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AGENDA Overview of MACRA Quality Payment Program
MIPS APM Determining Eligibility Timeline
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What Is MACRA? Medicare Access and CHIP Reauthorization Act of 2015
MACRA’s Quality Payment Program (QPP) replaces the Sustainable Growth Formula Changes clinician reimbursement from volume- based to quality and value-based Reforms Medicare Part B payments for >600,000 clinicians Only affects clinician reimbursement under Medicare Part B MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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MACRA: Medicare Access and CHIP Reauthorization Act of 2015
United States Government Publishing Office. Department of Health and Human Services. Centers for Medicare and Medicaid Services. Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Published 11/4/ Accessed 12/6/2016.
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Quality Payment Program (QPP) Performance-Based Payment Adjustment
How Does MACRA Work? Quality Payment Program (QPP) Focus: Delivery of High-Quality Patient Care Report data to CMS Receive Feedback Performance-Based Payment Adjustment Shift from VOLUME-based to VALUE-based payment adjustments MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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What Happens If I Don’t Participate?
Providers who are eligible, but do not participate in the Quality Payment Program in 2017 will receive a 4% negative payment adjustment in 2019 APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System. CMS. Quality Payment Program. Accessed 12/8/16.
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How Does MACRA Help Clinicians?
Combines 3 existing programs (PQRS, VBM, and MU) under a single umbrella, reducing administrative burden Adds a new category to provide incentives to clinicians for activities that improve clinical practice Avoids potential negative adjustments of 11% or more in 2019 that could have occurred under the previous system Under MACRA, the maximum negative payment adjustment in 2019 is only 4% MU = Meaningful Use; PQRS = Physician Quality Reporting System; VBM = Value-Based Modifier. American Medical Association. Medicare Access and CHIP Reauthorization Act (MACRA). Quality Payment Program Final Rule. Accessed 12/8/16.
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What Are The Anticipated Benefits of MACRA for Patients?
Enhanced care coordination with a patient- centered focus Increased access to better care Improved patient outcomes CMS. Quality Payment Program. Updated 11/29/16. Accessed 12/12/16.
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Quality Payment Program (QPP) Strategic Objectives
Improve beneficiary outcomes Enhance clinician experience Increase adoption of Advanced APMs Maximize participation Improve data and information sharing Ensure operational excellence in program implementation APM = Alternative Payment Model. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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POLLING QUESTION Do you believe the Quality Payment Program will bring value to your clinical practice? Yes No Remains to be seen
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What Are The 2 Reimbursement Tracks Under the MACRA Quality Payment Program?
Merit-Based Incentive Payment System (MIPS) Folds 3 current programs (PQRS, VBM, MU) into a single program Adds a new 4th component – Improvement Activities Opportunity to earn a performance-based payment adjustment Advanced Alternative Payment Model (APM) Adds incentives to encourage participation in certain APMs Qualifying clinicians are eligible for a 5% bonus and are exempt from MIPS MU = Meaningful Use; PQRS = Physician Quality Reporting System; VBM – Value-Based Modifier. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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Am I Eligible for MIPS? Eligible Clinicians 2017 Eligible Physicians
PAs NPs CNSs CRNAs Not 2017 Eligible 1st year Medicare Part B participants Below low patient threshold: Medicare Part B billing charges ≤$30K ≤100 Medicare Part B patients/year Qualifying APM participants The ABCs of MIPS October 19, 2016 (Healthcare NOW Radio) who bill >$30K/yr under Medicare Part B and provide care for >100 Medicare patients/yr (and groups that include these clinicians) APM = Alternative Payment Model; CNS = clinical nurse specialist; CRNA = certified registered nurse anesthetist; MIPS = Merit-Based Incentive Program; NP = nurse practitioner; PA = physician assistant. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16
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What is an APM? Alternative Payment Model (APM):
Payment approach that provides incentive payments to provide high-quality and cost- efficient care Can apply to a specific clinical condition, care episode, or a population CMS. What are Alternative Payment Models? Accessed 12/8/16.
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What is an Advanced APM? Advanced APMs: Subset of APMs
Practices earn more for taking on risk related to patients’ outcomes Qualifying Advanced APM Participants = 5% lump sum bonus in 2019 – 2024, with potential for higher incentive in subsequent years No payment reduction in this track 5% bonus is on top of existing Advanced APM-specific rewards APM = Alternative Payment Model. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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How Do I Know if I Qualify for MIPS or APM?
The majority of clinicians will be subject to MIPS However, clinicians who participate in APMs at a certain threshold will be QPs and excluded from MIPS CMS is working to notify clinicians of their QP status so they will know if they are excluded from MIPS prior to having to submit data APM = Alternative Payment Model; CMS = Centers for Medicare & Medicaid Services; MIPS = Merit-Based Incentive Payment System; QP = Qualifying [APM] Participant. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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What are the Requirements to be an Advanced APM?
Must use CEHRT* Payment must be tied to quality measures comparable to those in MIPS Must bear a certain amount of financial risk OR qualify as a Medical Home Model Meet revenue-based standard (≥8% of revenues at risk) Meet benchmark-based standard (≥ 3% maximum possible loss of spending target) * 2014 or 2015 edition CEHRT in 2017; 2015 edition CEHRT only in 2018. APM = Alternative Payment Model; CEHRT = Certified Electronic Health Record Technology; MIPS = Merit-Based Incentive Payment System. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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What are the Requirements to be an Advanced APM? (cont.)
In addition, to be eligible for the Advanced APM track and qualify to receive the 5% incentive payment, clinicians must: Receive 25% of their Medicare-covered services through Advanced APMs OR See 20% of their Medicare patients through Advanced APM Services provided at CAHs, RHCs, and FQHCs that meet certain criteria can contribute to the QP determination using patient counts Clinicians in traditional APMs can become eligible to participate in Advanced APMs by strategically increasing the amount of traditional Medicare payments or patient counts tied to the Advanced APM However, clinicians who already qualify for the Advanced APM track cannot opt out and choose the MIPS track instead APM = Alternative Payment Model; CAH = Critical Access Hospitals; FQHC = Federally Qualified Health Center; MIPS = Merit-Based Incentive Payment System; RHC = Rural Health Clinic; QP = Qualifying [APM] Participant. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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What Qualifies as an Advanced APM?
2017 Future CJR Payment Model (CEHRT) Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT) ACO Track 1+ New Voluntary Bundled Payment Model Vermont Medicare ACO Initiative MSSP Tracks 2 and 3 Next Generation ACO model The Oncology Care Model Two-Sided Risk Arrangement Comprehensive End Stage Renal Disease Care model CPC+ model (Medical Home Model) See for the most up-to-date list of qualified Advanced APMs. ACO = Accountable Care Organization; APM = Alternative Payment Model; CEHRT = Certified Electronic Health Record Technology; CPC+ = Comprehensive Primary Care Plus; CJR = Comprehensive Care for Joint Replacement; MSSP = Medicare Shared Savings Program. CMS. What are Alternative Payment Models? Accessed 12/8/16.
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What Do I Need to Do in 2017 if I am in an Advanced APM?
You will earn the 5% incentive payment in 2019 if you participate in an Advanced APM in 2017 and: You receive 25% of your Medicare Part B payments through an Advanced APM Or you see 20% of your Medicare patients through an Advanced APM And you submit the quality data required by your Advanced APM, including one outcome measure APM = Alternative Payment Model. CMS. What are Alternative Payment Models? Accessed 12/8/16.
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Future Advanced APM Opportunities
Coming in 2021 – “All-Payer Combination Option” Based on 2019 performance year Clinicians can use “other payers” to help meet the revenue or patient count thresholds to qualify for the Advanced APM track E.g., Medicare Advantage contracts Providers must still meet Advanced APM criteria APM = Alternative Payment Model. MACRA Final Rule, October 14, CMS. Quality Payment Program. Accessed 12/6/16.
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What is a MIPS APM? APMs that include MIPS eligible clinicians and hold their clinicians accountable for cost and quality of care Participants receive special MIPS APM scoring Most Advanced APMs are also MIPS APMs Eligible clinicians who do not meet the payment or patient requirements for Advanced APM will be scored under MIPS APM APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System. CMS. Alternative Payment Models in the Quality Payment Program Updated 10/14/16. Accessed 12/12/16.
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MIPS & Advanced APMs for 2017
MIPS APM Advanced APM Comprehensive ESRD Care (CEC) Model (non-LDO 1-sided risk arrangement) Comprehensive ESRD Care (CEC)Model (LDO arrangement, non-LDO 2-sided risk arrangement) Comprehensive Primary Care Plus (CPC+) Model (Medical Home Model) Medicare Shared Savings Program (MSSP) Track 1 Medicare Shared Savings Program (MSSP) Tracks 2, 3 Next Generation ACO Model Oncology Care Model (OCM) (1-sided risk arrangement) (2-sided risk arrangement) * See for the most up-to-date list of APMs. APM = Alternative Payment Model; ESRD = End Stage Renal Disease; MIPS = Merit-Based Incentive Payment System. CMS. Alternative Payment Models in the Quality Payment Program Updated 10/14/16. Accessed 12/12/16.
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What If I’m In a Small, Rural, or Health Professional Shortage Area?
Exempt from MIPS if: ≤$30,000 in Medicare Part B allowed charges or ≤100 Medicare patients Reduced reporting requirements in some categories Increased opportunities for clinicians at CAHs, RHCs, and FQHCs to participate in Advanced APMs Support is available: Transforming Clinical Practice Initiative (TCPI) QPP-Small, Rural, Underserved Support (QPP-SURS) APM = Alternative Payment Model; CAH = Critical Access Hospital; FQHC = Federally Qualified Health Center; MIPS = Merit-Based Incentive Payment System; QPP = Quality Payment Program; RHC = Rural Health Clinic. CMS. Quality Payment Program. Accessed 12/9/16.
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What If I’m a Non-Patient Facing Clinician?
Eligible to participate in MIPS if the MIPS requirements are met Non-patient facing definitions: Individual MIPS-eligible clinicians: ≤100 patient facing encounters Group: >75% of NPIs billing under the group’s TIN are labeled as “non-patient facing” There are special reporting adjustments for non-patient facing clinicians MIPS = Merit-Based Incentive Payment System; NPI = National Provider Identifier; TIN = Tax Identification Number. CMS. Quality Payment Program /29/16. Accessed 12/13/16.
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Summary: How Do I Know If I’m Eligible for the Quality Payment Program?
Am I in an APM? No Yes Is this my first year in Medicare OR am I below the low volume threshold? Am I in an eligible Advanced APM? Yes No Do I have enough payments or patients through my eligible Advanced APM? Yes No Not subject to MIPS Subject to MIPS No Yes Qualifying Advanced APM Participant 5% lump sum bonus payment ( ) Higher fee schedule updates (2026+) APM-specific rewards Excluded from MIPS Subject to MIPS Favorable MIPS scoring APM-specific rewards APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System. CMS. Quality Payment Program. Accessed 12/8/16.
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POLLING QUESTION Are you eligible to participate in the Quality Payment Program in 2017? Yes, under MIPS Yes, under MIPS APM Yes, under an Advanced APM I’m not eligible I don’t know
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What is the Timeline for the Quality Payment Program?
2017 Performance Year MIPS Track: record data for MIPS measure(s) for at least 90 consecutive days Advanced APM Track: provide care during the year through the Advanced APM Feedback CMS provides feedback about your performance Jan. 1, 2017 Jun. 30, 2017 Oct. 2, 2017 Dec. 31, 2017 Mar. 31, 2018 Jan. 1, 2019 Deadline to Register as a Group Last Day to Start Collecting Data to participate in MIPS in 2017 Submit Performance Data MIPS Track: submit data for MIPS measures to avoid the negative payment penalty and potentially earn a positive payment adjustment Advanced APM Track: submit quality data through your Advanced APM to earn the 5% incentive payment Payment Adjustment MIPS Track: maximum ±4% payment adjustment Advanced APM Track: 5% incentive payment APM = Alternative Payment Model; MIPS = Merit-Based Incentive Payment System. CMS. Quality Payment Program. Accessed 12/8/16.
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POLLING QUESTION To what extent are you concerned about implications of the MACRA program on your practice? 1.Not concerned at all 2. 3. 4. 5. Extremely concerned
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Where Can I Go For More Information & Support?
CMS Quality Payment Program Online Portal & Service Center Available Monday – Friday, 8 AM – 8 PM ET
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Key Takeaways MACRA’s QPP replaces the Sustainable Growth Formula & reforms Medicare Part B payments Shift from volume-based to value-based payments 2 reimbursement tracks: MIPS & APM with distinct eligibility criteria Exceptions for non-patient facing and small, rural, and HPSA clinicians Starts in 2017 with payment adjustments in 2019 Eligible clinicians who don’t participate will receive a 4% negative payment adjustment in 2019 APM = Alternative Payment Model; HPSA = Health Professional Shortage Area; MACRA = Medicare Access and CHIP Reauthorization Act of 2015; MIPS = Merit-Based Incentive Payment System; QPP = Quality Payment Program
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