1. The CMS Final Rule Updates for 2018 Brought to you by ifa united i-tech!

2. Introduction to ifa Ophthalmology only EHR
Ability to connect and interface with over 500 ophthalmic devices.
We have been in the market 33+ years
Extensive experience in Health IT
Experienced and highly trained consultants specializing in CMS and ONC regulatory affairs
Good morning everyone, As debra mentioned this webinar is will include topics from the CMS final rule which was announced Novmber 2. Before I get into the detail about this rule, I want to give everyone a brief introduction about ifa.

3. Quality Payment Program Year 2
The final rule for the second year of the Quality Payment Program includes flexibilities to:
Help MIPS eligible clinicians prepare for full implementation in year 3
Ease the burden on year 2 reporting
Now that I have introduced ifa I want to get into the main topic of the webinar, the CMS final rule and what that means for the quality payment program.

4. QPP Final Rule Summary
Some positive actions taken in the final rule include:
Postponing mandate for upgrading to 2015-edition certified electronic health records (EHRs).
Not increasing requirements for the number of quality measures reported.
Physicians will have to report six measures.
They would have had to report nine had the old Physician Quality Reporting System had remained in place.

5. QPP Final Rule Summary
Some additional positive actions taken in the final rule include:
Adding a hardship exemption to the Advancing Care Information (formerly Meaningful Use) category for practices of 15 or fewer physicians.
Continuing to allow physicians to report on Improvement Activities through simple attestation.
Adding a hardship exemption for physicians affected by hurricanes and wildfires.

6. More Options for Small Practices
Excluding individual MIPS eligible clinicians or groups with less than or equal to:
$90,000 in Part B allowed charges OR
200 Part B beneficiaries.
Giving solo practitioners and small practices the choice to form or join a Virtual Group to participate with other practices.
Adding a new hardship exception for the Advancing Care Information performance category for small practices.
CMS realized it can be hard for small practices to participate in the Quality Payment Program, so they are continuing to offer tailored flexibilities for groups of 15 or fewer clinicians including:

7. More Options for Small Practices
Adding 5 bonus points to the final scores of small practices.
Continuing to award small practices 3 points for measures in the Quality performance category that don’t meet data completeness requirements.

8. Gradual Implementation
Weighting the MIPS Cost performance category to 10% of your total MIPS final score.
CMS will calculate cost measure performance; no action is required from clinicians.
Increasing the performance threshold to 15 points in Year 2 (from 3 points in the transition year).
CMS is continuing many of its transition year policies while introducing modest changes. As they move towards full implementation of the Quality Payment Program, the policies below were finalized to ensure that clinicians are ready for full implementation in year 3. These policies include:

9. Extreme and Uncontrollable Circumstances
Over the past several months, numerous clinicians have been affected in many areas of the country due to Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period.
CMS addressed extreme and uncontrollable circumstances for both the transition year and the 2018 MIPS performance period in this final rule with comment.

10. Extreme and Uncontrollable Circumstances
For the transition year, if a MIPS eligible clinician’s CEHRT is unavailable as a result of extreme and uncontrollable circumstances (e.g., a hurricane, natural disaster, or public health emergency), the clinician may submit a hardship exception application to be considered for reweighting of the Advancing Care Information performance category. This application is due by December 31, 2017.

11. Extreme and Uncontrollable Circumstances
This final rule with comment period extends this reweighting policy for the three other performance categories (Quality, Cost, and Improvement Activities) starting with the 2018 MIPS performance period.
Because the policies relating to reweighting the Quality, Cost, and Improvement Activities performance categories are not effective until next year, CMS is issuing an interim final rule for automatic extreme and uncontrollable circumstances where clinicians can be exempt from these categories in the transition year without submitting a hardship exception application (note that cost has a 0% weight in the transition year).

12. What does that mean for 2017?
Clinicians in affected areas that do not submit data will not have a negative adjustment. CMS recognizes that the circumstances have created a significant hardship that has affected the availability and applicability of measures.
Clinicians that do submit data will be scored on their submitted data. This allows them to be rewarded for their performance in MIPS. Because MIPS is a composite, clinicians have to submit data on two or more performance categories to get a positive payment adjustment.

13. What does that mean for 2017?
The policy applies to individuals (not group submissions), but all individuals in the affected area will be protected for the 2017 MIPS performance period.
It should be noted that if a MIPS eligible clinician who is eligible for reweighting due to extreme and uncontrollable circumstances, but still chooses to report (as an individual or group), that they will be scored on that performance category based on their results.

14. 21st Century Cures Act
Reweighting the Advancing Care Information performance category to 0% of the final score for ambulatory surgical center (ASC)-based MIPS eligible clinicians.
Using the 21st Century Cures Act authority for significant hardship exceptions and hospital-based MIPS eligible clinicians to reweight the Advancing Care Information performance category to 0% of the final score.
Enacted in 2016, the 21st Century Cures Act contains provisions affecting the Advancing Care Information performance category for the Quality Payment Program’s current transition year and future years. The 21st Century Cures Act was enacted after the publication of the Quality Payment Program Year 1 Final Rule. In this final rule with comment period, CMS is implementing these provisions in the 21st Century Cures Act, some of which will apply to the MIPS transition year including:

15. Virtual Groups
A Virtual Group is a combination of 2 or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter specialty or location) to participate in MIPS for a performance period of a year.
Another new feature introduced is the virtual groups

16. Virtual Group Agreements
The virtual group arrangement must be set forth in a formal written agreement between each solo practitioner and group that composes a virtual group.
The written virtual group agreement must identify, but need not include as parties to the agreement, all clinicians who bill under the Taxpayer Identification Number (TIN) of a group that is in the virtual group, and would apply for at least one performance period.

17. Agreement Checklist
CMS has created a Virtual Groups Model Agreement to serve as a template that virtual groups could use, and to which they could add other elements that would meet the needs of the virtual group.

18. MIPS Final Score Changes
2017 MIPS performance period final score:
Performance category weight:
Quality 60%
Cost 0%
Improvement Activities 15%
Advancing Care Information 25%.

19. MIPS Final Score Changes
2018 MIPS performance year final score:
Performance category weight:
Quality 50%
Cost 10%
Improvement Activities 15%
Advancing Care Information 25%.

20. Performance Period For 2017: Minimum 90-day performance period for:
Quality
Advancing Care Information
Improvement Activities.
Exception: measures through CMS Web Interface, CAHPS, and the readmission measure are for 12 months.
Cost will be measured for 12 months.

21. Performance Period For 2018 No change for:
Advancing Care Information
Improvement Activities
Cost performance periods.
Minimum 12 month performance period for Quality.
No change to the exception

22. Meaningful Use with ifa
According to the ONC Health IT dashboard in % of ifa users were able to attest successfully.
This was the breakdown in 2016:
Data source:
program year
% of users 8% 3
20% 4
11% 5
55% 6 7%
Here at ifa, Meaningful Use has always been a priority. We have committed to making sure all of our users have the resources to be successful in all 3 stages of meaningful use.
the % i sent are for ifa users only
the idea is to show that our users have been attesting successfully for a number of years

23. Quality Measures with ifa
Ifa customers have been working with specialized registries since 2014
ifa has developed a unique connectivity process with the IRIS registry that enhances data collection while protecting your patients’ information and maintaining the control of the access to your patient data in your hands.
This module is called CREM- Clinical Registry Export Module
Along with meaningful use ifa has been dedicated to making sure our customers have the tools to properly and effectly report Quality measures for PQRS. With ifa’s structured data users have found it very easy to report quality measures with speed and efficiency.

24. The Final Rule with ifa
Ifa has always been in the forefront of the Health IT marketplace.
We will be one of the only ophthalmic EHR’s to obtain a certification this year, which qualifies our users to exclusive bonuses in 2018.
The final rule clearly states that the ONC believes it is critical for technology vendors to focus on interoperability and continue to press forward towards the future with the 2015 certification.

25. Consulting and Support
Ifa continuously offers on going training and webinars to ensure our users are on top of the latest CMS updates and requirements.
Ifa offers dedicated consultants that are available to support users through the reporting period and attestation process.
These ifa consultants are trained not only in the functionalities of the software but also the requirements of CMS and the ONC.

26. QPP Year 1 vs Year 2 Topic Year 1 Year 2 MIPS Policy
Low-volume threshold
You’re excluded if you or your group has
≤$30,000 in Part B allowed charges OR
≤100 Part B beneficiaries.
≤$90,000 in Part B allowed charges OR
≤200 Part B beneficiaries.
Non-patient facing
Individual - If you have ≤100 patient facing encounters.
Groups - If your group has > 75% NPIs billing under your group’s TIN during a performance period considered as non-patient facing.

27. Topic Year 1 Year 2 MIPS Policy Ways to submit
You use only 1 submission mechanism per performance category.
No change for Year 2.
For Year 3, no change for Year 2. Delayed until 2019 MIPS performance period.
For Year 3, you’ll be able to use multiple submission mechanisms.
Virtual Groups
Not an option for the transition year.
Added Virtual Groups as a way to participate for Year 2.
Virtual Groups 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 of a year.
Solo practitioners and small groups may only participate in a Virtual Group if you exceed the low-volume threshold.

28. Policy
Year 1
Year 2
MIPS Policy
Quality
Weight to final score:
• 60% in 2019 payment year.
• 50% in 2020 payment year.
• 30% in 2021 payment year and beyond.
Finalized at 50% in 2020 payment year.
30% in 2021 payment year and beyond.
Data completeness:
50% for submission mechanisms except for Web Interface and CAHPS.
Measures that don’t meet the data completeness criteria earn 3 points.
60% for submission mechanisms except for Web Interface and CAHPS.
Measures that don’t meet the data completeness criteria will earn 1 point, except for a measure submitted by a small practice, which will earn 3 points.

29. Quality cont.
Scoring:
3-point floor for measures scored against a benchmark.
3 points for measures that don’t have a benchmark or don’t meet case minimum requirements.
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 change for year 2.

30. Policy
Year 1
Year 2
MIPS Policy
Cost
Weight to final score:
0% in 2019 payment year.
Finalized at 10% in 2020 payment year.
30% in 2021 MIPS payment year and beyond.
Reporting/Scoring:
We’ll calculate individual MIPS eligible clinician’s and group’s Cost performance using administrative claims data if they meet the case minimum of attributed patients for a measure and if a benchmark has been calculated for a measure.
No change.

31. Policy
Year 1
Year 2
Improvement Activities
Weight to final score:
15% and we measure it based on a selection of different medium and high-weighted activities.
No change for the 2020 payment year.
Number of activities:
We included 92 activities in the Inventory.
Finalized more activities and changes to existing activities; for a total of approximately 112 activities in the inventory.

32. Policy
MIPS Policy
Advancing Care Information
Weight to final score:
25%, made up of a base score, performance score, and bonus points for data submission on certain measures and activities
No change for the 2020 payment year.
CEHRT requirements:
Can use either 2014 or 2015 Edition CEHRT for the 2017 transition year.
No change for 2018.
A 10% bonus is available if you only use the 2015 Edition CEHRT.

33. Policy
Year 1
Year 2
ACI Scoring
Scoring:
Award a base score of 50% if you submit the numerator (of at least “1”) and denominator, or “yes” for the yes/no measure, for each required measure.
If the base score isn’t met, you’ll get a 0 for the Advancing Care Information category.
Awarded performance score points if you submit additional measures (up to 10% each).
Give a bonus score (5%) for submitting to 1 or more additional public health agencies or clinical data registries.
Give bonus points (10%) when you use CEHRT to complete at least 1 of the specified Improvement Activities.
For the performance score, you or your group may earn 10% in the performance score for reporting to any single public health agency or clinical data registry.
A 5% bonus score is available for submitting to an additional public health agency or clinical data registry not reported under the performance score.
Additional Improvement Activities are eligible for a 10% Advancing Care Information bonus if you use CEHRT to complete at least 1 of the specified Improvement Activities.
A 10% bonus score for using 2015 Edition exclusively.

34. Conclusion
If you wish to receive additional information regarding the Quality Payment Program or MIPS, please feel free to contact us at
This concludes the content of todays webinar, and now we will begin the Question and Answer portion of the presentation. Please feel free to put any questions into the chat window at this time.