meaningful use 2015-2018 and merit based incentive payment in 2019
TRANSCRIPT
Meaningful Use 2015-2018 and Merit Based Incentive Payment in 2019
The World Turned Upside Down
• Since January we have seen:
– A second round of changes to Meaningful Use Stage 2
– Proposed Required eReporting of Quality Measures by 2018
– Repeal of the Sustainable Growth Rate and the launch of a Merit Based Payment for Value Medicare system in 2019
– Presidential and Congressional elections could lead to more changes.
It is great to be here!
Barriers to eReporting
• Since publication of the Stage 2 MU NPRM, CMS has changed CQM reporting requirements 2 times.
• Every eCQM has undergone anywhere from 2 to 4 revisions to the specifications (100% had errors)
• eCQMs are difficult to collect within normal provider workflows and don’t always accurately reflect quality of care.
• Implementation and measure development timelines are too short.
• Sub-regulatory guidance is vague and often difficult to find.
Timeline and Basics
• 2015- Attestation for any 90 day period or eReporting 1 CY quarter of data
• 2016- Attestation for a full year or eReporting Q3 and Q4 of eCQM data (2 submissions)
• 2017- Attestation for a full year or eReporting Q1, Q2, Q3, and Q4 of eCQM data (4 submissions)
• 2018- Mandatory eReporting of Q1, Q2, Q3, and Q4 of eCQM data (4 submissions)
• 2019- MACRA starts
– MU
– eCQM Reporting
– Outcomes/Performance
– Efficiency
Meaningful Use Stage 2:
2015
EH CQM Attestation in 2015
• EHs and CAHs must report on 16 of the 29 eCQMs found in the MU eCQM measure set covering 3 of the 6 National Quality Domains
• 2015 Stage 2 Flexibility NPRM proposed that attestation shift from full year to:
– Attestation for any 90 day period or eReporting 1 CY quarter of data
– Must use 2014 CEHRT
– Must attest by February 29, 2016.
• Medicaid EHs and CAHs will reporting 16 of 29 eCQMs in the manner prescribed by the states.
2015 EH eCQM eReporting Option• Finalized in the IPPS FY15 Final Rule
• For this option, EHs must:
– Report 16 of the 29 eCQMs found on the MU/IQR eReporting Measure Set from 3 of the 6 National Quality Domains
– Use 2014 CEHRT featuring the latest CQM specification updates. If errors are found in the latest specification updates, EHs must revert to the previous published CQM specifications.
– Report CQM data on any of the first three quarters of calendar year 2015, with a submission deadline of November 30th, 2015.
• Quarter 1: January 1st -March 30th, 2015
• Quarter 2: April 1st June 30th, 2015
• Quarter 3: July 1st September 30th, 2015
– EHs must submit CQM data as patient level data using the QRDAI transmission standard found in 2014 CEHRT, as prescribed in the CMS IQR Program eReporting System.
– Submission deadline: November 30th, 2015
EP 2015 CQM Attestation
• Medicare Eligible Professionals (EPs) can meet the clinical quality measurement reporting requirement for Meaningful Use by either attesting or eReporting on 9 of the 64 eCQMs in the Stage 2 Final Rule menu.
• First year Meaningful Use EPs must attest. Returning EPs may attest or eReport their measures.
• For EPs that choose to attest in 2015, CMS is proposing to change the attestation period for eCQMs from a full calendar year to any continuous 90-day period within calendar year 2015
• Attestation must be submitted by February 29th, 2016
EP 2015 eReporting CQMs
• As highlighted in the CY15 PFS Final Rule, Second Year EPs may meet the eCQM component of Meaningful Use by:
– Electronically collecting data on 9 CQMs of the 64 available eCQMs found in the Meaningful Use Stage 2 Final Rule menu from a minimum of 3 of the 6 National Quality Domains.
– Using 2014 CEHRT and the latest Measure Specifications
• If errors are found in a specification, EPs must utilize the latest correct specification for the eCQM
– Individual EPs must submit patient level data using reporting standard QRDA I to the PQRS eReporting module. Group practices reporting as a group must use GPRO Web Interface.
– EPs successfully reporting and meeting all other Meaningful Use and PQRS requirements will meet the eCQM reporting requirement for both programs with one successful electronic submission.
• Submission deadline: February 29th, 2016
• For this option, participating EP’s eCQM data will be publically reported on PhysicianCompare.gov.
ProposedMeaningful Use
Stage 2: 2016
EH CQM Attestation in 2016
• EHs and CAHs must attest or on 16 of the 29 eCQMs found in the MU eCQM measure set covering 3 of the 6 National Quality Domains
• Attestation requires eCQM capture for the full calendar year 2016 (January 1-December 31, 2016.)
– Must use 2014 CEHRT or 2015 CEHRT
– Must attest by February 28, 2017.
• Medicaid EHs and CAHs will reporting 16 of 29 eCQMs in the manner prescribed by the states.
2016 EH eCQM eReporting Option• Successful eCQM submission meets requirements for both MU Stage 2
2016 and CY16/2018 Payment Determination for the CMS IQR program
– 6 eCQMs (ED-1, ED-2, STK-04, VTE-5, VTE-6, and PC-01) must be part of the 16 to receive credit for both programs.
• Per IPPS FY16 Proposed Rule, for this option, EHs must:
– Report 16 of the 29 eCQMs found on the MU/IQR eReporting Measure Set from 3 of the 6 National Quality Domains
– Use 2014 CEHRT featuring the latest CQM specification updates (May 2015 Annual Update.) If errors are found in the latest specification updates, EHs must revert to the previous published CQM specifications.
– Report CQM data on the last two quarters of CY2016.
• Quarter 3: July 1st September 30th, 2016
• Quarter 4: October 1st-December 31st, 2016
– EHs must submit CQM patient level data using QRDAI transmission standard found in 2014 CEHRT.
– Submission deadline: February 28th, 2017
2016 eReporting Option for EHs and Validation
• EHs would not fail validation based on these data for CY 2016/FY 2018 payment determination reporting because validation for eCQMs is currently under development.
• eCQMs reported via eCQM will be marked with a footnote on HospitalCompare.gov noting : (1) the hospital submitted data via EHR; (2) data are being processed and analyzed; and (3) CMS will eventually publicly report this data once CMS determines the data to be reliable and accurate.
EP 2016 CQM Attestation
• Medicare Eligible Professionals (EPs) can meet the clinical quality measurement reporting requirement for Meaningful Use by either attesting or eReporting on 9 of the 64 eCQMs in the Stage 2 Final Rule menu.
• For 2016, EPs participating in the MU program for the first time may attest and report CQM data for any consecutive 90 day period within the calendar year.
• For 2016, returning EPs choosing to attest may collect and report CQM data for the full calendar year.
• Attestation must be submitted by February 28th, 2017
EP 2016 eReporting CQMs
• EPs have the option of electronically collecting and reporting data on 9 CQMs of the 64 available eCQMs found in the Meaningful Use Stage 2 Final Rule menu from a minimum of 3 of the 6 National Quality Domains
• eReporting proposed requirements for 2016 will be published in the CY16 Physician Fee Schedule Proposed Rule, (expected to be published at the end of June/early July.)
• Submission deadline: February 28th, 2017
• For this option, participating EP’s eCQM data will be publically reported on PhysicianCompare.gov.
Proposed Meaningful Use Stage 3 CQMs:
2017-2018
EH eCQM Flexibility in 2017
For Medicare Meaningful Use Stage 3 EHs, and CAHs, there are two options for meeting eCQM reporting requirements in 2017
– Attestation (Four quarterly attestation periods for the Calendar Year)
– EHs, and CAHs have the option to report eCQMs electronically in 2017.
• To eReport, EPs, EHs, and CAHs must use the most recent available electronic measure specifications, which will be published by CMS in 2016.
*States will determine reporting requirements for Medicaid EHs, and CAHs.
EHs eCQM Reporting in 2018
• For 2018 and subsequent years, Medicare EHs must eReport eCQMs using QRDAI (Patient Level Data)
• Hardship Exemption
– a data submission system failure
– natural disaster,
– certification issue outside the control of the provider
• In 2018, states will determine if attestation or eReporting will be required for eCQMs for Medicaid EHs
• Capture Requirements and Reported Deadlines will be published in the FY18 IPPS Proposed Rule (Anticipated Publication April 2017)
• The IPPS rulemaking will include a common eCQM reporting set for both Medicare and Medicaid EHs.
• CMS will continue to post the defined CQM sets and the published electronic specifications on the eCQM Library page: http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/eCQM_Library.html
EPs eCQM Reporting Requirements
• CMS will publish eCQM reporting requirements for Meaningful Use in the Physician Fee Schedule rulemaking for 2017 and subsequent years.
• The Physician Fee Schedule (PFS) proposed rule is published annually in July 2016 (MU Stage 3, 2017) and July 2017 (MU Stage 3, 2018.
• Medicaid eCQM reporting requirements would continue to be determined by the states, subject to CMS approval.
• The PFS rulemaking will include a common eCQM reporting set for both Medicare and Medicaid EPs.
• CMS will continue to post the defined CQM sets and the published electronic specifications on the eCQM Library page: http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/eCQM_Library.html
EP eCQM Flexibility in 2017
For Medicare Meaningful Use Stage 3 EPs, there are two options for meeting eCQM reporting requirements in 2017
– Attestation (Full Year)
– EPs have the option to report eCQMs electronically in 2017.
• To eReport, EPs, EHs, and CAHs must use the most recent available electronic measure specifications, which will be published by CMS in in CY17 Proposed Rule (publication date July 2016.)
*States will determine reporting requirements for Medicaid EPs, EHs, and CAHs.
EPs eCQM Reporting in 2018
• For 2018 and subsequent years, Medicare EPs must eReport eCQMs using 2015 CEHRT and the specifications found in the 2017 Annual Update
• eReporting Hardshipso a data submission system failureo natural disaster,o certification issue outside the control of the provider
• In 2018, states will determine if attestation or eReporting will be required for eCQMs.
• Capture and Reported Deadlines will be published in the CY18 PFS Proposed Rule (Anticipated Publication July 2017)
TBD: Stage 3 eCQMs and Certification
• Option 1: vendors certify to all eCQMs that are in the EP selection list, or eligible hospital/CAH vendors certify to all eCQMs in the selection list for those stakeholders.
• Option 2: Phased approach such that the number of CQMs required for the vendors to have certified would increase each year until EHR products are required to certify all CQMs required for reporting by EPs, eligible hospitals, and CAHs.
– Example
• Year 1-EHRs to be certified to at least 18 of 64 available CQMs for EPs and 22 of 29 available CQMs for eligible hospitals and CAHs
• Year 2- EHRs to be certified to at least 36 CQMs for EPs and all 29 CQMs for eligible hospitals and CAHs
2019 and Beyond: MACRA,
the Merit Based Incentive Payment
System (MIPS), and Payment for Value
MACRA- Sustainable Growth Rate Repeal
• (H.R. 2- The Medicare Access and CHIP Reauthorization Act of 2015 or MACRA) is bi-partisan legislation that is passed in April by the United States Congress. The legislation aims to achieve the following objectives:
– Repeal the Medicare Sustainable Growth Rate, instead instituting a 0.5% payment update each year for five years.
– Improve the fee-for-service system by streamlining Medicare’s existing web of quality programs into one value-based performance program known as the Merit-Based Incentive Payment System (MIPS.)
– Make Medicare more transparent by giving patients more access to information and supplying doctors with data they can use to improve care by requiring certified EHRs to be interoperable by December 31st, 2018.
– Automatic 5% annual bonus for participation in qualifying Alternative Payment Models
Merit-Based Incentive Payment System (MIPS)
• Starting in 2019, all current Medicare payment, including incentive programs, will be combined into one Merit-Based Incentive Payment System, known as MIPS.
• The MIPS program will replace all Medicare reimbursement for eligible professionals.
MIPS Performance Measurement
• The MIPS program will use four performance measures to determine reimbursement
– Quality.
– Efficient Resource Use
– Clinical practice improvement activities.
– Meaningful use of certified EHR technology.
• Using these four performance factors, HHS will annually create MIPS adjustment factor weighing each category to determine reimbursement.
Quality
• CQMs being used for MU Stage 3, the CMS Value Modifier Program, and the PQRS will be retained for the 2019 program year. These measures can only be removed through the annual MIPS Annual Performance Measure Updates
• EPs that successfully utilize certified EHR technology will successfully meet the quality reporting requirement. Measure scores/performance will not determine reimbursement factor for quality.
• Quality domains will continue to include:
– clinical care
– Safety
– care coordination
– patient and caregiver experience
– population health and prevention
Efficient Use of Resources
• The Resource Use measures will initially feature the resource use measures currently utilized in the CMS Value-Based Modifier Program.
Meaningful Use of CEHRT
• Current requirements for demonstrating the Meaningful Use of an electronic health record will be required to receive full credit for this performance area. This includes:
– Utilization of a ONC Certified Electronic Health Record Technology
– Reporting EHR Incentive Program Objective Measures
– Successfully reporting clinical quality measures to CMS meets the Meaningful Use and Quality Reporting Performance requirements of the MIPS program
Clinical Practice Improvements
• Achievement Through Participation in an Alternative Care Model
– MIPS EP who is in a practice that is certified as a patient-centered medical home or comparable specialty practice, as determined by HHS, in a performance period shall be given the highest potential score for the performance category
– Participation by a MIPS EP in a recognized alternative payment model shall earn a minimum score of one-half of the highest potential score for the performance category.
• An EP that successfully reports on Expanded Practice Access, Population Management, Care Coordination, Beneficiary Engagement, and Patient Safety/Practice Assessment Measures can still achieve the maximum score without participating in an APM.
Performance Periods and Thresholds
• Performance Period
– Performance Periods will be as close as possible to matching a calendar year. The first performance period will start in 2019.
• Performance Thresholds
– HHS will create annual performance standards that will dictate reimbursement. Those performance standards will be based on:
• Historical performance standards on clinical quality measurement
• Improvement.
• The opportunity for continued improvement.
Performance Assessment
• HHS determines the weighting of each of the 4 categories. Scores will be 0-100.
– For example:
• Meaningful Use 20%
• Quality 50%
• Efficiency 15%
• Performance Improvement 15%
• Credit will be given to EPs that demonstrate annual improvement.
• The performance threshold will be the mean or median of the composite performance scores for all MIPS professionals during the previous reporting year.
Reimbursement
• Eligible professionals who exceed the mean/median score of all MIPS eligible professionals will receive an incentive payment.
• Eligible professionals who meet the threshold will receive the standard fee for service schedule/not receive a payment adjustment.
• Eligible professionals who score below the threshold will receive a penalty.
Incentives
• Eligible professionals with higher performance scores will receive proportionally larger incentive payments up to a maximum of three times the annual cap for negative payment adjustments.
• Additional Incentive Payment – An additional performance threshold for exceptional performance will be set at the 25th percentile of the range between the initial performance threshold and a perfect 100 score. Aggregate additional incentive payments will be capped at $500 million per year for each of 2019 through 2024
Penalties
• Eligible professionals whose composite performance score falls between 0 and ¼ of the threshold will receive the maximum possible negative payment adjustment for the year.
• Professionals with composite performance scores closer to the threshold will receive proportionally smaller negative payment adjustments.
– 2019- 4% maximum penalty
– 2020- 5% maximum penalty
– 2021- 7% maximum penalty
– 2022- 9% maximum penalty
