% of Final Score in Transition Year) Points earned on required 6 quality measures Any bonus points + Total Quality Performance Category Score = Maximum number of points* Quick Tip: Maximum score cannot exceed 100% *Maximum number of points = # of required measures x 10
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Transition Year 2017 >70 points 4-69 points 3 points 0 points
Quality Payment Program Transition Year 2017 Final Score Payment Adjustment >70 points Positive adjustment Eligible for exceptional performance bonus—minimum of additional 0.5% 4-69 points Not eligible for exceptional performance bonus 3 points Neutral payment adjustment 0 points Negative payment adjustment of -4% 0 points = does not participate
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HOW TO GET STARTED
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STEP 1: Pick Your Measures
Reporting as individual Define the specific activities that will qualify each eligible professional in your office for the maximum incentive payment for MIPS Reuse activities related to other incentive programs aka MU Reporting as a Group Select measures that are common to > 50% Eps Identify back up measures
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Improvement Activities – Examples
Subcategory Description Weight Expanded Practice Access Provide 24/7 access to MIP’s EC’s or care teams, expanded evening or weekend hours, e-visits, group visit, home visits, same day access High Population Management Patient with diabetes with meds – individualized care plan addressing comorbidities, risk for hypoglycemia and reassessed annually 60% of patients on anticoagulation participate in systematic anticoagulation program (coagulation clinic, patient self-reporting or management program) Targeted patient population reports that show unique characteristics of eligible patients, identification of vulnerable patients and how treatment is tailored Medium Beneficiary Engagement Collection and follow-up on patient experience and satisfaction data on patient engagement Patient Safety and Practice Assessment Consultation of a prescription drug monitoring program prior to the issuance of a controlled substance schedule II that will last more than three days Care Coordination Timely communication of test results defined as timely identification of abnormal test results with timely follow-up NOTE: High – 20 points, Medium – 10 point; 60 points to max category
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ACI: Domain Measures Part of the base score
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MEASURE NAME MEASURE DESCRIPTION MEASURE TYPE HIGH PRIORITY MEASURE Adult Kidney Disease: Blood Pressure Management Percentage of patient visits for those patients aged 18 years and older with a diagnosis of chronic kidney disease (CKD) (stage 3, 4, or 5, not receiving Renal Replacement Therapy [RRT]) with a blood pressure < 140/90 mmHg OR >= 140/90 mmHg with a documented plan of care Intermediate Outcome Yes Adult Kidney Disease: Catheter Use at Initiation of Hemodialysis Percentage of patients aged 18 years and older with a diagnosis of End Stage Renal Disease (ESRD) who initiate maintenance hemodialysis during the measurement period, whose mode of vascular access is a catheter at the time maintenance hemodialysis is initiated Outcome Adult Kidney Disease: Catheter Use for Greater Than or Equal to 90 Days Percentage of patients aged 18 years and older with a diagnosis of End Stage Renal Disease (ESRD) receiving maintenance hemodialysis for greater than or equal to 90 days whose mode of vascular access is a catheter Adult Kidney Disease: Referral to Hospice Percentage of patients aged 18 years and older with a diagnosis of ESRD who withdraw from hemodialysis or peritoneal dialysis who are referred to hospice care Process Adult Major Depressive Disorder (MDD): Coordination of Care of Patients with Specific Comorbid Conditions Percentage of medical records of patients aged 18 years and older with a diagnosis of major depressive disorder (MDD) and a specific diagnosed comorbid condition (diabetes, coronary artery disease, ischemic stroke, intracranial hemorrhage, chronic kidney disease [stages 4 or 5], End Stage Renal Disease [ESRD] or congestive heart failure) being treated by another clinician with communication to the clinician treating the comorbid condition Care Plan Percentage of patients aged 65 years and older who have an advance care plan or surrogate decision maker documented in the medical record or documentation in the medical record that an advance care plan was discussed but the patient did not wish or was not able to name a surrogate decision maker or provide an advance care plan Controlling High Blood Pressure Percentage of patients years of age who had a diagnosis of hypertension and whose blood pressure was adequately controlled (<140/90mmHg) during the measurement period Diabetes: Foot Exam The percentage of patients years of age with diabetes (type 1 and type 2) who received a foot exam (visual inspection and sensory exam with mono filament and a pulse exam) during the measurement year No Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) Percentage of patients years of age with diabetes who had hemoglobin A1c > 9.0% during the measurement period Documentation of Current Medications in the Medical Record Percentage of visits for patients aged 18 years and older for which the eligible professional attests to documenting a list of current medications using all immediate resources available on the date of the encounter. This list must include ALL known prescriptions, over-the-counters, herbals, and vitamin/mineral/dietary (nutritional) supplements AND must contain the medications' name, dosage, frequency and route of administration.
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Example of 2017 MIPS Participation for a Nephrologist
Quality Payment Program Example of 2017 MIPS Participation for a Nephrologist Sample Quality Measures (6, Including 1 Outcome): Closing the referral loop with referring provider Documentation of current medications Hemoglobin A1c Care Plan Immunization Controlling high blood pressure (outcome measure) Catheter at start of Dialysis (Outcome measure)
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Example of 2017 MIPS Participation for a Nephrologist
Quality Payment Program Example of 2017 MIPS Participation for a Nephrologist Sample Quality Measures (6, Including 1 Outcome): Sample Improvement Activities (2 High-Weighted): Closing the referral loop with referring provider Documentation of current medications Hemoglobin A1c Care Plan Immunization Controlling high blood pressure (outcome measure) Catheter at start of Dialysis (Outcome measure) Provide 24/7 access to eligible clinicians or groups who have real- time access to patient’s medical record. (EHR) Use of QCDR for feedback reports that incorporate population health. (RCO)
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Example of 2017 MIPS Participation for a Nephrologist
Quality Payment Program Example of 2017 MIPS Participation for a Nephrologist Sample Quality Measures (6, Including 1 Outcome): Sample Improvement Activities (2 High-Weighted): Advancing Care Information (Use of Technology) Measures (5 Base Score and 1 Performance Score): Closing the referral loop with referring provider Documentation of current medications Hemoglobin A1c Care Plan Immunization Controlling high blood pressure (outcome measure) Catheter at start of Dialysis (Outcome measure) Provide 24/7 access to eligible clinicians or groups who have real- time access to patient’s medical record. (EHR) Use of QCDR for feedback reports that incorporate population health. (RCO) Security Risk Analysis e-Prescribing Provide Patient Access Send a Summary of Care Request/Accept a Summary of Care Secure Messaging (performance score)
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Example of 2017 MIPS Participation for a Nephrologist
Quality Payment Program Example of 2017 MIPS Participation for a Nephrologist Sample Quality Measures (6, Including 1 Outcome): Sample Improvement Activities (2 High-Weighted): Advancing Care Information (Use of Technology) Measures (5 Base Score and 1 Performance Score): Closing the referral loop with referring provider Documentation of current medications Hemoglobin A1c Care Plan Immunization Controlling high blood pressure (outcome measure) Catheter at start of Dialysis (Outcome measure) Provide 24/7 access to eligible clinicians or groups who have real- time access to patient’s medical record. (EHR) Use of QCDR for feedback reports that incorporate population health. (RCO) Security Risk Analysis e-Prescribing Provide Patient Access Send a Summary of Care Request/Accept a Summary of Care Secure Messaging (performance score) Flexibility to CHOOSE WHAT and HOW you report Payment adjustments according to composite score
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Change is Hard
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STEP 2: Create Strategy Create a strategy for ensuring initial and continued high performance in selected measures Optimal use of EMR features or IT Tools to track progress on a regular basis Monitor back up measures also
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STEP 3: Transform Workflow redesign EHR optimization
Measure and monitor Change management
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Langley et al 1996 IHI What are we trying to accomplish?
How do we know that change is an improvement? What change can we make that will result in an improvement? PDSA Do Study Act Plan Langley et al 1996 IHI
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Introduction to Advanced Alternative Payment Models
(APMs)
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Alternative Payment Models (APMs)
A payment approach that provides added incentives to clinicians to provide high-quality and cost- efficient care. Can apply to a specific condition, care episode or population. May offer significant opportunities for eligible clinicians who are not ready to participate in Advanced APMs. Advanced APMs are a Subset of APMs APMs Advanced APMs
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Advanced Alternative Payment Models
Clinicians and practices can: Receive greater rewards for taking on some risk related to patient outcomes. + Advanced APMs Advanced APM- specific rewards 5% lump sum incentive
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Receive a higher Physician Fee Schedule update
What are the Benefits of Participating in an Advanced APM as a Qualifying APM Participant (QP)? Are excluded from MIPS QPs: Receive a 5% lump sum bonus Receive a higher Physician Fee Schedule update starting in 2026
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If you are a Qualifying APM Participant (QP)
The Quality Payment Program provides additional rewards for participating in APMs. Potential financial rewards Not in APM In APM In Advanced APM MIPS adjustments MIPS adjustments + APM-specific rewards APM-specific rewards + 5% lump sum bonus If you are a Qualifying APM Participant (QP) =
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Advanced APMs Must Meet Certain Criteria
To be an Advanced APM, the following three requirements must be met. The APM: Either: (1) is a Medical Home Model expanded under CMS Innovation Center authority OR (2) requires participants to bear a more than nominal amount of financial risk. Provides payment for covered professional services based on quality measures comparable to those used in the MIPS quality performance category; and Requires participants to use certified EHR technology;
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Advanced APMs in 2017 For the 2017 performance year, the following models are Advanced APMs: Comprehensive End Stage Renal Disease Care Model (Two-Sided Risk Arrangements) Comprehensive Primary Care Plus (CPC+) Shared Savings Program Track 2 Shared Savings Program Track 3 Oncology Care Model (Two-Sided Risk Arrangement) Next Generation ACO Model
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Qualifying APM Participant (QP)
Qualifying APM Participants (QPs) are clinicians who have a certain % of Part B payments for professional services or patients furnished Part B professional services through an Advanced APM Entity. Beginning in 2021, this threshold % may be reached through a combination of Medicare and other non- Medicare payer arrangements, such as private payers and Medicaid.
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How do Eligible Clinicians become Qualifying APM Participants?—Step 3
Requirements for Incentive Payments for Significant Participation in Advanced APMs (Clinicians must meet payment or patient requirements) Performance Year 2017 2018 2019 2020 2021 2022 and later Percentage of Payments through an Advanced APM Percentage of Patients through an Advanced APM
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Center for Healthcare Quality and Payment Reform
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