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Participation Criteria for quality payment Program year 2 (2018) nancy

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1 Participation Criteria for quality payment Program year 2 (2018) nancy
Participation Criteria for quality payment Program year 2 (2018) SUMMARY of Presentation changes 9 from the Budgetary Act 2018 Feb 9th. Performance categories: QUALITY, COST Virtual Groups Low-volume threshold Topped out measures Performance threshold and payment adjustments—bonuses, lowest score to avoid penalty Small practice bonus Complex patient bonus Ambulatory surgery center based clinicians Extreme and uncontrollable circumstances

2 Quality Payment Program
MIPS and Advanced APMs The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS by law to implement an incentive program, referred to as the Quality Payment Program, that provides for two participation tracks: The Merit-based Incentive Payment System (MIPS) If you decide to participate in MIPS, you will earn a performance-based payment adjustment through MIPS. Advanced Alternative Payment Models (Advanced APMs) If you decide to take part in an Advanced APM, you may earn a Medicare incentive payment for sufficiently participating in an innovative payment model. MIPS Advanced APMs OR The Quality Payment Program: MIPS only Burden reduction changes—most of the changes come from listening to clinicians

3 Merit-based Incentive Payment System (MIPS)
Basics for Year 2 (2018)

4 Merit-based Incentive Payment System (MIPS)
Quick Overview MIPS Performance Categories for Year 2 (2018) 50 Quality Cost Improvement Activities Promoting Interoperability + 10 15 25 = 100 Possible Final Score Points CHANGE Greater flexibility in setting the Cost performance category weight for three additional years beginning with the 2019 performance period. This means that we are not required to set the weight of Cost to 30% in Year 3 (2019). “So what?” – Allows us to continue to offer a gradual transition to help MIPS eligible clinicians familiarize themselves with the category. We will also not be implementing cost improvement scoring for Performance Years 2, 3, 4, and 5. Additional flexibility in calculating the MIPS performance threshold for three additional years beginning with the 2019 performance period. Ends in 2022 Comprised of four performance categories in 2018. So what? The points from each performance category are added together to give you a MIPS Final Score. The MIPS Final Score is compared to the MIPS performance threshold to determine if you receive a positive, negative, or neutral payment adjustment.

5 MIPS year 2 (2018) Participation Basics

6 In an Alternative Payment Model.
MIPS Year 2 (2018) Participation Basics In Year 2 (2018) of the Quality Payment Program, eligible clinicians can participate in MIPS: As an individual; As a group; As a virtual group; or In an Alternative Payment Model. No change in eligible clinicians

7 Participating as an Individual
MIPS Year 2 (2018) Participating as an Individual

8 MIPS Year 2 (2018) Who is Included? No change in the types of clinicians eligible to participate in 2018. MIPS eligible clinicians include: As a reminder: the definition of Physicians 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 Chiropractors With respect to certain specified treatment, a Doctor of Chiropractic legally authorized to practice by a State in which he/she performs this function. Physicians Physician Assistants Nurse Practitioners Clinical Nurse Specialists Certified Registered Nurse Anesthetists

9 MIPS Year 2 (2018) No change in basic exemption criteria.*
Who is Exempt? No change in basic exemption criteria.* Advanced APMs Newly-enrolled in Medicare Below the low-volume threshold Significantly participating in Advanced APMs Medicare Part B allowed charges for covered professional services under the PFS less than or equal to $90,000 a year OR Furnish services to 200 or fewer Medicare Part B patients a year Enrolled in Medicare for the first time during the performance period (exempt until following performance year) Receive 25% of their Medicare payments OR See 20% of their Medicare patients through an Advanced APM No change to basic exemption criteria, except the low volume threshold has changed. DISCUSS ON NEXT SLIDE *Only Change to Low-volume Threshold

10 Transition Year 1 (2017) Final
MIPS Year 2 (2018) Who is Included? Change to the Low-Volume Threshold for Include MIPS eligible clinicians billing more than $90,000 a year in Medicare Part B allowed charges for covered professional services under the Medicare PFS AND furnishing covered professional services to more than 200 Medicare beneficiaries a year Transition Year 1 (2017) Final Year 2 (2018) Final BILLING >$30,000 >100 BILLING >$90,000 >200 We’ve reduced the number of individual clinicians and groups who must participate in MIPS : to reduce burden for those who still find it challenging to participate and need more time to prepare.  This particularly helps MIPS eligible clinicians in small and rural practices who are required to participate in the program. The Bipartisan Budget Act of 2018, enacted on February 9, 2018, included several changes to MIPS. For Year 2 (2018) and future program years, these include: Change to the application of the MIPS payment adjustment. For the first payment year under MIPS in 2019 (based on 2017 performance), and all future payment years, the MIPS payment adjustment will only apply to covered professional services under the Medicare Physician Fee Schedule. Number of Medicare Part B benes who received covered professional services under PFS. “So what?” - The payment adjustment will not apply to Medicare Part B drugs and other items and services that are not covered professional services. 2017 low-volume thresholds are NOT affected.. AND AND Voluntary reporting remains an option for those clinicians who are exempt from MIPS.

11 MIPS Year 2 (2018) No change to eligibility determination process.
Determining Participation in Year 2 No change to eligibility determination process. CMS verifies that you meet the definition of a MIPS eligible clinician type. CMS reviews your historical PFS claims data from 9/1/16 to 8/31/17 to make the initial determination. “So what?” – If you are determined to be exempt during this review, you will remain exempt for the entirety of Year 2 (2018). CMS conducts a second determination on performance period PFS claims data from 9/1/17 to 8/31/18. “So what?” - If you were included in the first determination, you may be reclassified as exempt for Year 2 during the second determination. If you were initially exempt and later found to have claims/patients exceeding the low- volume threshold, you are still exempt. Then… Later… ********* NO CHANGE, BUT LOTS OF QUESTIONS. Initial determination Dec 2017 Second determination Dec 2018 emphasize THE EXAMPLES ON SLIDES…

12 How do I check my participation status?

13 Participation Status for Year 2 (2018)
Getting Started For MIPS: Start by checking your participation status using the National Provider Identifier (NPI) Look-up Tool on qpp.cms.gov. Please note that we did not mail individual letters outlining your Year 2 participation status. QPP WEBSITE NPI NUMBER

14 Participation Status for Year 2 (2018)
Getting Started For MIPS: If you’re included, you will see the below screen. You will need to submit data for each associated TIN where you are included at the individual level. Status appears, if exempt, you will not have to do anything for performance year 2018 If included will see the screen on slide… Let’s look at some examples of scenarios on next slide.

15 Participation Status for Year 2 (2018)
Getting Started: Scenarios You’re exempt at both the individual and group level and do not need to participate. You’re exempt at the individual level, but may need to participate if your TIN opts to report at the group level. Go over slide. You’re included at both the individual and group level and need to participate.

16 Participating as a Group
MIPS Year 2 (2018) Participating as a Group

17 MIPS Year 2 (2018) Participating at the Group Level You Have Asked: “Does the $90,000 in Medicare Part B allowed charges for covered professional services under the PFS AND 200 Medicare Part B beneficiaries who are furnished covered professional services under the PFS also apply at the group level if my practice chooses group reporting?” Yes. For Year 2 (2018), the Low-Volume Threshold for MIPS also applies at the group level. “So what?” – The low-volume threshold exclusion is based on both the individual (TIN/NPI) and group (TIN) status. For group-level reporting, a group (as a whole) is assessed to determine if it exceeds the low-volume threshold.   No change, but group assessed same as individual… Example on next slide.

18 Individually (Assessed at the TIN/NPI Level)
MIPS Year 2 (2018) Participating at the Group Level Example Individually (Assessed at the TIN/NPI Level) Group (Assessed at the TIN Level) Dr. “A.” Billed $250,000 Saw 210 Patients Included in MIPS Dr. “B.” Billed $100,000 Saw 80 Patients Exempt from MIPS Nurse Practitioner Billed $50,000 Saw 40 Patients Exempt from MIPS As a Group (Dr. A., Dr. B., NP) Billed $400,000 Saw 330 Patients ALL Included in MIPS BILLING > $90,000 >200 Remember: To participate AND

19 Participating as a Virtual Group
MIPS Year 2 (2018) Participating as a Virtual Group

20 MIPS Year 2 (2018) New: Virtual Groups What is a virtual group?
A virtual group can be made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter what specialty or location) to participate in MIPS for a performance period for a year. To be eligible to join or form a virtual group, you would need to be a: Solo practitioners who exceed the low-volume threshold individually, and are not a newly Medicare-enrolled eligible clinician, a Qualifying APM Participant (QP), or a Partial QP choosing not to participate in MIPS. Group that has 10 or fewer eligible clinicians and exceeds the low-volume threshold at the group level. CHANGE Virtual groups Solo practitioners Groups of 10 or less both have to be eligible, exceed the low volume threshold Example on next slide

21 There is no limit to the number of TINs that form a virtual group.
MIPS Year 2 (2018) Virtual Groups There is no limit to the number of TINs that form a virtual group.

22 MIPS Year 2 (2018) New: Virtual Groups What else do I need to know?
Generally, policies that apply to groups would apply to virtual groups. Virtual groups use same submission mechanisms as groups. All clinicians within a TIN are part of the virtual group. Virtual groups are required to aggregate their across the virtual group for each performance category and will be assessed and scored as a virtual group. Solo practitioners and groups who want to form a virtual group must go through the election process. Virtual groups election must occur prior to the beginning of the performance period and cannot be changed once the performance period starts. CHANGE Policies of virtual group are same as group but 2 step election process---info on QPP website

23 Performance Categories
MIPS Year 2 (2018) Performance Categories

24 Transition Year 1 (2017) Final
MIPS Year 2 (2018) Quality Component Transition Year 1 (2017) Final Year 2 (2018) Final Weight to Final Score 60% 50% Data Completeness 50% for submission mechanisms except for Web Interface and CAHPS. Measures that do not meet the data completeness criteria earn 3 points. 60% for submission mechanisms except for Web Interface and CAHPS. Measures that to not meet data completeness criteria earn 1 point. Burden Reduction Aim: Small practices will continue to receive 3 points. Basics: Change: 50% of Final Score in 2018 270+ measures available You select 6 individual measures 1 must be an Outcome measure OR High-priority measure You may also select a specialty-specific set of measures CHANGE 50% weighting Measures that do not meet completeness are receiving 1 instead of 3 points To ensure valid analysis, some QM, not all, require reporting on non-Medicare patients (60%) to meet measurement requirements MA not included… Burden Reduction Aim:

25 MIPS Year 2 (2018) Quality Basics: Component
Transition Year 1 (2017) Final Year 2 (2018) Final Scoring 3-point floor for measures scored against a benchmark. 3 points for measures that do not have a benchmark or do not meet case minimum. Bonus for additional high priority measures up to 10% of denominator for performance category. Bonus for end-to-end electronic reporting up to 10% of denominator for performance category. No changes Basics: Change: 50% of Final Score in 2018 270+ measures available You select 6 individual measures 1 must be an Outcome measure OR High-priority measure You may also select a specialty-specific set of measures As more than 80% of the MIPS quality measures finalized are tailored for specialists, we continuously work with specialty societies in defining the direction for quality measurement as well as the identification of specific quality area gaps to focus on. We plan to partner with clinicians in developing quality measures and provide funding. We will continue to allow reweighting of the quality and improvement activities performance categories for extenuating circumstances. Do not have to do 270 measures…six, if specialty measures have 3 or 4 that is all you report…

26 Quality Measures Reminder:
Meaningful and Relevant measures….opioids during this crisis time

27 MIPS Year 2 (2018) Quality Topped Out Measures:
Topped-out measures will be removed and scored on 4 year phasing out timeline. Topped out measures with measure benchmarks that have been topped out for at least 2 consecutive years will receive up to 7 points. The 7-point scoring policy for the 6 topped out measures identified for the 2018 performance period is finalized. These measures are identified on the next slide. Topped out measures will only be removed after a review of performance and additional considerations. Topped out policies do not apply to CMS Web Interface measures, but this will be monitored for differences with other submission options. What is the significance? A measure may be considered topped out if meaningful distinctions and improvement in performance can no longer be made. Topped out measures could have an impact on the scores for certain MIPS eligible clinicians, and provide little room for improvement for the majority of MIPS eligible clinicians. A measure may be considered topped out if measure performance is so high and unvarying that meaningful distinctions and improvement in performance can no longer be made. Topped out measures could have a disproportionate impact on the scores for certain MIPS eligible clinicians, and provide little room for improvement for the majority of MIPS eligible clinicians. Topped-out measures will be removed and scored on 4 year phasing out timeline. Example: Year 1: Measures are identified as topped out in the benchmarks published for the 2017 MIPS performance Period. The 2017 benchmarks are posted on the Quality Payment Program website: Year 2: Measures are identified as topped out in the benchmarks published for the 2018 MIPS performance period. Year 3: Measures are identified as topped out in the benchmarks published for the 2019 MIPS performance period. The measures identified as topped out in the benchmarks published for the 2019 MIPS performance period and 2018, 2017 periods have special scoring applied for the 2019 MIPS performance period Year 4: Topped out measures that are finalized for removal are no longer available for reporting

28 MIPS Year 2 (2018) Quality Topped Out Measures:
The six topped out measures include the following: Perioperative Care: Selection of Prophylactic Antibiotic-First or Second Generation Cephalosporin. (Quality Measure ID: 21) Melanoma: Overutilization of Imaging Studies in Melanoma.(Quality Measure ID: 224) Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients). (Quality Measure ID: 23) Image Confirmation of Successful Excision of Image-Localized Breast Lesion. (Quality Measure ID: 262) Optimizing Patient Exposure to Ionizing Radiation: Utilization of a Standardized Nomenclature for Computerized Tomography (CT) Imaging Description (Quality Measure ID: 359) Chronic Obstructive Pulmonary Disease (COPD): Inhaled Bronchodilator Therapy (Quality Measure ID: 52) What is the significance? A measure may be considered topped out if meaningful distinctions and improvement in performance can no longer be made. Topped out measures could have an impact on the scores for certain MIPS eligible clinicians, and provide little room for improvement for the majority of MIPS eligible clinicians. List of current topped out measure…

29 MIPS Year 2 (2018) Cost Change: Cost performance category weight is finalized at 10% for 2018. 10 episode-based measures adopted for the 2017 MIPS performance period will not be used. We are developing new episode-based measures with significant clinician input and are providing feedback on these measures this fall through field testing. This will allow clinicians to see their cost measure scores before the measures are potentially included in the MIPS program. We will propose new cost measures in future rulemaking. Basics: Change: 10% Counted toward Final Score in 2018 Medicare Spending per Beneficiary (MSPB) and total per capita cost measures are included in calculating Cost performance category score for the 2018 MIPS performance period. These measures were used in the Value Modifier and in the MIPS transition year We have finalized the Cost performance category weight at 10% of the MIPS Final Score for Year 2 after being weighted at 0% in the 2017 transition year. We are required by law to weight the Cost performance category at 30% beginning in Year 3 (2019) of the program. To assist clinicians with the Cost performance category, we will provide feedback on the scoring system and cost measures from the 2017 transition year by summary Feedback begins after the submission period(March 31 unless extended) and before end of the payment year.. For 2018, we are not using the 10 episode-based measures used in the transition year, but we are developing new episode-based measures for which we’ll solicit feedback in the fall episode cost measures field tested and comment period in fall 2018

30 MIPS Year 2 (2018) Cost Reporting/Scoring: Basics:
Each individual MIPS eligible clinician’s and group’s cost performance will be calculated using administrative claims data if they meet the case minimum of attributed patients. Individual MIPS eligible clinicians and groups are not required to submit any additional information for the cost performance category. Performance is compared against performance of other MIPS eligible clinicians and groups during the performance period so benchmark is not based on a previous year. Performance category score is the average of the two measures: Medicare Spending per Beneficiary (MSPB) and total per capita cost measures. If only one measure can be scored, it will serve as the performance category score. Basics: Change: 10% Counted toward Final Score in 2018 Medicare Spending per Beneficiary (MSPB) and total per capita cost measures are included in calculating Cost performance category score for the 2018 MIPS performance period. These measures were used in the Value Modifier and in the MIPS transition year Individual MIPS eligible clinicians and groups are not required to submit any additional information for the cost performance category.

31 MIPS Year 2 (2018) Improvement Activities Number of Activities:
No change in the number of activities that MIPS eligible clinicians must report to achieve a total of 40 points. Burden Reduction Aim: MIPS eligible clinicians in small practices and practices in a rural areas will continue to report on no more than 2 activities to achieve the highest score. Basics: 15% of Final Score in 2018 112 activities available in the inventory Medium and High Weights remain the same from Year 1 Medium = 10 points High = 20 points A simple “yes” is all that is required to attest to completing an Improvement Activity Patient-centered Medical Home: We finalized the term “recognized” is equivalent to the term “certified” as a patient centered medical home or comparable specialty practice. 50% of practice sites* within a TIN or TINs that are part of a virtual group need to be recognized as patient-centered medical homes for the TIN to receive the full credit for Improvement Activities in 2018. No change for improvement activities…small, rural, and HPSA—med=20 and high = 40 *We have defined practice sites as the practice address that is available within the Provider Enrollment, Chain, and Ownership System (PECOS).

32 MIPS Year 2 (2018) Improvement Activities Additional Activities:
We are finalizing additional activities, and changes to existing activities for the Improvement Activities Inventory including credit for using Appropriate Use Criteria (AUC) through a qualified clinical support mechanism for all advanced diagnostic imaging services ordered. Basics: 15% of Final Score in 2018 112 activities available in the inventory Medium and High Weights remain the same from Year 1 Medium = 10 points High = 20 points A simple “yes” is all that is required to attest to completing an Improvement Activity Scoring: Continue to designate activities within the performance category that also qualify for an Advancing Care Information performance category bonus. For group reporting, only one MIPS eligible clinician in a TIN must perform the Improvement Activity for the TIN to receive credit. For virtual group reporting: only one MIPS eligible clinician in a virtual group must perform the Improvement Activity for the TIN to receive credit. Continue to allow simple attestation of Improvement Activities. No change We intend to issue more detailed guidance about improvement activities, such as allowing attestation to reduce burden. Our goal is to allow flexibility in performing activities and avoid complex reporting requirements.

33 Improvement Activities
Relevant improvement activities…

34 MIPS Year 2 (2018) Advancing Care Information CEHRT Requirements:
Burden Reduction Aim: MIPS eligible clinicians may use either the or 2015 CEHRT or a combination in 2018. A 10% bonus is available for using only 2015 Edition CEHRT. Measures and Objectives: CMS finalizes exclusions for the E-Prescribing and Health Information Exchange Measures. Basics: 25% of Final Score in 2018 Comprised of Base, Performance, and Bonus score Promotes patient engagement and the electronic exchange of information using certified EHR technology Two measure sets available to choose from based on EHR edition. Scoring: No change to the base score requirements for the 2018 performance period/2020 payment year. For the performance score, MIPS eligible clinicians and groups will earn 10% for reporting to any one of the Public Health and Clinical Data Registry Reporting measures as part of the performance score. For the bonus score a 5% bonus score is available for reporting to an additional registry not reported under the performance score. Additional Improvement Activities are eligible for a 10% Advancing Care Information bonus for completion of at least 1 of the specified Improvement Activities using CEHRT. Total bonus score available is 25% No changes Special rules exist for the Improvement Activities performance category under MIPS for: MIPS eligible clinician types in practices with 15 or fewer eligible clinicians and solo practitioners; MIPS eligible clinician types in designated rural areas; and MIPS eligible clinician types working in HPSAs. The points for both medium-weight and high-weight activities are doubled. This means: Medium-weight = 20 points; and High-weight = 40 points.

35 MIPS YEAR 2 (2018) Performance Threshold and Payment Adjustment 35

36 MIPS Year 2 (2018) MIPS: Performance Threshold & Payment Adjustment
Change: Increase in Performance Threshold and Payment Adjustment Transition Year 1 (2017) Final Year 2 (2018) Final 3 point threshold Exceptional performer set at 70 points Payment adjustment set at +/- 4% 15 point threshold Exceptional performer set at 70 points Payment adjustment set at +/- 5% Report all required improvement activities Meet ACI base score and submit 1 Quality measure that meets data completeness Meet ACI base score, by reporting 5 base measures and submit one medium weight IA Submit 6 quality measures that meet data completeness criteria How can I achieve 15 points? Report all required Improvement Activities. Meet the Advancing Care Information base score and submit 1 Quality measure that meets data completeness. Meet the Advancing Care Information base score, by reporting the 5 base measures, and submit one medium-weighted Improvement Activity. Submit 6 Quality measures that meet data completeness criteria. 36

37 MIPS Year 2 (2018) New: Small Practice Bonus
5 bonus points added to final score of any MIPS eligible clinician or group who is in a small practice (15 or fewer clinicians), so long as the MIPS eligible clinician or group submits data on at least 1 performance category in an applicable performance period. Burden Reduction Aim: o We recognize the challenges of small practices and will provide a 5 point bonus to help them successfully meet MIPS requirements. Added to final score 37

38 MIPS Year 2 (2018) New: Complex Patient Bonus
Up to 5 bonus points available for treating complex patients based on medical complexity. o As measured by Hierarchical Condition Category (HCC) risk score and a score based on the percentage of dual eligible beneficiaries. MIPS eligible clinicians or groups must submit data on at least 1 performance category in an applicable performance period to earn the bonus. Added to _________________score 38

39 Transition Year 1 (2017) Final
MIPS Year 2 (2018) If You’re Included… Note the changes to the performance threshold and payment adjustments. Transition Year 1 (2017) Final Year 2 (2018) Final Final Score 2017 Payment Adjustment 2019 >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 Final Score 2018 Change Y/N Payment Adjustment 2020 >70 points N Positive adjustment greater than 0% Eligible for exceptional performance bonus—minimum of additional 0.5% points Y Not eligible for exceptional performance bonus 15 points Neutral payment adjustment Negative payment adjustment greater than -5% and less than 0% points Negative payment adjustment of -5% Change 15 points is neutral

40 MIPS Year 2 (2018) Submission Mechanisms No change: All of the submission mechanisms remain the same from Year 1 to Year 2 Performance Category Submission Mechanisms for Individuals Submission Mechanisms for Groups (Including Virtual Groups) Quality QCDR Qualified Registry EHR Claims CMS Web Interface (groups of 25 or more) Cost Administrative claims (no submission required) Administrative claims (no submission required) Improvement Activities Attestation QCDR Qualified Registry EHR Advancing Care Information Please note: Continue with the use of 1 submission mechanism per performance category in Year 2 (2018). Same policy as Year 1. The use of multiple submission mechanisms per performance category is deferred to Year 3 (2019). No change—use of multiple submission mechanisms is deferred to Year 3.

41 MIPS year 2 (2018) Special Status

42 Transition Year 1 (2017) Final
MIPS Year 2 (2018) Non-patient Facing No change in Non-Patient Facing criteria. Transition Year 1 (2017) Final Year 2 (2018) Final Individual – If you have <100 patient facing encounters. Groups – If your group has >75% of NPIs billing under your group’s TIN during a performance period are labeled as non-patient facing. No Change to Individual and Group policy. NEW - Virtual Groups are included in the definition. Virtual Groups that have >75% of NPIs within a virtual group during a performance period are labeled as non-patient facing Finalized as proposed. Burden Reduction No change…still eligible for reweighing for ACI. IA report fewer 2 medium or 1 high activity;

43 MIPS Year 2 (2018) No change in Hospital-based criteria.
Clinicians are considered hospital-based if they provide 75% or more of their services in an: Inpatient Hospital; On-campus Outpatient Hospital; Emergency Room; or Off-campus Outpatient Hospital. (Newly added for Year 2.) Hospital-based clinicians have their Advancing Care Information performance category reweighted to zero. Hospital-based clinicians are subject to MIPS if they exceed the low-volume threshold and should report the Quality and Improvement Activities performance categories. No change in hospital based criteria definition for clinicians.

44 MIPS Year 2 (2018) Ambulatory Surgical Center-based (ASC) Change to add Ambulatory Surgical Center-based special status to the 2017 and 2018 performance years. Clinicians are considered Ambulatory Surgical Center(ASC)-based if they provide 75% or more of their services in a Place of Service (POS) code 24. POS 24 defines an ASC as a freestanding facility, other than a physician's office, where surgical and diagnostic services are provided on an ambulatory basis. ASC-based clinicians have their Advancing Care Information performance category reweighted to zero. ASC-based clinicians are subject to MIPS if they exceed the low-volume threshold and should report the Quality and Improvement Activities performance categories. Please note that ASC-based determinations will be made independent of hospital-based determinations. ASC-based MIPS eligible clinician types qualify for an automatic reweighting of the Advancing Care Information performance category to zero. However, they can still choose to report if they would like, and, if data is submitted, CMS will score their performance and weight their Advancing Care Information performance accordingly. CHANGE ASC-based clinicians are subject to MIPS if they exceed the low-volume threshold and should report the Quality and Improvement Activities performance categories.

45 MIPS Year 2 (2018) Small, Rural, Health Professional Shortage Areas No change to the basic application of Small, Rural, and HPSA special status; minor changes to technical aspects. Special Status Component Year 2 (2018) Final Application Small Practice Definition Practices consisting of 15 or fewer eligible clinicians. No change to the application of these special status designations from Year 1 to Year 2. Rural and Health Professional Shortage Areas Rural and HPSA practice designations An individual MIPS eligible clinician, a group, or a virtual group with multiple practices under its TIN (or TINs within a virtual group) with more than 75 percent of NPIs billing under the individual MIPS eligible clinician or group’s TIN or within a virtual group in a ZIP code designated as a rural area or HPSA. No change to application of small, rural and HPSA status

46 MIPS Year 2 (2018) Advancing Care Information Reweighting No change in the Advancing Care Information performance category automatic reweighting policy for MIPS eligible clinicians who are considered one of the following: Non-patient Facing; Hospital-based; Ambulatory Surgical Center-based; and Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists. No change ACI reweighing.

47 MIPS Year 2 (2018) Extreme and Uncontrollable Circumstances
Extreme and Uncontrollable Circumstances in Year 2 (2018): The Final Rule with Comment Period for Year 2 extends the Transition Year hardship exception reweighting policy for the Advancing Care Information performance category to now include Quality, Cost, and Improvement Activities. This policy applies to all of the 2018 MIPS performance categories. A hardship exception application is required. The hardship exception application deadline is December 31, 2018. CHANGE 2 year extension for hardship that now includes QM, COST, IA for reweighting ACI Hardship application is required….

48 Quality payment program
Help & Support

49 Technical Assistance RESOURCE LIBRARY UPDATE
Available Resources CMS has free resources and organizations on the ground to provide help to eligible clinicians included in the Quality Payment Program: RESOURCE LIBRARY UPDATE To make it easier for clinicians to search and find information on the Quality Payment Program, CMS has moved its library of QPP resources to CMS.gov. QPP.CMS.GOV redirects to the CMS.GOV Resource Library: CMS.GOV Resource Library: Program/Resource-Library/Resource-library.html Final Rule Materials Posted: Program/Quality-Payment-Program.html To learn more, view the Technical Assistance Resource Guide:

50 Contact Info Nancy L Fisher, MD, MPH Chief Medical Officer, Region X and VIII* Centers for Medicare & Medicaid Services *acting 53

51


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