1. JAMES R. CHRISTINA, DPM 301-581-9265 jrchristina@apma.org
MIPS in a deep dive
JAMES R. CHRISTINA, DPM
October 1, 2015
forgiveness

2. Quality Payment Program
SGR
MACRA
(The Medicare Access and CHIP Reauthorization Act of 2015)
Quality Payment Program
MIPS APM

3. MIPS Score Highest total of 100
EPs will receive either a positive or negative payment adjustment to Medicare part B fee schedule based on MIPS score
Almost all podiatrists will report through MIPS first year
Exceptional Performance Threshold 70
500M

4. Thresholds
CMS set the Performance Threshold at 3 and the Exceptional Performance Threshold at 70, meaning that any clinician with a score of at least 3—which can be accomplished by submitting, for example, just one Quality measure—will avoid a negative adjustment, and those earning a score of at least 70 will be eligible for an Exceptional Performance Adjustment from the annual $500 million pool.

5. MIPS Adjustments
2019: -4% to +4% (based on 2017 score) 2020: -5% to +5% (based on 2018 score) 2021: -7% to +7% (based on 2019 score) 2022 : -9% to +9% (based on 2020 score)

6. MIPS Year 1 Mostly budget neutral Penalty no more than 4%
Most positive adjustments no more than 4% …positive moved based on budget neutrality
“Exceptional Performance” (MIPS Score of 70 or higher—access to additional $500 million bonus pool)

7. MIPS
Two determination period options to meet 2017 low volume threshold:
9/1/ /31/2016 or
9/1/2016 – 8/31/2017

8. MIPS
MIPS reporting not limited to Medicare patients* (but some quality measures do have age ranges in their denominators so pay attention to them) *Reporting Quality Component by Claims method is exception

10. CHOSE YOUR COURSE OF PARTICIPATION
Three options with regards to MIPS

11. MAXIMUM MIPS
Clinicians can choose to report to MIPS for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment.

12. MODERATE MIPS
Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.

13. MINIMUM MIPS
Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative payment adjustment.

14. MINIMUM SCORE OF 3
For the 2017 transition year, if the measure is submitted but is unable to be scored because it does not meet the required case minimum (20), does not have a benchmark, or does not meet the data completeness requirement (at least 50% reporting rate), the measure will receive a score of 3 points

15. WHAT ABOUT NO MIPS?
Four percent payment reduction on Medicare Part B Fee For Service Payments in 2019

16. MIPS Quality (60%) Choose 6 PQRS measures
One must be an outcome measure (or if no outcome available then a high priority measure)
All 6 must be reported by the same method

17. Quality Measures Submission Methods
Claims
50% or more of Medicare Part B patients
Registry
50% or more of all patients
EHR
50% of all patients
CMS Web Interface (groups of 25+)
ALL SIX MUST BE SUBMITTED BY SAME MECHANISM

18. QPP.CMS.GOV

19. QPP.CMS.GOV

20. QPP.CMS.GOV

21. QUALITY MEASURES Claims Reporting
Documentation of Current Meds in the Medical Record
Diabetes: Hemoglobin A1c (HbA1c) Poor Control - Intermediate Outcome
Pain Assessment and Follow-Up
Pneumococcal Vaccination Status for Older Adults
BMI Screening and Follow Up Plan
Influenza Immunization
Screening for High Blood Pressure and Follow Up
Tobacco Screening and Cessation Intervention

22. The Six Measures I Recommend
Documentation of Current Meds in the Medical Record
Pneumococcal Vaccination Status for Older Adults
BMI Screening and Follow Up Plan
Influenza Immunization
Screening for High Blood Pressure and Follow Up
Tobacco Screening and Cessation Intervention

23. Documentation of Current Medications in Medical Record*

25. Pneumococcal Vaccination Status for Older Adults

26. BMI Screening and Follow Up Plan

29. Influenza Immunization

31. Screening for High Blood Pressure and Follow Up

35. Tobacco Screening and Cessation Intervention

37. QUALITY MEASURES Registry Reporting
Diabetes: Hemoglobin A1c (HbA1c) Poor Control Intermediate Outcome
Diabetes: Medical Attention for Nephropathy
Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam
Diabetic Foot and Ankle Care, Ulcer Prevention – Examination of Footwear
Documentation of Current Meds in the Medical Record
Immunizations for Adolescents

38. QUALITY MEASURES Registry Reporting
Functional Status Change for Patients with Foot or Ankle Impairments – Outcome
Pain Assessment and Follow-Up
Pneumococcal Vaccination Status for Older Adults
Preventive Care & Screening: Body Mass Index (BMI) Screening & Follow-Up Plan
Preventive Care and Screening: Influenza Immunization
Screening for High Blood Pressure and Follow Up
Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling

39. Six RecommendedRegistry Measures (All patients)
Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurologic Exam
Diabetic Foot and Ankle Care, Ulcer Prevention – Examination of Footwear
Documentation of Current Meds in the Medical Record
Screening for High Blood Pressure and Follow Up
Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
Preventive Care & Screening: Body Mass Index (BMI) Screening & Follow-Up Plan

40. QUALITY MEASURES EHR Reporting Diabetes: Foot Exam
Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) – Intermediate Outcome
Diabetes: Medical Attention for Nephropathy
Documentation of Current Medications in the Medical Record*
Falls: Screening for Future Fall Risk*
Pneumococcal Vaccination Status for Older Adults
Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan

41. QUALITY MEASURES EHR Reporting
Preventive Care and Screening: Influenza Immunization
Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention

42. When choosing quality measures check minimum case requirements!
Most minimum case requirements listed as 20

43. Advancing Care Information
In 2017, there are two measure set options for reporting. The option you use to submit your data is based on your electronic health record edition.
Option 1: Advancing Care Information Objectives and Measures
Option 2: 2017 Advancing Care Information Transition Objectives and Measures
You can report the Advancing Care Information Objectives and Measures (Option 1):
If you have technology certified to the 2015 Edition; or
If you have a combination of technologies from 2014 and 2015 Editions that support these measures.
You can report the 2017 Advancing Care Information Transition Objectives and Measures (Option 2):
If you have technology certified to the 2014 Edition; or
If you have a combination of technologies from 2014 and 2015 Editions.

44. Advancing Care Information (25%)
4 Measures if using 2014 ONC Certified EHR
(Transition—Option 2)

45. Advancing Care Information (25%)
40% credit just for reporting
Other 60% depends on performance
No more clinical decision support rule
No more CPOE

46. Base Score + Performance Score + Bonus Points
Total ACI Score
Base Score + Performance Score + Bonus Points

47. ACI Base Score Base score: 10 points for reporting a measure
Base Score: Max 40
Base Score: Can get 40 points just for reporting numerators/denominators or yes/no for 4 objectives
Need numerator to be ≥ 1 for each

48. ACI Performance score
Performance Score: Receive 1-20 points for each measure reported based on performance of that measure
Performance Score: Max 80 points

49. ACI Bonus Points
5 Bonus Points for reporting to any additional public health or clinical data registry
10 Bonus Points for achieving one Improvement Activity via CEHRT

50. ACI
Score 100 or above on ACI = full 25 MIPS points

51. MIPS ACI Base 4 Measures (Transition)
Protect Patient Health Information (yes/no)
MUST BE A “YES” OR ZERO FOR ACI
Electronic Prescribing
Provide Patient Electronic Access (numerator/denominator—performance weight up to 20%)
Health Information Exchange (numerator / denominator—performance weight up to 20%)

52. ACI
Can submit more than 4 measures (up to 11) for additional credit

53. ACI All 11 Measures Security Risk Analysis E-prescribing
Provide Patient Electronic Access
Health Information Exchange
View, Download, or Transmit (VDT) (up to 10%)
Provide Patient-Specific Education (up to 10%)
Secure Messaging (up to 10%)
Medication Reconciliation (up to 10%)
Immunization Registry Reporting (0 or 10%)
Syndromic Surveillance Reporting (5% bonus)
Specialized Registry Reporting (5% bonus)

54. ACI Total Score
Reporting Score (40) + Performance Score (80) + Bonuses (20) = 140
If earn 100 (or more), get the full 25 ACI score
If earn less than 100, declines proportionately. It is not all or nothing!

55. Clinical Practice Improvement Activities (15%)
List of more than 90 options
Choose 4 activities if in a group of more than 15 clinicians
Choose 2 activities if in a group of 15 or fewer clinicians

56. Clinical Practice Improvement Activities (15%)
Medium weight = 10 points
High weight = 20 points
Activities double weighted if group of less than 15
Score = points / 40

57. QPP.CMS.GOV

58. Clinical Practice Improvement Activities (15%)
Registration in your state’s prescription drug monitoring program - Medium
Implement Fall Screening & Assessment Program - Medium
Provide 24/7 access to clinician who has real-time access to patient’s medical record - High
Assess patient experience of care through surveys, advisory councils and/or other mechanisms - Medium
Use decision support and standardized treatment protocols - Medium
Program to send reports back to referring clinician - Medium

59. Clinical Practice Improvement Activities (15%)
Collection and follow-up on patient experience and satisfaction data on beneficiary engagement - High
Collection and use of patient experience and satisfaction data on access - Medium
Consultation of the Prescription Drug Monitoring program - High
Engagement of community for health status improvement - Medium
Engagement of patients, family and caregivers in developing a plan of care - Medium

60. Clinical Practice Improvement Activities (15%)
Engagement of patients through implementation of improvements in patient portal – Medium
Implementation of condition-specific chronic disease self-management support programs - Medium
Implementation of use of specialist reports back to referring clinician or group to close referral loop - Medium
Improved practices that disseminate appropriate self-management materials - Medium
Use of decision support and standardized treatment protocols - Medium

61. Cost (0% in 2017)
Calculated by claims review so no additional reporting
Higher points for more efficient resource use
Each cost measure worth up to 10 points

62. APMs Exempt from MIPS payment adjustments
Successful participation = 5% bonus and no MIPS adjustment
Have to receive certain amount of payments or see certain number of patients through APM

63. Advanced APM
Advanced APMs are those in which clinicians accept risk for providing coordinated, high- quality care.

64. APMA MACRA RESOURCES

65. Resources
For more information on Quality measures: For more information on CPIA: For more information on Advancing Care: Quality Payment Program (CMS Web Page):

66. QUESTIONS