1. “Success in Quality Payment Programs (QPP)”
Educational Series
“Success in Quality Payment Programs (QPP)”
Part II Workshop-Enhancing Quality Demonstrates Improved Results
Topic: Pick Your Pace Strategy: What, Why, How?
Tony Rodgers, Principal
Health Management Associates
September 29, 2017

2. Pick Your Pace Strategy
Session Topics
The Purpose of the MACRA Law
Merit Based Incentive Payments System (MIPS) Quality Performance Program
Pick Your Pace Strategy Options
What Participating Practices Need to Do
Consequences of Doing Nothing
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3. Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)
Purpose
Replaced the Medicare Sustainable Growth Rate (SGR) payment authorization.
Update the Medicare Physician Fee schedule (PFS) to reward high-quality patient care through the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).
Combined previous multiple Medicare quality and incentive reporting programs into one Quality Payment Program (QPP)
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4. Health Management Associates

5. MIPS uses a composite score from four
Then (2016) and Now (2017)
MACRA changed clinician Medicare Quality Reporting and the CMS Quality Performance Payment program. CMS transition from quality reporting from the previous PQRS reporting payment adjustment system to MIPS QPP and Alternative Payment Models.
Previous CMS Payment Incentives:
Physician Quality Reporting System (PQRS): Medicare’s quality reporting system
Medicare Electronic Health Record Incentive Adjustment: Certified EHR system that meets meaningful use criteria
Value Based Payment Modifier (aka Value Modifier): The fee for service modifier that will be used to adjust provider payments.
2016 is the final reporting period for these stand alone programs; their same infrastructure will be used for MIPS.
MIPS uses a composite score from four
key performance areas to determine the aggregate financial reward or penalty the a physician will receive:
Quality Performance (six measure)
Resource Use (not included in year 1)
Advancing Care Information: Meaningful Use
Clinical Practice Improvement Activities
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6. Participation in the Quality Payment Program
The MIPS Quality Payment Program in 2017 covers;
Clinicians who are in an Advanced APM or
Clinician who billed Medicare more than $30,000 in Part B allowed charges a year and provide care for more than 100 Medicare patients a year.
You must both meet the minimum billing and the number of attributed patients to be a QPP eligible clinicians.
If you are below either, you are not eligible to be in the MIPS program.
The definition of healthcare value presented here is generally how most healthcare policy leaders define Value Based Care. Value is a product of achieving a specific healthcare outcome within specific time parameters and that is at or below an expected total cost of care target.
Common Elements Value Base Payment
A standard measure of outcome
A consistent method for calculating the total cost of care
A methodology for allocating provider accountability
Standardized outcome reporting methodology to document/report on achievement of outcome measure
A standard definition for the full cycle of care (beginning and end time parameters related to the achievement of the outcome)
Consistent formulas for risk adjustment, ”risk limit” or mitigation, and allocation of provider accountability
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7. What You Need to Know About MIPS Quality Performance Program Reporting Requirements
Eligible clinicians need to know about the MIPS Quality Performance Payment:
You must submit quality performance data to potentially earn an upward adjustment or avoid a negative adjustment to their future Medicare Part B payments.
Participate as an individual or as part of their group.
Choose a one of the “Pick Your Pace” options for participation for the transition year (2017 performance year) or participate in an Advance APM.
Submit MIPS 2017 performance data to Medicare between January 1, 2018 and March 31, 2018 to qualify for a neutral to positive adjustment and a negative future payment adjustment.
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8. Medicare Beneficiary Attribution to Primary Clinician
Two Step Attribution Process
Step 1: A beneficiary is attributed to a TIN if the TIN’s primary care physicians (PCPs) accounted for a larger share of allowed charges for primary care services than other PCPs of any other TIN.
Step 2: Beneficiaries not assigned to PCP in step 1 may be assigned to the TIN of a physician specialists, nurse practitioners (NPs), physician assistants (PAs), or clinical nurse specialists (CNSs) who accounted for the largest portion of more Medicare allowed charges for primary care services.
Beneficiaries excluded from attribution:
Beneficiaries enrolled in Medicare Part A only or Medicare Part B for less than 12 months during the performance year.
Enrolled in Medicare managed care (for example, a Medicare Advantage plan) for any month during the year
Resided outside of the United States, its territories, and its possessions for any month during the year
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9. Pick Your Pace
Participating clinicians can “Pick Their Pace” of implementation of QPP for 2017 quality reporting:
Marathon Runners: If you're began collecting quality performance data in January 1, 2017, you are fully participating and can start submitting your performance data and attestations between January 1, 2018 and March 31, 2018
5 k Runners: If you're only able to collect and submit data on a limited number of quality performance measures, but not all six measures, or only for a limited number of months, you may be eligible for a partial financial award and you will avoid any penalty for 2017 performance year.
Sprinters: If you can only submit performance data for three months of the calendar year (for example, data on one quality measure and one improvement activity), you won’t be eligible for a financial reward but you can avoid a penalty in The get to sprint to the finish line.
If you not participating in a Advanced APM in 2017 your can Pick Your Pace
Whenever you choose to start, you'll need to send in your performance data by March 31, You can also begin participating in an Advanced APM.
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10. Fully Participating Physicians and Group Practices
To achieve full credit for the Quality performance category, physicians must report on 90% of all patients, if reporting via registry, and 80% of all Medicare Part B patients if reporting via claims.
CMS maintains a list of individual Quality Measures available for MIPS reporting in 2017.
In addition, the list is re-ordered to identify the measures by medical specialty. Providers may choose from the list and will need to report six quality measures (including one outcome and one cross-cutting measure)
Fully participating clinician must report a minimum of 6 measures, with at least one cross-cutting measure and one outcome measure, if available. If no outcome measure applies to the clinician, he or she would report one “high priority measure.”
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11. The First Year MIPS Requirements for “fully” participating clinicians
Quality
Claims submission
QCDR or qualified registry
EHR
Administrative claims for population health measures (no submission required)
Groups only: CMS web interface (groups > 25); CMS approved survey vendor for CAHPS and MIPS
Resource Use
Administrative claims (no submission required)
Advancing Care Information (MU)
Attestation
Groups only: CMS web interface (groups > 25)
Clinician Practice Improvement Activities (CPIA)
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12. What QPP Participating Clinicians Need to Do: First Year: 2017 MIPS Quality Payment Program
Transmitting 2017 Performance Data:
To potentially earn a positive payment adjustment under MIPS/QPP, clinician must transmit quality data to CMS and attest to used EHR technology in 2017 by the March 31, 2018 deadline. Clinicians can earn an additional 5% incentive payment by participating in an Advanced APM and send quality data through Advanced APM reporting process.
For the first performance year of MIPS, CMS will allow providers to report their quality performance data through anyone of the following methods claims, registry, EHR, or Web Interface (GPRO).
Providers may report their data through multiple submission methods, and CMS will use the highest available score toward the overall MIPS composite score.
Providers do not have to submit data for each of the MIPS categories through the same mechanism in the first year, however in future years CMS may require all MIPS data to be submitted by a single reporting method.
CMS Feedback:
Medicare will give clinician feedback on the data submitted and clinician after you send your data.
2017 Performance Period:
The first performance period started January 1, 2017 and will closes December 31, During 2017 performance period the clinicians must collected and submit quality data and attest to the used certified EHR technology to support your practice depending on the Pick Your Pace Option chosen.
Or a clinician can participate in an Advanced APM.
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13. Advance Alternative Payment Model
Alternative Payment Model Performance Measures
If you participate in the Advanced APM
You must:
Receive 25% of your Medicare payment or
See 20% of your Medicare patient as part of your advance APM in 2017.
Then you are eligible to earn and addition 5% incentive payment in 2019.
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14. Consequences of Doing Nothing: Year to Year Escalating Potential Financial Adjustments Based on QPP Composite Scores
Ignoring MACRA could cost you:
If you don’t send in any performance data:
The performance reward and penalty increases
4% in 2019
5% in 2020,
7% in 2021
9% in 2022. 
+9%
+7%
+5%
+4%
+7%
-4%
+5%
+9%
2017
2018
2019
2020
2021
2022
QPP Performance Years

15. Quick Self Evaluation Check List for Eligibility for MIPS Quality Performance Payment
You one of the eligible clinician types:
Physicians, which includes doctors of medicine, doctors of osteopathy (including osteopathic practitioners), doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors;
Physician assistants (PAs);
Nurse practitioners (NPs);
Clinical nurse specialists;
Certified registered nurse anesthetists
Will you earn $30,000 and are you the primary clinician for a minimum 100 Medicare patients.
As a clinician you must participated in MIPS QPP reporting if A and B are true. B
You are exempt from MIPS QPP if:
This is the first year of your participation in Medicare
You are participating in a APMs that qualify for bonus payments, and
You are a clinician whose patient panel of Medicare beneficiaries fall below the low volume threshold. C
You are exempt from reporting in 2017 if C is true.
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16. Wrap Up
If you are a MIPS QPP eligible clinicians it is important to understanding and complying with MACRA quality reporting requirements is very important to your practices future financial health.
CMS’s long term goal is to move most clinical providers to some form of value based alternative payment.
In 2017 you have reporting options so you can avoid penalty adjustments in 2019.
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17. Tony Rodgers Principal
CONTACT ME
Tony Rodgers Principal
2398 Camelback Rd
Phoenix, Arizona 80016
(800)