folder contents - kentucky rec · macra final rule, advanced apms include: advanced apm...
TRANSCRIPT
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Folder Contents
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Agenda 10:00AM – 10:20AM Registration
10:20AM – 10:30AM Welcome and Introduction
10:30AM – 11:15AM Highlights of the MACRA Rule
11:15AM – 12:00PM Tips and Tricks for MU and PQRS
12:00PM Lunch
12:15PM – 1:15PM Panel: Optimizing Your Practice for MU, PQRS, MACRA Success
1:15PM – 1:30PM Break
1:30PM – 2:00PM HIPAA Scan: Top Threats and Success Strategies for Practices
2:00PM – 2:30PM Getting Ready for Practice Transformation
2:30PM – 3:00PM Open Q & A/Closing Remarks
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Today’s Hashtag: #kytransform
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Carol Steltenkamp, MD, MBA
CMIO, UK HealthCare
Trudi Matthews, Managing Director, Kentucky REC
Highlights of MACRA Final Rule
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Moving to Value-Based Payment
Understanding the What & Why
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What is Value Based Payment?
Quality Cost
VA
LUE
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Volume to Value Based Shift Recent legislative, regulatory and marketplace developments suggest that the transition from volume to value-based payment is accelerating from a “testing” phase to a “scaling” phase
Affordable Care Act Enacted
March 2010
January 2012
Pioneer ACO Program
Launched
October 2012
Hospital Value Based Purchasing
Program
April 2013
Bundled Payments for Care Improvement
(BPCI)
CMS Announces Value-Based Payment Goals;
Value Modifier Program Begins
January 2015
Medicare Access and CHIP Reauthorization Act (MACRA) Enacted
April 2015
Testing Phase Scaling Phase
April 2016
MACRA NPRM, Medicaid Managed
Care Final Rule Released
July 2016
Cardiac & CJR Episode Payment NPRM
Released
MACRA Final Rule
Released
October 2016
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In January 2015, the Department of Health and Human Services announced
new goals for value-based payment and APMs in Medicare
2015: CMS Accelerates Shift to Value-Based Payment
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April 2016: Medicaid Managed Care Regulations
Among other provisions State Medicaid Agencies may require an MCO to:
• Implement value based purchasing models for provider reimbursement
• Participate in multi-payer delivery system reform or performance improvement
• Phase out of supplemental payments – with option to move payments into value-based payment models
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Commercial Insurers Accelerate VBP
“Our industry is in the midst of a profound shift from fee-for-service, or volume-based care, to value-based care. Aetna has successfully built more than 72 ACO relationships with providers, growing from very small numbers in 2011 to more than 2 billion dollars in revenue today. …We plan to maintain 75 percent of our medical spending in value-based contracts by 2020.”
- Charles Kennedy, MD, chief population officer for Healthagen, Aetna
Source: Health Care Learning & Action Network
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Highlights of the Medicare Access and CHIP Reauthorization Act (MACRA)
Final Rule
Released in October 2016
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APM MIPS
April 2016 MACRA Final Rule: New Medicare Part B Payment Program
Merit-based Incentive Payment System
Alternative Payment Models
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88% CMS estimate of
Medicare-eligible
clinicians under MIPS
track in 2019
Sources: The Advisory Board; CMS, “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,”
81 FR 28161, Federal Register, May 9, 2016,
For most health care organizations, the only real MACRA survival strategy:
SUCCEED IN MIPS
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MACRA Glossary of New Terms • New program name for MACRA’s change in Medicare
Part B payments Quality Payment Program (QPP)
• New pay for performance approach under Medicare Merit-Based Incentive Payment
System (MIPS)
• New payment models (e.g., ACOs) that move away from fee-for-service reimbursement
Alternative Payment Models (APMs)
• Overall clinician score from 0-100 calculated based on four weighted performance categories
Final Score
• Category that replaces PQRS; worth 60% of final score in Yr 1
Quality
• New name for resource use category; replaces value modifier program; not assessed in Yr 1 Cost
• Category that replaces the Medicare EHR Incentive Program for meaningful use; worth 25% in Yr 1
Advancing Care Information (ACI)
• New category; worth 15% of final score; includes activities aimed at improving care
Improvement Activities
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MACRA Eligible Clinicians (ECs)
• Physicians, PAs, NPs, CNS, CRNA
• After 2020, CMS may expand to other clinicians in Medicare FFS: PT, OT, NMW, CSW, Clinical Psychologists, Dieticians and Nutrition professionals
5 Types of Eligible Clinicians (ECs)
• Hospitals/Medicare Part A payments
• FQHCs/RHCs and Medicaid Providers
Not covered by MACRA:
• 1st year ECs
• “Non-patient facing” provider
• Low volume providers who do not bill at least $30,000 under the Medicare Physician Fee Schedule or care for more than 100 Medicare patients yearly
• Advanced APM Qualifying Provider not scored under MIPS
Exclusions:
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MACRA Timeline
October 14, 2016:
Release of Final Rule
Jan – Dec 2017:
1st Performance Period for MACRA
March 31, 2018: Reporting Deadline for First Year
Jan – Dec 2019:
1st Payment Year = +/- up to 4%
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Physician Compare
Coming Soon – Your MACRA performance score!
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2017 Transition Year: “Pick Your Pace” Options
Option 1:
Test Submission
Option 2:
Partial Submission
Option 3:
Full Submission
Option 4:
Advanced APM
QPP
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MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)
Physician Value-Based
Modifier
Physician Quality
Reporting System
EHR Incentive Program and
Meaningful Use
MIPS: A Consolidation of Programs
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Providers will receive a MIPS final score based on 4 weighted performance categories:
MIPS
Final
Score
0-100
Quality
Cost
Advancing
Care
Information
Improvement
activities
How will MIPS measure performance?
CY19 60% 0% 15% 25%
CY20 50% 10% 15% 25%
CY21 30% 30% 15% 25%
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Maximum MIPS Payment Adjustments
Source: Leavitt Partners - MACRA: Quality Incentives, Provider Considerations, and the Path Forward
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Quality
% Score: Measures:
Requirements
Methods:
Makes up 60% of your final score for PY 2017 Replaces PQRS;
# of measures from 9 down to 6 measures
200+ measures
to choose from
6 Measures Except: Groups using
CMS web interface report 15 quality measures
MIPS – APMS report via CMS web interface
1 measure must be: Outcome
measure OR High-priority
measure
Measures updated each year
Specialist sets available
QCDR EHR Qualified
Registry Web interface
(groups only) Claims
(individual only)
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Improvement Activities
% Score: Measures:
Requirements:
Method:
Makes up 15% of your final score for PY 2017 Full points for: Certified
PCMH/PCSP Medical Home
Model or Advanced APMs
MIPS - APMs get 50% of full pts
90+ Activities in 9 subcategories Access Population Management Beneficiary Engagement Care Coordination Patient Safety Equity
2- 4 Activities required: Highly weighted = 20 pts Medium weighted = 10 pts
Special consideration for small groups and ECs in rural and underserved areas
Simple attestation suffices for reporting Must be performed for a 90 consecutive day period
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Advancing Care Information
% Score: Measures:
Requirements:
Reporting:
Makes up 25% of your final score for PY 2017 Replaces Medicare MU Program New Data Blocking Requirements
Base Score: Submit 5
Required Objectives
Performance Score: Submit up to 9
measures for additional credit
Flexible Scoring: 1. Base 2. Performance 3. Bonus
Bonus Credit: Public
Health/Clinical Data Registry
Use of CEHRT for improvement activities
Individual or Group/TIN Level reporting available
2017 Options: 1. ACI
Objectives 2. 2017 ACI
Specific measures
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Cost
% Score: Measures:
Requirements:
Method:
Makes up 0% of your final score for PY 2017 2018 – category - 15% weight ECs will get feedback on this category in Quality and Resource Use Report (QRUR)
Score is based off of Medicare Part B claims, including: Measure 1: Spending per Beneficiary (MSPB) Measure 2: Total costs per capita for all attributed beneficiaries
New 10 episode-specific cost measures When clinician bills Medicare for diagnosis code gets included in episode Minimum # of patients sample. Typically 20 or > 35 for MSPB
No data submission required Validation of data is important!
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APM MIPS
April 2016 MACRA Final Rule: New Medicare Part B Payment Program
Merit-based Incentive Payment System
Alternative Payment Models
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What’s the big deal about APMs?
Stated intention of CMS that more and more of its $ will be spent in APMs over time
5% Annual Participation Bonus for Advanced APM participants from 2019-2025
Favorable scoring under MIPS for all APM participants
Annual update after 2025 is 0.75% for APM entities versus 0.25% for MIPS entities
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Next Generation ACO Model
Medicare Shared Savings Program – Tracks 2 & 3
Comprehensive Primary Care Plus (CPC+)
Comprehensive ESRD Care Model
Oncology Care Model Two-Sided Risk Arrangement (in 2018)
Cardiac & CJR Episode Model (in 2018)
In new
MACRA
Final
Rule,
Advanced
APMs
include:
Advanced APM participants are eligible for 5% bonus payment. But, only some APMs are risk-bearing Medicare payment models that qualify for this bonus payment.
30
• MACRA does not change how any particular APM rewards value. • APM participants who are not “Qualifying Providers” (QPs) will receive favorable
scoring under MIPS.
Advanced Alternative Payment Models
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All APM
Participants
QPs in
Advanced
APMs
Only providers in Advanced APMs will be deemed qualifying APM participants (“QPs”): 1. Report APM quality measures 2. Use of Certified EHR 3. Meet Advanced APM criteria (risk-bearing
or medical home model) 4. Must meet APM thresholds for payment and
patient volumes
Most physicians and practitioners who participate in APMs will be subject to MIPS and will receive favorable scoring under the MIPS clinical practice improvement activities performance category.
Not Every APM Will Qualify for 5% APM Bonus
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Impact of MACRA on Medicare Providers
Financial & Strategy Implications
• MACRA moves Medicare payment from one size fits all to a meritocracy
• Market share will shift from low performers to high performers over time
• Delay means disaster; exponential leaps in value will be needed to catch up with those that perform better as thresholds increase over time
Reputational Status
Publicly available scores on quality and value that compare organizations/professionals will affect:
• Health plan negotiations
• Talent recruitment
• Consumer choice
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How can clinicians and staff prepare?
"People's lives can be absolutely transformed by being nudged along a slightly altered route.“
- Dr. Ben Fletcher
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Sample QRUR
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Immediate Actions to Consider
• Engage leadership & key clinicians
• Medical home recognition a critical first step
• Dominate your quality data
• Analyze QRUR and other payer feedback
• Review compensation models
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Some clinicians think MACRA means…
• Stop seeing sick, non-compliant patients
• Start accepting only patients who are healthy
• But successful VBP/APM leaders understand
the 5-50 Rule.
5% of patients are responsible for 50% of costs.
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Focus on Common Elements on the Payment Innovation Journey
Culture of Continuous Quality Improvement & Team Based Care
Patient Attribution & Empanelment
Performance Measurement, Data Analysis and Identification of Gaps in Care
Identification of Higher Risk, High Cost Patients & Targeted Care Management
Care Coordination across the Medical Neighborhood
Patient Engagement & Experience of Care
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Kentucky REC & the Great Lakes PTN
• Great Lakes PTN is one of 29 Practice
Transformation Networks (PTNs) • GLPTN works with 10 Support and Alignment
Networks (SANs) GLPTN State Level Leadership: • Indiana University (primary grant recipient) • University of Kentucky (Kentucky) • Purdue Healthcare Advisors (Indiana) • Northwestern University (Illinois) • Altarum Institute (Michigan)
CMS established the Transforming Clinical Practices Initiative (TCPI) to help clinicians achieve large-scale health transformations through collaborative and peer-based learning networks
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Thank you!
Questions?
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Getting Ready for 2016 Reporting:
Tips and Tricks for PQRS
Healthcare Transformation
Regional Roadshows
Date here
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Tip 1: List of Eligible Providers (EPs)
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Tip 2: Reporting Methods
Individual Reporting Methods:
Claims
Qualified PQRS Registry
EHR Direct using certified EHR Technology (CEHRT)*
CEHRT via Data Submission Vendor (DSV)
Qualified Clinical Data Registry (QCDR)
Group Reporting Methods:
Qualified PQRS Registry
Web Interface (for groups of 25 or more)
EHR Direct using certified EHR Technology (CEHRT)*
CEHRT via Data Submission Vendor (DSV)
CAHPS for PQRS via CMS-certified survey vendor (for group practices of 2+)
* Requires obtaining a CMS Enterprise Identity Management (EIDM) account formerly known as the IACS account
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Tip 3: Reporting Criteria
Required to submit 9 measures over 3 domains and one cross
cutting measure
Cross-cutting measures are defined as measures that are broadly
applicable
There are 6 National Quality Strategy Domains
Satisfactorily reporting measures requires that the measure
performance percentage must be greater than 0%
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Tip 4: Reporting Timeframe
Claims – report through out the program year, note cannot re-submit claim just
to add PQRS modifiers
Qualified PQRS Registry – selected registry will have from Jan.1,2017
through Mar. 31, 2017 to submit on behalf of the EP
EHR Direct using certified EHR Technology (CEHRT) – EPs will be able to
submit appropriate data files through the CMS portal from Jan.1, 2017 through
Feb. 28, 2017
CEHRT via Data Submission Vendor (DSV) – Vendor can start submitting
data on behalf of EPs from Jan. 1, 2017 through Feb. 28, 2017
Qualified Clinical Data Registry (QCDR) – selected QCDR will have from
Jan.1,2017 through Mar. 31, 2017 to submit on behalf of the EP
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Trick 1: PQRS Measure Selection
Considerations
Step 1: Review reporting year Measures list on PQRS website
Step 2: Consider Important Factors
Clinical conditions usually treated
Types of care typically provided – e.g., preventive, chronic, acute.
Other quality reporting programs in use or being considered – e.g.
Value-Based Modifier Program, upcoming Quality Payment Program
Step 3: Review Measure Specifications
After making a selection of potential measures, review the
specifications for the selected reporting mechanism for each measure
under consideration.
Select those measures that apply to services most frequently provided
to Medicare patients by the EP or PQRS group practice.
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Trick 2: Leverage all Available Information
Download PQRS feedback reports from previous years to see
past performance to identify improvement trends
Obtain annual Quality Resource User Reports (QRURs) to
review quality previous quality scores *
* Requires obtaining a CMS Enterprise Identity Management (EIDM)
account formerly known as the IACS account
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Trick 3: Obtain EIDM Account Early
Registration for an account is online using the CMS portal
Individual requesting access will be required to enter their
Social Security Number and Date of Birth for verification
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Trick 4: Importance of Focusing on
PQRS
2016 the last performance year for PQRS as you know it
Starting performance year 2017 PQRS measures will be
used to calculate 60% of the Merit-Incentive Payment
System (MIPS) performance score proposed under the
Medicare Access and CHIP Reauthorization Act (MACRA)
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QUESTIONS?
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Lynn Grigsby Tiller, MBA, MSIS
Project Manager, Kentucky REC
Tips & Tricks for MU
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Meaningful Use Tips & Tricks 2016
Meaningful Use is Still Here
Meaningful Use Measure Summary
CQMS Requirements for 2016
Incentives and Payment Adjustments
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Meaningful Use is Still Here
Meaningful Use – Medicare versus Medicaid
• Continue to attest – 2016 LAST year for the Medicare EHR Incentive Program
• MACRA Implements, Sunsets and Incorporates Medicare MU Program for EPs
• No changes yet to Medicaid MU requirements for both EPS and EHs • Continue on 2016 path monitoring regulations • Since Medicaid MU program continues to 2021, dual
reporting will be required under current regulations
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Breaking News: OPP Final Rule
• Aligns MU & Advancing Care information objectives Aligns
• 2016 reporting period: 90 days
• 2017 reporting period: 90 days
Reporting Period
• Removes CPOE
• Removes CDS Rules
Objective Changes
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Important Deadlines for 2016
*Medicare – February 28, 2017 *Medicaid – March 31, 2017
• 60 days from start of reporting period • Last reporting period will be Oct 3 – Dec 31 • PH addendums must be signed by Dec 1 • Electronic Lab Reporting – If missed Oct 1 deadline – contact KHIE
Last Y ear to Enroll in Medicaid EHR Incentive Program
Attestation Deadlines
Public Health
Clinical Quality Measures – Reporting Mechanism
• 2016 is last year for EPs to enroll in the Medicaid EHR Incentive Program • Feb 28, 2017 – Last day to register for 2016 Medicaid EHR Incentive Program
• Dual eligible providers in danger of PQRS – VM Penalty – determine reporting mechanism ASAP
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Objective Measure
Protect Patient Health Information • Security Risk Analysis*
Clinical Decision Support • 5 CDS Rules tied to 4 CQMS
Computerized order entry • >60 % Medication Orders • >30 % Lab Orders • >30 % Radiology Orders
Electronic Prescribing • >60% ePrescribing*
Health Information Exchange • >10 % Exchange information with other physicians*
Patient Education • >10 % Patient-Specific Education**
Medication Reconciliation • >50% Patient Transitioned into EPs care has medication reconciliation performed
Patient Electronic Access • >50% Patient Access* • 2016: 1 patient 2017: >5% View, Download and Transmit
(VDT)**
Secure Electronic Messaging • 2016: 1 patient 2017: >5 % Secure Messaging**
Public Health Reporting • Immunization registry reporting** (& Bonus) • Syndromic surveillance reporting (Bonus) • Specialized registry
Stage 2 Objectives 2016 - 2017
*ACI Base Score ** ACI Performance Score
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• All participants in Medicaid MU will attest to Stage 3 beginning in 2018
Exception: Medicaid providers in their first year of demonstrating meaningful use report on 90 days
• All providers must use EHR technology certified to 2015 Edition for a full calendar year for 2018 EHR reporting period
• Providers choosing option to attest to Stage 3 in 2017 MUST have 2015 CEHRT
Stage 3 Objectives
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2016 CQM Reporting Options:
• Submit though Medicare attestation
• Submit through PQRS Portal Medicare
• Submit individual through PQRS Portal
• Submit group through PQRS Portal
• Report group through ACO
Quality Programs
• Submit through Medicaid attestation Medicaid
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CQM Requirements for 2016 Dual EH & CAHs
• Option 1: Attest to 16 of 29 possible CQMs through the EHR
Registration & Attestation System
• Option 2: eReport 4 CQMs through Hospital Inpatient Quality Reporting (IQR) through QualityNet Secure Portal
• Note: The CQM reporting options for EPs and hospitals in 2016 are the same as the options that were available in 2015. Medicaid-only hospitals report their CQMs via their state's portal.
• For more information on the 2016 program requirements and clinical quality measures, visit the 2015 CQM Reporting Options page on the CMS EHR Incentive Programs website.
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Medicare EHR Incentives
Payment Amount
First Payment 2011
First Payment 2012
First Payment 2013
First Payment 2014
2011 $18,000
2012 $12,000 $18,000
2013 $7,840 Reduction ($160)
$11,760 Reduction ($240)
$14,700 Reduction ($300)
2014 $3,920 Reduction ($80)
$7,840 Reduction ($160)
$11,760 Reduction ($240)
$11,760 Reduction ($240)
2015 $1,960 Reduction ($40)
$3,920 Reduction ($80)
$7,840 Reduction ($160)
$7,840 Reduction ($160)
2016 $1,960 Reduction ($40)
$3,920 Reduction ($80)
$3,920 Reduction ($80)
Total Incentive Payments
$43,720 $43,720 $38,220 $23,520
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Medicaid EHR Incentives
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2018 Payment Adjustments Based on 2016 Eps Participation
Medicare EHR Incentive Program
–3% penalty based on participation in 2016
PQRS
–2% penalty based on participation in 2016
Value Based Payment Modifier (VM)
Mandatory quality-tiering for PQRS reporters
• Groups 2-9 EPs and solo physicians will see +/-2% adjustment based on quality-tiering
• Groups with 10+ EPs will see +/-4% adjustment
• Non-PQRS reporters will see automatic 2% penalty unless in group of 10+ and they will see 4% penalty
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2018 Payment Adjustments Based on 2016 participation – EH/CAH
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2016 – Prepare for MIPS
• Attest to Meaningful Use (MU)
• Submit Physician Quality Reporting System (PQRS)
• Review and Understand your Quality Resource and Use Reports (QRURs)
• Understand Implications of non-participation in CMS’ Quality Programs on your PRACTICE REVENUE
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Thank you!
Questions?
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Kentucky Medicaid EHR Incentive Program
You can find more information about the Kentucky Medicaid EHR
Incentive Program at http://chfs.ky.gov/dms/ehr.htm
For all other EHR questions, please send a note to the
CHFS DMS EHR Incentive Program Mailbox
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EHR Information Center Help Desk
• (888) 734-6433 / TTY (888) 734-6563
• Hours:Monday-Friday 8:30 a.m.–4:30 p.m. in all time zones (Except Federal
holidays)
NPPES Help Desk
• Visit https://nppes.cms.hhs.gov/NPPES/Welcome.do
• (800) 465-3203 - TTY (800) 692-2326
PECOS Help Desk
• Visit https://pecos.cms.hhs.gov/
• (866)484-8049 / TTY (866)523-4759
Identification & Access Management System (I&A) Help Desk
• PECOS External User Services (EUS) Help Desk Phone: 1-866-484-8049
• TTY 1-866-523-4759
• E-mail: [email protected]
Additional information available on new 2015 Program Requirements page:
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/indextml
CMS Help Desks
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Follow us on Twitter: @KentuckyREC
Like us on Facebook: facebook.com/EHRResource
Follow us on LinkedIn: linkedin.com/company/kentucky-rec
Check out our website: www.kentuckyrec.com
Contact us by Phone: 859-323-3090
Connect with Kentucky REC!
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LUNCH & PANEL DISCUSSION
Optimizing Your Practice for MU, PQRS, and MACRA Success
Facilitator: Polly Mullins-Bentley Panelists: Lynn Grigsby-Tiller: Kentucky REC Margie Banse: QSource Carla Cooper: Kentucky DMS Jennifer NeSmith: Kentucky Health Center Control Network
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Brent McKune, CHPS, CPHIMS
Project Manager, Kentucky REC
HIPAA Scan
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Agenda
• Why a Security Risk Analysis should be conducted and/or reviewed on an annual basis
• Review the National Institute of Standards and Technology (NIST) and OCR’s recommended steps to conducting a thorough Security Risk Analysis
• Best practices and tactics to reduce breaches in your organization
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Definitions • Business Associates (BA) - A person or entity, other than a member of the workforce of a
covered entity, who performs functions or activities on behalf of, or provides certain services to, a covered entity that involve access by the business associate to protected health information.
• Business Associates Agreement (BAA) - A covered entity’s contract or other written arrangement with its business associate must contain that describes the permitted and required uses of protected health information by the business associate.
• Code of Federal Regulations (CFR) - The codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the federal government of the United States.
• Covered Entity (CE) - Defined in the HIPAA rules as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with transactions for which HHS has adopted standards.
• Electronic- Protected Health Information (e-PHI) - Any protected health information (PHI) that is covered under Health Insurance Portability and Accountability Act of 1996 (HIPAA) security regulations and is produced, saved, transferred or received in an electronic form.
• Health Insurance Portability and Accountability Act (HIPAA) - is the federal Health Insurance Portability and Accountability Act of 1996. The primary goal of the law is to make it easier for people to keep health insurance, protect the confidentiality and security of healthcare information and help the healthcare industry control administrative costs.
• National Institute of Standards and Technology (NIST) - a federal technology agency that works with industry to develop and apply technology, measurements, and standards
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Definitions • Security Rule - The HIPAA Security Rule establishes national standards to protect
individuals’ electronic personal health information that is created, received, used, or maintained by a covered entity. The Security Rule requires appropriate administrative, physical and technical safeguards to ensure the confidentiality, integrity, and security of electronic protected health information.
• Security Risk Analysis (SRA) – the process of identifying the risks to system security and determining the likelihood of occurrence, the resulting impact, and the additional safeguards that mitigate this impact.
• Privacy Rule - The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients’ rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.
• Protected Health Information (PHI) - Any information about health status, provision of health care, or payment for health care that can be linked to a
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Evolution of HIPAA
1996 HIPAA was enacted
2005 Security Rule
2013 Omnibus
2009 HITECH
2003 Privacy Rule
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Security Risk Analysis Overview
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Reasons to Complete a Security Risk Analysis
HIPAA Security
Rule
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Performing a Security Risk Analysis
How often should I conduct a security risk analysis?
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Security Risk Analysis Beneficiaries
Patients
Business Associates
Covered Entities
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Security Risk Analysis Steps
The National Institute of Standards and Technology (NIST) recommends a 9 step
methodology approach to conducting a security risk assessment
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Risk Analysis Steps
Step 9: Results Documentation
Step 8: Control Recommendations
Step 7: Risk Determination
Step 6: Impact Analysis
Step 5: Likelihood Determination
Step 4: Control Analysis
Step 3: Vulnerability Identification
Step 2: Threat Identification
Step 1: System Characterization
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What does compliance look like?
Is compliance one size fits all?
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Approaches for Conducting a Security Risk Analysis
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Mitigating Risks
Should I mitigate all risks?
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OCR Settlement Highlights
• Cancer Care Group ($750,000 settlement, August 31, 2015) – OCR found widespread non-compliance, and lack of policies, after
laptop bag with unencrypted media exposed records of 55,000 patients
• Feinstein Institute for Medical Research (research institute organized as NY non-profit corporation ($3.9M settlement and substantial corrective action plan, March 17, 2016) – Laptop computer with ePHI of approx.13K patients stolen from
employee’s car
• Raleigh Orthopedic – ($750,000 settlement, April 14, 2016) – For providing PHI for 17,300 patients to potential business partner
without first executing a BAA
• St. Joseph Health – ($2,140,500 settlement, October 17, 2016) – Unrestricted access to PDF files containing ePHI of 31,800 individuals
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Audits and Preparation
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Kentucky REC Can Help!
• Kentucky REC offers the following services performed by AHIMA Certified HIPAA Privacy & Security professionals:
– Security Risk Analysis addressing HITECH requirements for Meaningful Use
– Review of Administrative, Technical & Physical safeguards
– Remediation plan and timeline to eliminate or mitigate identified gaps
– HIPAA compliant sample policies
– Breach Notification
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Thank you!
Questions?
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Robin Huffman
Kentucky Regional Extension Center
Getting Ready for Practice
Transformation
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Providers will receive a MIPS final score based on 4 weighted performance categories:
MIPS
Final
Score
0-100
Quality
Cost
Advancing
Care
Information
Improvement
activities
How will MIPS measure performance?
CY19 60% 0% 15% 25%
CY20 50% 10% 15% 25%
CY21 30% 30% 15% 25%
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Improvement Activities
Expanded Practice Access
Population Management
Care Coordination
Beneficiary Engagement
Patient Safety and Practice Assessment
Participation in an APM, including a medical home model
Achieving Health Equity
Emergency Preparedness and Response
Integrated Behavioral and Mental Health
PCMH/PCSP Certification = Full Points for Category
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“The Gold Standard” for Primary Care Transformation
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A journey of a thousand miles begins with a single step…
Meaningful Use
Care Delivery Innovation (PCMH)
Payment Innovation
Health IT & HIE + Quality Improvement
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PCMH is a model that provides specific standards for transforming the organization and delivery of primary care to be more:
Comprehensive Patient-Centered Coordinated Accessible Safe
PCMH: A Roadmap
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Patient-Centered Medical Neighborhood
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Patient-Centered Specialty Practice • An innovative program for improving specialty
care.
• Organizes care around patients
• Promotes team based care
• Coordinating and tracking care over time with primary care and other specialists
• Improve quality
• Reduce redundancies and negative patient experiences
• Proactive coordination
• Patient centered
• Encourages the use of health information technology
• Meaningful Use Alignment
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Benefits of a PCMH
• Long-term partnerships, not hurried visits
• Care that is coordinated among providers
• Better access
• Shared decision-making with patients
• Reduced cost of care
• Decreased ER visits, hospitalizations
• More satisfied providers and patients
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Benefits of PCSP
• Effective care coordination • Greater efficiency • Improved patient safety
• Readiness for a delivery/reimbursement model that
focuses on outcomes and reduced duplication of services. • Promoting a practice’s suitability for newly proposed
physician delivery and payment models.
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PCMH Recognition
For outpatient primary care
Practice-site level
Recognizes PCPs at the site, including NPs and PAs who can be designated as a personal clinician
3-year Recognition period
Practice may add/remove clinicians
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Who is eligible for PCMH Recognition?
• Recognized Practices: • Internal Medicine • Family Medicine • Pediatrics
• Recognized Providers: • Physicians (MD or DO) • APRNs • PAs
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PCSP Recognition
Practice-based evaluation for clinicians who provide care in non-primary care specialties
Recognizes eligible specialty clinicians at the practice
NCQA defines a practice as one or more clinicians who practice together and provide patient care at a single geographic location.
3-year Recognition period
Practice may add/remove clinicians
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Who is eligible for PCSP Recognition?
• Recognized Practices: • Non-primary care specialties
• Recognized Providers: • Physicians (MD or DO) • APRNs • PAs • Certified Midwives • Behavioral Health Practitioners
• Doctoral or Master’s-level (state certified or licensed): • Psychologists • Social workers • Marriage and family counselors
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Who is not eligible for PCSP?
• Chiropractors, Optometrists, Podiatrists are not eligible for the PCSP program.
• Primary care clinicians who are eligible for NCQA PCMH Recognition are not eligible for NCQA PCSP Recognition.
• All clinicians who do not share or have their own panel of patients.
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NCQA PCMH 2014 Standards
Standard 1. Enhance Access and Continuity
Standard 2. Team-Based Care
Standard 3. Population Management
Standard 4. Plan and Manage Care
Standard 5. Track and Coordinate Care
Standard 6. Measure and Improve Performance
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NCQA PCSP 2016 Standards
Standard 1: Working with Primary Care and Other Referring Clinicians
Standard 2: Provide Access and Communication
Standard 3: Identify and Coordinate Patient Populations
Standard 4: Plan and Manage Care
Standard 5: Track and Coordinate Care
Standard 6: Measure and Improve Performance
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Scoring Components
PCMH 2014 Recognition 6 Standards 27 Elements 178 Factors*
*Factors are the scored items within an element.
• 6 Must-Pass Elements – Most important aspects of PCMH
• Critical Factors
– Required to receive at least some (if any) points
PCSP 2016 Recognition 6 Standards 26 Elements 164 Factors*
*Factors are the scored items within an element. • 6 Must-Pass Elements
– Most important aspects of PCSP
• Critical Factors – Required to receive at least some (if
any) points
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Levels of Recognition
• 3 levels of NCQA PCMH Recognition • Each level reflects the degree to which a practice meets the requirements • Allows practices with a range of capabilities to meet the requirements
successfully
PCMH Recognition PCSP Recognition
Recognition Levels Required Points
Level 3 85 – 100 points
Level 2 60 – 84 points
Level 1 35 – 59 points
Recognition Levels Required Points
Level 3 75 – 100 points
Level 2 50 – 74 points
Level 1 25 – 49 points
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A look at the numbers…
PCMH Recognition
In Kentucky:
• 880 Clinicians/Sites
In the US:
• 67,652 Clinicians/Sites
PCSP Recognition
In Kentucky:
• 10 Clinicians/Sites – 2 Sites
– 8 Clinicians
In the US:
• 1,467 Clinicians/Sites
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Why Become a PCMH or PCSP? What’s in it for the practice?
Big Picture Payment Reform
Incentives Competition
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Why Become a PCMH or PCSP? What’s in it for the provider?
Maximizing the Use of My Skills
Experiencing Satisfaction
from Positive Patient
Interaction
Enjoying Greater
Efficiency in My Job
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Why Now?
In order to earn full credit for IA you will need to have recognition for 3 months in 2017.
You should submit for recognition by July 31st, 2017 to meet this requirement.
IA Credit The PCMH 2014
Standards are expiring!
PCMH 2017 comes out March 2017. NCQA is expected to once again raise the bar for recognition.
PCMH 2014
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Strategies for Success
Set Direction
Mission
Vision
Strategy
Develop a Realistic Plan
Form a Team
Physician Lead
Practice Manager
Administrative Lead
Clinical Lead (i.e. LPN, MA, care coordinator, etc.)
Develop a Communication Plan
Staff
Providers
Patients
Devote Resources
Protected Time
Financial Resources
Data
Technology
Staffing
Engage Physicians
Create Segmented Plans
Be wise in their involvement
Respect their time
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Important Dates
3/31/17
• Last day to purchase PCMH 2014 survey licenses • Redesigned process and 2017 standards become available
5/31/17 • Last day to submit PCMH 2014 Corporate Survey
6/30/17 • Last day to request PCMH 2014 Add-On Surveys
7/31/17 • Last day to submit PCMH 2014 Corporate Add-On Tools
9/30/17 • Last day to submit all PCMH 2014 Site Surveys
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Thank you!
Questions?
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