1. A Physician’s Perspective: Strategies for Achieving the Best Score in MIPS Performance July 14, 2017
Deborah Tracy MD, MBA

2. Disclaimer
HSAG remains a neutral vendor and today’s speaker is one of many experts on subjects of topical interest.

3. Deborah Tracy, MD, MBA - Board Certified Anesthesiologist
- Subspecialty Certified Pain Management, ABA
- Fellow of the Interventional Pain Practice, WIP
- Board Certified Pain Management, ABIPP

4. Objectives
Identify strategies to maximize scoring potential in the Merit-based Incentive Payment System.
Recognize how to calculate your MIPS composite score
Discuss how to access your QRUR report to monitor the Cost MIPS performance category

5. Most Clinicians Subject to MIPS

6. Percentage of MIPS Categories

7. Who Is Excluded from MIPS?
Eligible:
Greater than $30,000
AND
Greater than 100 Medicare Part B Fee-for-Service patients

8. Reporting as Individual or Group

9. Group Reporting Example

10. Pick Your Pace
***
***No downside to report ONE measure or IA

11. MIPS Adjustment
Based on a MIPS Composite Performance Score, clinicians will receive +/- or neutral adjustment up to the percentages below.

12. MIPS Incentive Payment Formula
> 70 points
Note that between the ‘haves’ and the ‘have nots’ the maximum bonus:
2019 high as 22%
2020 bonus could be 37%.

13. Scores and Publication
Publication - Each clinician’s annual final score is released to the public by CMS on Physician Compare
Reputational Impact - Score follows clinician for 2 years
62% of patients use internet ratings
Scores - CMS sets a performance threshold (PT)
For 2017:
Performance threshold as 3 points minimum per measure
Exceptional performance threshold to 70 points

14. Percentage of MIPS Categories (cont.)

15. QUALITY

16. Quality, 60% of Score = 60 points
Each measure can max at 10 points:
Total = 60 quality points + 6 bonus points
Each measure earns up to 10 points based upon the percentile-basis performance of that measure relative to national peer benchmarks
One must be an outcome measure or a high priority measure
Example:
62% measure
60% of peers reflected in the benchmark for the measure

17. Example of Using Benchmarks for a Single Measure to Assign Points
Decile
Sample Quality Measure Benchmarks
Possible Points
Decile 1 %
Decile 2 %
Decile 3 %
Decile 4 %
Decile 5 %
Decile 6 %
Decile 7 %
Decile 8 %
Decile 9 %
Decile 10 % 10

18. QUALITY (cont.)

19. BENCHMARKS
BIG CHANGE!

20. 2017 Benchmarks qpp.cms.gov Education & Tools – Scroll Down
Last Column = Topped Out

21. 2017 Benchmarks Table 2: MIPS Benchmark Results Measure_Name
Measure_ID
Submission_Method
Measure_Type
Benchmark
Decile 3
Decile 4
Decile 5
Decile 6
Decile 7
Decile 8
Decile 9
Decile 10
Topped Out
Diabetes: Hemoglobin A1c Poor Control 1
Claims
Outcome Y
<= 4.00 No
EHR
Registry/QCDR
<= 10.32
Colorectal Cancer Resection Pathology Reporting: pT Category (Primary Tumor) and pN Category (Regional Lymph Nodes) with Histologic Grade
100
Process --
Yes
Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients
102
Prostate Cancer: Adjuvant Hormonal Therapy for High Risk Prostate Cancer Patients
104
Adult Major Depressive Disorder (MDD): Suicide Risk Assessment
107
>= 98.68
Osteoarthritis (OA): Function and Pain Assessment
109
Preventive Care and Screening: Influenza Immunization
110
>= 79.02
>= 91.84
Pneumonia Vaccination Status for Older Adults
111
>= 99.07
>= 85.53
>= 90.20
Breast Cancer Screening
112
>= 98.53
>= 73.23
>= 87.93
Colorectal Cancer Screening
113

22. Assessment in Benchmark Table, 2017
Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
128
Claims
Process Y --
100 No
EHR
>= 68.19
Registry/QCDR
>= 97.34
Documentation of Current Medications in the Medical Record
130
Claims
Process Y --
100
Yes
EHR
>= 99.76
Registry/QCDR
Diabetes: Foot Exam
163
Claims
Process Y --
100 No
EHR
>= 76.17
Registry/QCDR
>= 98.04
Falls: Screening for Future Fall Risk
318
EHR
Process Y
>= 98.50 No
Registry/QCDR
>= 92.21

23. How many measures should be reported?
Report 6 measures with the best performance. 
Review in 2017 Quality Benchmarks document what score is needed to score 10 points for each measure
Report more than 6 measures only if they have high performance           
Do not report ‘everything but the kitchen sink’ because the poor quality measures will be published

24. Calculation of Quality Points
Example:
6 measures = 7 points each
Total points 6 x 7 = 42 out of 60 points
42/60 =70% of the 100% (60 points) for Quality
CY2017 performance year
Quality has a weight of 60%
Quality score of 70%
Quality category contributing 70% x 60% x 100 = 42 MIPS points to the clinician’s overall MIPS final score

25. QUALITY: MIPS
If bonus points are available a score of > 100% is truncated back to 100%

26. Quality, Bonus Points 6 POINTS MAXIMUM
The maximum number of bonus points for high priority measures for the Quality Performance Category score is 10% of the possible points; however, the bonus can be lower than that maximum.
As an example, for an individual reporter that can report at least 6 measures, the maximum number of bonus points is 6 points for the entire category because the possible points is 60 (6 measures x 10 points per measure). If the clinician only submits one additional outcome measure, then the total bonus points would be 2; in no case would the number of bonus points be greater than 6.
CMS Query

27. Reporting Tips Don’t report everything but the kitchen sink
Each measure will be available publically
Physician Compare, Yelp, Consumer Reports
They will choose the top six, but may not choose the ones you think are best
Only report high scoring measures
Score will follow clinician, even if he/she changes TINs
Measure Groups are gone
If an individual clinician has a low threshold - think about reporting as a group

28. QUALITY (60%) QUALITY REPORTING Individuals report through:
Claims (NQFs)
Qualified Registry (NQFs)
Specialty Registry – QCDR, Qualified Clinical Data Registry
EHR – eCQMs
Data Submission Vendor, DSV

29. CMS eCQMs Library

30. EC CLINICAL QUALITY MEASURES FOR EHR INCENTIVE PROGRAMS
Website for EHR eCQMs

31. Percentage of MIPS Categories

32. Advanced Care Information (ACI) (25%)
Fulfill the required measures for a minimum of 90 days
Base Points = 50 Points
Security risk analysis – Conduct or review a security risk analysis that addresses security of electronic patient health information (PHI) and implements security updates to identify risks;
Security Risk Analysis
E-prescribing – Electronically query for and transmit at least at least one prescription;
Provide patient access – Provide patients with timely access to electronically view, download and transmit health information, or offer access in an application of their choice
Send summary of care – Electronically create a summary of care and exchange summary of care to another provider when patients transition to another care setting; and
Receive summary of care – Electronically receive summary care record when patient is transitioning from another care setting and incorporate into EHR.
Performance Score = 90 Points
Public Health Registry Bonus = Points TOTAL = 155 POINTS

33. ACI Base Score Requirements
To satisfy base score requirements eligible clinician only need one (1) patient in the numerator of the base measures
2 measures overlap and achieving a high numerator gets extra bonus points

34. ACI Base Score Example Scoring Example: Base Score (12.5 points)
Measure Result
Security Risk Analysis Yes
E-Prescribing 1/500
Provide Patient Access 1/500
Send Summary of Care 1/500
Accept Summary of Care 1/500

35. Advancing Care Information

36. ACI

37. ACI (cont.)

38. ACI: Flexibility

39. ACI Scoring for Hospital Based

40. Scoring Performance Category
Security risk
E-prescribing
Provide patient access
Send summary of care
Receive summary care
Scoring Performance Category

41. ACI Scoring Performance Measures

42. ACI Performance Scoring

43. ACI: Performance Score
EXAMPLE: OBJECTIVES AND MEASURES
PERFORMANCE SCORE (90%)
Measure
Num/Denominator
Performance Rate
Percentage Score
Provide patient access
250/500*
50% 5%
Patient specific education
15/500 3% 1%
View, download transmit
300/500
60% 6%
Send a summary of care
450/500*
90% 9%
Accept a summary of care
277/500*
55%
Registry reporting
yes
Total Performance
32%

44. Bonus Points

45. ACI Scoring

46. ACI Example Bonus Point Scoring
ACI: OBJECTIVES AND MEASURES
BONUS POINTS
MEASURE
RESULT
SCORE
Specialized registry reporting
YES 5%
Reporting IA improvements thru CEHRT
10%
BONUS POINTS
15%

47. Advancing Care Information Attestation
Public Health Registry Bonus Point:
Immunization registry reporting is required. In addition, clinicians may choose to report on more than one public health registry, and will receive one additional point for reporting beyond the immunization category
State Prescription Drug Monitoring Program (PDMP) for pain physician will count
Section 10 Attestation - Public Health - Specialized Registry Reporting
MU 2016 Objective 10 Measure #3

48. Credit for Specialized Registry, #3 State PDMP
FLORIDA E-FORCSE MEANINGFUL USE ATTESTATION— Retrieval of Patient Information
Florida’s Prescription Drug Monitoring Program, E-FORCSE, maintained by the Florida Department of Health (FDOH) meets the definition of a specialized registry. Below is an explanation designed to help Eligible professionals (EPs) get started and prepared for Meaningful Use (MU) Stage 2 Specialized Registry attestation regarding retrieval of patient specific controlled substance dispensing information.
On January 1, 2016, Florida’s Prescription Drug Monitoring Program, E-FORCSE, maintained by the Florida Department of Health (FDOH) identified itself as a specialized registry.  EPs can meet the MU Stage 2 Specialized Registry objective by complying with one of the following:
EPs may submit patient specific controlled substance dispensing information electronically to E-FORCSE; or
EPs may electronically retrieve patient specific controlled substance dispensing information from E-FORCSE.
Open an Internet browser window and type the following URL in the address bar:

49. Total ACI Score In ACOs the ACI category is reported for each TIN
One additional public health reporting = 5 points
Cross-category bonus by reporting IA thru CEHRT = 10 points
All numerators greater than zero
Each Scored on Decile System

50. ACI: Example Total Score
BASE SCORE
50%
PERFORMANCE MEASURE SCORE
32%
BONUS SCORE
15%
TOTAL SCORE
97%
FINAL SCORE
X =
24.25 POINTS

51. ACI: Transition Year

52. ACI Bonus Points for Reporting IA

53. Percentage of MIPS Categories IA

54. MIPS, Improvement Activities (15%)
Report 40 points in Improvement Activities to earn 100% in this category
Small practices (15 or less clinicians); practices located in rural areas or geographic HPSAs, or non-patient facing
20 points weight for medium activities and 40 points weight for high activities
All other MIPS-eligible clinicians
10 points weight for medium activities and 20 points weight for high activities
Bonus Point for using activities that employ EHR
Report any combination of medium-weight and/or high-weight activities
Activities such as expanded practice access; population management; care coordination; beneficiary engagement; patient safety and practice assessment; and participation in an APM. Clinicians would select from a list of available activities.
Nine categories, 90+ choices
Expanded patient access
Safety
Same day appointments
Patient engagement
Population management
Patient and practice assessment
Emergency preparedness and response
Care Coordination
Regular, formal staff meetings
Participating in an PCMH
Integrated behavioral and mental health
MOC

55. Improvement Activities

56. MIPS Scoring for Advancing Care Information
(20 for < 15 ECs)

57. MIPS 2017, COST (0%) COST (0%), 2017 Does not require reporting
Replaces VBM, CMS will calculate these scores based on Medicare claims
Does not require reporting
Based on the TIN that provided more Primary Care services to the beneficiary (as measured by Medicare-allowed charges)
Standardized algorithms
Risk Adjust, Hierarchical Condition Categories (HCC)
Ordinary least squares regressions
Truncated expected values
Winsorize observed episode costs
Standardized spending levels
Calculate predicted episode costs
Standard Deviations
Actuarial Adjustments

58. Percentage of MIPS Categories Cost

59. COST

60. Example 1: Calculating a Final Score
Assuming that the numerical examples used for the four categories as described above all apply to the same clinician, we can calculate a total Final Score from the components:
Quality = (42 of 60 points) x 60% weight x 100 = 42 points
ACI = (50 of 100 points) x 25% weight x 100 = 12.5 points
IA = (30 of 40 points) x 15% weight x 100 = 11.3 points (rounded up from 11.25)
COST = 0% weight x 100 = 0 Final Score
Total Final Score = = 65.8

61. Example 2: Calculating a Final Score
Assuming that the numerical examples used for the four categories as described above all apply to the same clinician, we can calculate a total Final Score from the components:
Quality = (60 points) x 60% weight x 100 = 60 points
ACI = (97 of 100 points) x 25% weight x 100 = 24.5 points
IA = (40 points) x 15% weight x 100 = 15 points
COST = 0% weight x 100 = 0 Final Score
Total Final Score = = 99.5
YOU ARE AN EXCEPTIONAL PERFORMER!

62. Transition Year 2017

63. Reporting Your Data to CMS

64. When Does MIPS Begin?

65. QRUR Quality Resource Use Report COST $$$

66. What Information Is Contained in the 2015 Annual QRUR?

67. QRUR, Pain, 2015 x

68. THE END! Thank you for participating.
That concludes the presentation part of the session today and we thank you for joining us.

69. Questions?

70. QPP Technical Assistance Resource Guide
Below is a link to the QPP TA Resource guide for small and large practices. To locate a Small Underserved Rural Support QPP contractor, click on the link and a resource will appear directing you the state point of contact in your area.
Source: The Centers for Medicare & Medicaid Services

71. HSAG QPP Technical Assistance
Thank You
HSAG QPP Technical Assistance
Toll free: