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QUALITY PAYMENT PROGRAM
SMALL UNDERSERVED RURAL SUPPORT (QPP SURS) WEBINAR
DECEMBER 10, 11:00 AM ET AND DECEMBER 12, 3:30 PM ET
IMPLICATIONS OF THE YEAR 4
FINAL RULE FOR SOLO AND
SMALL GROUP PRACTICES
IMPLICATIONS OF THE YEAR 4 FINAL RULE
HOUSEKEEPING ANNOUNCEMENTS
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If you are listening to this webinar through your phone,
please remember to mute your computer speakers.
You can download the slides from the file pod on your
screen.
For assistance, enter your issue in the chat box.
To ask a question, enter your inquiry in the chat box.
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
POLLING QUESTION
What is your role?
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A clinician working in a practice with 15 or fewer clinicians
Non clinical staff from a practice with 15 or fewer clinicians
A clinician working in a practice with more than 15 clinicians
Non clinical staff in a practice with more than 15 clinicians
Quality Payment Program (QPP) contractor
Other person helping practices prepare for MIPS
Other
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
POLLING QUESTION
How are you planning to submit your 2019 MIPS data?
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I am submitting as an individual
I am submitting as a group
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
POLLING QUESTION
What topics related to the 2020 final rule are you
most interested in learning more about?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
CMS WELCOME
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Kathleen Johnson RN, BS
Health Insurance Specialist
Centers for Medicare and Medicaid
Services (CMS)
Quality Improvement and Innovation Group
(QIIG)
Division of ESRD, Population and
Community Health (DEPCH)
IMPLICATIONS OF THE YEAR 4 FINAL RULE 7
Bruce Spurlock, MDPresident & CEO,Cynosure Health
Marvin Nichols Jr., MHA. PCMH CCE, Practice
Transformation Specialist, Quality Insights
London Manor-Petersen, BS, Improvement Advisor/QPP
Comagine Health
Christine Lalios Kuykendall, BS RHIA CPHQ IM, Health
Informatics Specialist, HSAG
IMPLICATIONS OF THE YEAR 4 FINAL RULE
SETTING THE STAGE▸
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Focus: Understanding the changes in the Final Rule that have implications
for solo and small group practices.
Strategy: A panel of experts familiar with the Final Rule will offer advice
and answer questions on the Year 4 changes that will affect small
practices.
Not an exhaustive summary of the entire 2020 Final Rule
Topic Overview:
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What has not changed
Summary of most important changes in the 2020 Rule for solo and small
group practices
Advice to Succeed in 2020
▸ Using the Chat Box
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
FIND YOUR LOCAL TECHNICAL ASSISTANCE ORGANIZATION FOR FREE ASSISTANCE
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Location of Practice Technical Assistance Organization
Contact Information
FL, GA, NC, SC Alliant GMCF [email protected]
IL, IN, KY, MI, MN, OH, WI Altarum [email protected]
ID, WA Comagine Health [email protected]
CT, MA, ME, NH, RI, VT Healthcentric Advisors [email protected]
AZ, CA, HI, NM, VI HSAG [email protected]
DC, MD, NY, VA IPRO [email protected]
AK, MT, NV, OR, UT, WY NRHI NV, OR, UT: [email protected], MT, WY: [email protected]
AL, TN QSource [email protected]
DE, NJ, PA, WV Quality Insights [email protected]
IA, ND, NE, SD Telligen [email protected]
AR, CO, KS, LA, MO, MS, OK, PR, TX
Find your local technical assistance contractor here: https://qpp.cms.gov/about/small-
underserved-rural-practices
PANELIST INTRODUCTIONS
▸ Introductions
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PANELIST INTRODUCTIONS
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Marvin Nichols Jr., MHA. PCMH CCE, Practice Transformation Specialist, Quality Insights
PANELIST INTRODUCTIONS
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Christine Lalios Kuykendall, BS RHIA CPHQ IM, Health Informatics Specialist, HSAG
PANELIST INTRODUCTIONS
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London Manor-Petersen, BS, Improvement Advisor/QPP Comagine
Health
QUESTION:
MIPS is heading into it’s 4th year. What is staying the
same even after the 2020 Final Rule?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
A LOT REMAINS THE SAME FOR NEXT YEAR
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Free and customized support for small and rural practices
Continued support and flexibility specifically for small practices
Eligible clinician types
▸Low-volume threshold
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
A LOT REMAINS THE SAME FOR NEXT YEAR
▸Determination Periods
▸Performance Periods for each performance
category
▸PI hardship exceptions
▸Performance Category weights
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QUESTION:
How have the Quality Measure reporting requirements
changed?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
QUALITY MEASURE BASICS▸
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Still 45% of your final MIPS score
Still a 12 month reporting period
Select 6 measures
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1 outcome OR
High Priority
Small practice bonus of 6 points, if you submit data on 1 quality
measure
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QUALITY MEASURE CHANGES
▸Addition of Specialty Sets:
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Speech Language Pathology
Audiology
Clinical Social Work
Chiropractic Medicine
Pulmonology
Nutrition/Dietician
Endocrinology
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▸Increase in Data Completeness
Requirements:
▸70% sample of Medicare Part B
patients for the performance
period
▸QCDR measures, MIPS CQMs,
and eCQMs: 70% sample of
clinician's or group's patients
across all payers for the
performance period
IMPLICATIONS OF THE YEAR 4 FINAL RULE
QUALITY MEASURE CHANGES▸Additional Measure Removal Criteria:
▸MIPS quality measures that do not meet case minimum and reporting
volumes required for benchmarking for 2 consecutive years may be
removed.
▸CMS will consider a MIPS quality measure for removal if it’s
determined not available for MIPS Quality reporting by or on behalf of
all MIPS eligible clinicians (including via third party intermediaries).
▸ Review list of MIPS measures finalized for removal in Table C of the PY 2020
Final Rule
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
QUALITY MEASURE CHANGES▸Alternative Benchmarks:
▸Establish flat percentage benchmarks in limited cases where CMS
determines that the measure’s otherwise applicable benchmark could
potentially incentivize treatment that could be inappropriate for
particular patients.
▸The modified benchmarks would be applied to all collection types
where the top decile for a historical benchmark is higher than 90% for
the following measures:
▸MIPS #1 ((NQF 0059): Diabetes: Hemoglobin A1c (HbA1c) Poor
Control (>9%)
▸MIPS #236 (NQF 0018): Controlling High Blood Pressure
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QUALITY MEASURE IMPLICATIONS
▸Review list of removed and topped out measures
▸Did you previously report on measures that are gone?
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Decide early which measures to report
Pay attention to data submission methods
More measure opportunities for specialties with new specialty sets
Pay attention to data completeness especially if you submit via
claims
▸Small practices will receive 3 points per measure if you fall below
70%
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QUESTION:
What requirements have changed in the cost
category?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
COST—BASICS ▸
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Still 15% of final MIPS score
No reporting requirements
No changes to case minimums
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35 for Medicare Spending Per Beneficiary (MSPB)
20 for Total Per Capita Cost (TPCC)
▸8 episode-based measures added last year remain the same
For more on calculating cost, review the 2019 MIPS Cost User Guide
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COST— NEW EPISODE-BASED MEASURES
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Acute Kidney Injury Requiring New Inpatient Dialysis
Elective Primary Hip Arthroplasty
Femoral or Inguinal Hernia Repair
Hemodialysis Access Creation
Inpatient Chronic Obstructive Pulmonary Disease (COPD) Exacerbation
Lower Gastrointestinal Hemorrhage (applies to groups only)
Lumbar Spine Fusion for Degenerative Disease, 1-3 Levels
Lumpectomy Partial Mastectomy, Simple Mastectomy
Non-Emergent Coronary Artery Bypass Graft (CABG)
Renal or Ureteral Stone Surgical Treatment
▸ For more information, please review Table 44 (p. 62963) in the Final Rule
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COST—REVISIONS TO CURRENT MEASURES AND ATTRIBUTION▸
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Medicare Spending Per Beneficiary (MSPB)
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Name change: Medicare Spending Per Beneficiary Clinician (MSPB- C)
MSPB Clinician attribution will have a different methodology for surgical and
medical episodes.
Total Per Capita Costs (TPCC)
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TPCC attribution will require a combination of evaluation and management (E&M)
services and general primary care service or a second E&M service, from the
same clinician group.
TPCC attribution will exclude certain clinicians who primarily deliver certain non-
primary care services (e.g., general surgery) or are in specialties that are unlikely
to be responsible for primary care services (e.g., dermatology).
Measure attribution will be different for individuals and groups and will
be defined in the applicable measure specifications
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COST—IMPLICATIONS
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Understand the new episode-based measures. Is your specialty
included?
Get familiar with attribution and what it means for your practice
Review last year’s cost—learn from last year
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QUESTION:
How have the requirements for the Improvement
Activities and Promoting Interoperability performance
categories changed?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
IMPROVEMENT ACTIVITIES– THE BASICS
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Still 15% of final MIPS score
Select and attest “yes”
Activity weights remain the same:
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Medium- 20 points for small practices
High- 40 points for small practices
IMPLICATIONS OF THE YEAR 4 FINAL RULE
IMPROVEMENT ACTIVITIES—WHAT’S NEW
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▸Updates to Improvement Activity Inventory:
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2 new IAs
Modified 7 existing
Removed 15 IAs
▸Definition Change for Rural Area: a ZIP code designated
as rural by the Federal Office of Rural Health Policy
(FORHP) using the most recent FORHP Eligible ZIP
Code file available.
IMPLICATIONS OF THE YEAR 4 FINAL RULE
IMPROVEMENT ACTIVITIES—CHANGES TO GROUPS
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▸Group or virtual group can attest to an improvement
activity when at least 50% of the clinicians perform the
same activity during any continuous 90-day period within
the same performance year.
IMPLICATIONS OF THE YEAR 4 FINAL RULE
PROMOTING INTEROPERABILITY—THE BASICS
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Still 25% of your Final MIPS score
Must use 2015 Certified EHR Technology
PI Hardship Exception has not changed
▸The Query of Prescription Drug Monitoring Program
(PDMP) measure is now an optional measure, and
available for bonus points
▸Verify Opioid Treatment Agreement measure was
removed
IMPLICATIONS OF THE YEAR 4 FINAL RULE
PROMOTING INTEROPERABILITY—OTHER CHANGES
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For the 2019 performance period:
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Query of PDMP measure will require a yes/no response
instead of a numerator/denominator.
CMS will redistribute the points for the Support Electronic
Referral Loops by Sending Health Information measure
to the Provide Patients Access to Their Health
Information measure if an exclusion is claimed.
For the 2020 performance period: Changes to Hospital-
Based MIPS Eligible Clinicians in Groups:
▸Hospital-based and eligible for reweighting when more
than 75% of the NPIs in the group meet the definition of a
hospital-based individual MIPS eligible clinician
IMPLICATIONS OF THE YEAR 4 FINAL RULE
IA AND PI IMPLICATIONS
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Talk to staff and other clinicians about IAs and
reporting on the same activities
Review new activities and decide early on which ones
to do (make sure your activities have not been
removed)
If you are considering a hardship exemption,
understand the quality implications
Consider the cost of an EHR
QUESTION:
I heard about MIPS Value Pathways (MVP). Is this
something I need to understand for next year?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
MIPS VALUE PATHWAYS
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▸CMS intends to:
▸Provide enhanced data and feedback to clinicians
▸Analyze existing Medicare information to provide
clinicians and patients with more information to
improve health outcomes
▸Reduce reporting burden by limiting the number of
required specialty or condition-specific measures
▸More information is available on the QPP website at:
https://qpp.cms.gov/mips/mips-value-pathways
IMPLICATIONS OF THE YEAR 4 FINAL RULE
MIPS VALUE PATHWAYS—WHAT YOU CAN DO NOW
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▸Take advantage of providing feedback to help with
clinician burden
▸Contact the person or committee at your specialty
society who creates a response.
▸Start to align your activities with what MVP is
proposing
MIPS MVP video
MIPS Value Pathway Diagrams
QUESTION:
What changes will affect scoring?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
2020 FINAL PERFORMANCE CATEGORY REWEIGHTING
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2020 FINAL PERFORMANCE THRESHOLD AND PAYMENT ADJUSTMENTS
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QUESTION:
What final advice can you give small practices to
succeed in 2020?
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IMPLICATIONS OF THE YEAR 4 FINAL RULE
TIPS FOR SUCCESS
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Understand key deadlines
Start early
Understand your options and what works best for your
practice
Using MVP as a guide for the future
Strive to complete more than 6 measures
If you have an EHR, monitor your measures
Review results from 2018, see where you can improve and
plan strategically
Include all staff in MIPS discussions
Take advantage of the free help!
QUESTION:
If I still need help, where can I go?
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FREE RESOURCES FOR ASSISTANCE FROM CMS
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QPP website: https://qpp.cms.gov/--includes information tailored for the needs of small
practices
Contact the Quality Payment Program at: [email protected] or call 1-866-288-8292
Support and Available resources for Small, Underserved, and Rural Practices:
https://qualitypaymentprogram.cms.gov/about/small-underserved-rural-practices
Small Underserved Rural Support Technical Assistance Organizations (see list on slide
9)
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Contact information is available at: https://qpp.cms.gov/about/small-underserved-
rural-practices
Available websites of each Technical Assistance Organization
Types of help: needs assessments, webinars, technical support, links to peers you
can talk with, assistance getting signed up to report through an approved channel
that meets your practice’s needs
▸ Resource Library
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FREE RESOURCES FOR ASSISTANCE FROM CMS
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QPP Participation Status Tool
2020 QPP Final Rule
2020 QPP Final Rule Overview Fact Sheet
2020 QPP Final Rule FAQs
MIPS Value Pathways Diagrams
MIPS Value Pathways
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WRAP-UP ACTIVITIES
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Links to Q&A documents, transcripts, and recordings of the event are
available here: www.qppsurs.com
January 2020 LAN Webinar: MIPS Question and Answer Town Hall Event
for Solo and Small Group Practices
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January 23, 2020, 3:30pm ET
January 28, 2020, 11:00am ET
▸ Please provide feedback on this event: Feedback Form
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REFERENCES
Slide decks created by event panelists also provided information reflected in this presentation. The input from project panelists is gratefully acknowledged.
Other documents on the https://qpp.cms.gov/ and https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html website provide additional detail about the MIPS program.
Disclaimer: This presentation was current at the time it was published or uploaded onto the web. Medicare policy changes periodically so links to the source documents have been provided within the document for your reference. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.
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APPENDIX: ACRONYMSAPM – Alternative Payment Model
ACO – Accountable Care Organization
CERT—Certified EHR Technology
FORHP— Federal Office of Rural
Health Policy
E&M—Evaluation and Management
Services
FFS- Fee for Service
MIPS – Merit-based Incentives
Payment System
MSPB—Medicare Spending Per
Beneficiary
MVP—MIPS Value Pathways
PDMP— Query of Prescription Drug
Monitoring Program
PCMH— Patient Centered Medical
Home
PCP— Primary Care Provider
PI— Promoting Interoperability
PFS-Physician Fee Schedule
IA – Improvement Activities
EHR – Electronic Health Records
TPCC—Total Per Capita Cost
QCDR—Qualified Clinical Data
Registry
QPP – Quality Payment Program
QRDA – Quality Reporting Data
Architecture
QRUR— Quality and Resource Use
Reports
SURS - Small Underserved Rural
Support
TIN—Tax Identification Number
QI-Quality Improvement
QP- Qualifying APM Participant
VBP- Value-Based Purchasing
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