preparing your practice for macra - greenway health...per beneficiary medicare expenditures did not...

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Preparing your practice for MACRA

The Daunting Landscape

32% of those expenditures are being spent in the hospital market, where prices are significantly higher than services in the ambulatory market, which only receives 20% of the spend2.

Public payers such as Medicare, Medicaid, and the VA pay for over 40% of all healthcare services2.

Healthcare expenditures will represent over 19% of GDP by 20231.

1 Kaiser Family Foundation calculations using NHE data from Centers for Medicare and Medicaid Services, Office of the Actuary, National Health Statistics Group at http://www.cms.hhs.gov/NationalHealthExpendData/ 2 Centers for Medicare & Medicaid Services, Office of the Actuary, National Health Statistics Group

Preparing your practice for MACRA 2

What is the Medicare Access andCHIP Reauthorization Act of 2015?MACRA was enacted to replace the Sustainable Growth Rate (SGR), which was designed to ensure that growth in per beneficiary Medicare expenditures did not exceed GDP Growth.

• MACRA reauthorizes appropriations for Medicare Part B (physician services) and Children’s Health Insurance Program (CHIP). It only applies to Medicare Part B.

• MACRA creates the Quality Payment Program, which is broken into two tracks:

• Merit-based Incentive (MIPS)

• Advanced Alternative Payment Models (APMs)


What Does MACRA Do?

MACRA was passed in 2015 to roll the following programs into a single Quality Payment Program (QPP) that focuses on quality, cost, and administrative simplification by removing different reporting requirements.

• PQRS

• Meaningful Use

• Value-based Modifier

PQRS

Meaningful Use

Value-based Modifier

MACRA Quality Payment Program


MIPSMIPS is the default of the two programs. It measures Eligible Clinicians on Quality, Cost, Clinical Practice Improvement Activities, and Advancing Care Information.

You are subject to MIPS if:• You take enough Medicare revenue and/or see

enough Medicare patients; and,

• You are an “Eligible Clinician” (EC), meaning:

• Physicians (MD/DO and DMD/DDS), PAs, NPs, clinical nurse specialists, and certified registered nurse anesthetists for Years one and two.

• CMS may expand this to Physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, and dietitians/nutritional professionals.

• Even if you are an EC, you are not subject to MIPS if it’s your first year accepting Medicare or participate in an APM.


Who is Eligible to Participate in MIPS?

YEARS 1 AND 2 Physicians (MD/DO and DMD/DDS), PAs, NPs, clinical nurse specialists, certified registered nurse anesthetists.

YEARS 3+ Physical or occupational therapists, speech-language pathologists, audiologists, nurse midwives, clinical social workers, clinical psychologists, dietitians/nutritional professionals.


Eligible Clinician Reporting

Eligible clinicians can participate in MIPS as an individual or group.

GROUP A group, as defined by taxpayer identification number (TIN), would be assessed as a group practice across all four MIPS performance categories.

VIRTUAL GROUP REPORTINGTo be implemented in 2019 performance period where multiple TINs with 10 ECs or fewer may report as a single entity.

INDIVIDUAL

Preparing your practice for MACRA 7Preparing your practice for MACRA 7

Who is Not Eligible to Participate in MIPS?

Note: MIPS does not apply to hospitals or facilities.

In first year of Medicare Part B

participation

Below low patient volume threshold

Certain participants in Advanced APMs

Billing Medicare charges ≤$30,000 OR providers

caring for <100 patients in one year


Most Clinicians Will Be Subject to MIPS

Subject to MIPS

Not in APM In non-Advanced APM QP in Advanced APM

In Advanced APM, but not a QP

Some clinicians may be in Advanced APMs but not have enough payments or patients.


MIPS and Your Bottom Line

Two years after each performance period, you’ll get a payment adjustment on your FFS claims.

• For the 2017 performance period, you’ll get a up to a positive or negative 4% adjustment — depending your performance — in 2019.



• For the 2020 performance period and future ones, you’ll get a up to a positive or negative 9% adjustment — depending your performance — in 2022 onwards.


Initial Years’ Exceptional Performers BonusFor the first six years of the program, Congress has appropriated $500 million per year for “exceptional performers.”

• These exceptional providers can earn up to an additional 10% positive adjustment on their claims (so for example, for the 2017 performance period, up to 14%).

• For the first two years of the program, to be an exceptional performer you must earn a composite score of 70 or higher.

• These funds are exempt from budget neutrality.


MIPS at Maturity

Once the program is fully implemented, CMS will set a “performance threshold” each year, comprised of the mean or median of all prior year MIPS scores.

This principal is called budget neutrality. The program is designed to not increase or decrease the impacts on the federal budget.

CMS performance threshold

Exceed threshold: Make money

Meet threshold: No impact

Fall below threshold: Lose money


MIPS Scoring

MIPS measures in four categories, which collectively create a composite score of 100:

QUALITYReplaces the Physician Quality Reporting System (PQRS) and represents 30% of your total score after full implementation (2019).

ADVANCING CARE Replaces Meaningful Use, measures how providers use technology, and represents 25% of your composite score.

COSTReplaces the Value-based Modifier and measures healthcare expenditures per patient, will represent 30% of your score after full implementation (2019).

IMPROVEMENT ACTIVITIESMeasures clinical process improvements, representing 15% of MIPS composite score.


Quality Quality

Quality

Cost

Cost

60% 50%

30%

10%

30%

15%15%

15%

25% 25%

25%

Advancing Care Information



Clinical Practice Improvement Activities



2017 CATEGORY WEIGHTS




MIPS Categories: Quality

• While Quality represents 30% of the composite score, you earn up to 60 points within Quality (10 per measure).

• If you are in the top decile on a measure, you’ll get 10 points, the next decile will get nine points, and so on.

• The floor is three points for most measures (so even if you’re in the bottom decile you’ll get three points instead of one).

• Reporting is accomplished by claims, QCDR, qualified registry, or through an EHR depending on the measure.

Quality

Cost

30%

30%15%

25%Advancing Care Information




MIPS Categories: Cost

• It will include the Medicare Spending Per Beneficiary (MSPB), which is a per capita measure of overall spending.

• Going forward, CMS will introduce new episode-based measures that assess cost for certain events, such as a heart attack.

• Reporting is done by CMS on the back-end through claims.

Quality

Cost

30%

30%15%





MIPS Categories: Advancing Care Information

• Within Advancing Care Information (ACI), you can earn up to 100 points.

• 50 points comes from your base score. There are 4-5 base measures that require you to complete an activity at least one time for one patient.

• If you do not meet your base measures, you will fail the entire category.

• Base measures include:

• Electronic Prescribing

• Health Information Exchange (sending and receiving summaries of care)

• Providing patients with electronic access to their health record

• Security Risk Analysis

Quality

Cost

30%

30%15%





Advancing Care Information (cont’d)

• The remaining 50 points come from your performance score and bonus score.

• Essentially, the more you do, the more you earn. For example, one performance measure is “View, Download, Transmit.” If 1/10 patients view their electronic health record, you will get one point to your ACI score. If 2/10 do, you’ll get two points, all the way up to 10.

• You can get a bonus score. You get more points for connecting to public health registries, immunization registries, and for using CEHRT to reporting improvement activities.

Quality

Cost

30%

30%15%





ACI Measures – 2017


Objective Measure Required Performance

Protect Patient Health Information Security Risk Analysis Y 0

Electronic Prescribing e-Prescribing Y 0

Patient Electronic AccessProvide Patient Access Y Up to 20%

View, Download or Transmit (VDT) N Up to 10%

Patient-Specific Education Patient-Specific Education N Up to 10%

Secure Messaging Secure Messaging N Up to 10%

Health Information Exchange Health Information Exchange Y Up to 20%

Medication Reconciliation Medication Reconciliation N Up to 10%

Public Health and Clinical Data Registry Reporting

Immunization Registry Reporting N 0 or 10%

Syndromic Surveillance Reporting NUp to 5% bonus per measure, 15% maximum bonus allowed

Specialized Registry Reporting N


ACI Measures – 2018 onward


Objective Measure Required Performance

Protect Patient Health Information Security Risk Analysis Y 0

Electronic Prescribing e-Prescribing Y 0

Patient Electronic AccessProvide Patient Access Y Up to 10%

Patient-Specific Education N Up to 10%

Coordination of Care Through Patient Engagement

View, Download or Transmit (VDT) N Up to 10%

Secure Messaging N Up to 10%

Patient-generated health data N Up to 10%

Health Information Exchange

Send a Summary of Care Y Up to 10%

Request/Accept Summary of Care Y Up to 10%

Clinical Information Reconciliation N Up to 10%

Public Health and Clinical Data Registry Reporting

Immunization Registry Reporting N 0 or 10%

Syndromic Surveillance Reporting N

Up to 5% bonus per measure, 15% maximum bonus allowed

Electronic Case Reporting N

Public Health Registry Reporting N

Clinical Data Registry Reporting N



Essentially, the more you do, the more you earn. For example, one performance measure is “View, Download, Transmit.” If 1/10 patients view their electronic health record, you will get one point to your ACI score. If 2/10 do, you’ll get two points, all the way up to 10.

You can also get a bonus score. You get more points for connecting to public health registries, immunization registries, and for using CEHRT to reporting improvement activities.

Maximizing ACI


MIPS Categories – Clinical Process Improvement Activities


Within this category, you can earn up to 40 points. If you are a small practice, defined as having 15 ECs or fewer, you need only 20 points. High-weighted activities are worth 20 points. Medium-weighted activities are worth 10 points.

Examples of activities: Providing patients with 24/7 access to their care team.

Chronic care and preventative care management for empaneled patients.

Engagemenat of patients through implementation of improvements in patient portal.

Collection and follow-up on patient experience and satisfaction data on beneficiary engagement.

Engagement of patients, family, and caregivers in developing a plan of care.

Becoming a recognized Patient-Centered Medical Home (automatic 100%).



Compare

Learn

Design

LEARN ABOUT THE PROGRAM Learn what it means for your bottom line, and what’s coming, with qpp.cms.gov and Greenway Health webinars.

COMPARE YOUR DATA Look at your historical data and measures, and focus on what you’re good at, what’s relevant to your patient population, and where you can make the easiest improvements.

DESIGN A PLAN Design a plan based on your data that accounts for 2017 and 2018. Use the transition year to test your plan, don’t slack this year or 2018 might catch you off guard.

Prepare for success! Don’t take off the transition year.

How to Succeed with MACRA


http://qpp.cms.gov

OTHER VISUAL ELEMENTS

Provider Strategies for MIPS


If you are eligible, start learning about the program. Read the executive summary.

Talk with your doctors to establish financial, clinical, and performance goals.

Do you want to simply comply and avoid penalties?

Do you want to test your systems and gradually improve over time?

Do you want to be a high performer?

Determine what workflow and process changes might be required to meet your performance goals.

Getting Started


https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html


2017 Compliance/Penalty Avoidance

Failure to participate results in a negative 4% adjustment rate.

To simply avoid a penalty (reach three points):

Read the executive summary. Start collecting data on either:

1. One CQM.

2. One improvement activity, or ...

3. The required ACI measures.



2017 High Performance (scores exceeding 70)


It is strongly recommended that you upgrade to a 2015 Certified EHR Technology (CEHRT) to add a bonus to your composite score.

Choose and start collecting data on: Six quality measures

• Analyze prior years’ CQM performance to determine what your practice is good at. • One outcome’s measure or another high-priority measure if outcome is unavailable. • Attempt to score at least in the 4th decile across all your quality measures. • Visit this page to download measure specifications and what scores place you in what deciles.



2017 Test Your Systems (scores from 3-70)


It is strongly recommended that you upgrade to a 2015 certified EHR Technology (CEHRT) to add a bonus to your composite score.


• Analyze prior years’ CQM performance to determine what your practice is good at. • One outcome’s measure or another high-priority measure if outcome are unavailable. • Attempt to score at least in the 4th decile across all your quality measures. • Visit this page to download measure specifications and what scores place you in what deciles.

Collect data on the required ACI measures • Pick several to excel at and implement process changes at the clinician level so technology is consistently used to ensure you reach the maximum ACI score.

Choose 1-4 improvement activities depending on practice size and priority weights (get to 40 points).

Conduct workflow analyses across the organization on all measures to ensure data is being captured on a quarterly basis.

Really look at full-year reporting to make sure your organization is prepared and has staff capacity to do this year after year.




2018 Compliance/ Penalty Avoidance

Determine a pathway to 15 composite points.

Sample reporting options: Start collecting data on either:

• Six CQMs • Full improvement activity participation, or ... • The required ACI measures and one CQM



2018 Test Your Systems (scores from 15-70)



• One outcome’s measure or another high-priority measure if outcome is unavailable. • Attempt to come in at least in the 4th decile across all your quality measures. Visit this page to download measure specifications and what scores place you in what deciles.

Collect data on the required ACI measures, and pick a couple you really want to hone in on and excel at (workflow dependent); and,

Choose 1-4 improvement activities (get to 40 points).





2018 High Performance (scores exceeding 70)



• Analyze prior years’ CQM performance to determine what your practice is good at. • One outcome’s measure or another high-priority measure if outcome is unavailable. • Attempt to score at least in the 4th decile across all your quality measures. • Visit this page to download measure specifications and what scores place youin what deciles. • Consider trying to improve on a prior year’s CQM to take advantage of improvement scoring under MIPS.



2018 High Performance (cont’d)


Collect data on the required ACI measures • Pick several at which to excel, then implement process changes at the clinician level, and use technology consistently to ensure you reach the maximum ACI score.

Choose 1-4 improvement activities depending on practice size and priority weights (get up to 40 points).


Participate in full-year reporting to prepare for the eventual transition to an Advanced APM. Begin evaluating what Advanced APMs are available to you in 2019 and beyond, whether through

Medicare, Medicaid, or the All-Payer Option. Determine whether it makes sense to participate based on: • Process readiness • Clinician culture • Financial performance under MIPS • Alignment with other programs/initiatives in your payer mix


2019?


Cost and resource use will be measured at 30% of your MIPS score • 2019 episode-based measures have not been determined, so subscribe for updates at qpp.cms.gov. • The Medicare spending per beneficiary measure will likely be included. • Review prior Quality and Resource Use Reports (QRUR) to assess current levels of performance.

The MIPS performance threshold will be set at the mean or median of prior years’ MIPS composite scores. This means each year the performance threshold will increase. As the program becomes more aggressive, consider Advanced APMs. Determine whether it makes sense to participate based on: • Process readiness • Clinician culture • Financial performance under MIPS • Alignment with other programs/initiatives in your payer mix


http://qpp.cms.gov

Greenway Health: A Record of Success in Value-based Care


Exclusive to the ambulatory market, Greenway Health has specialized in serving independent practices for more than 40 years.

We have more than 17,000 meaningful use attestations, and over 80% of our participating clients have made money or avoided negative adjustment in MU 1, MU 2, and MU 3.

Over 90% of our participating clients made money or avoided a negative adjustment in ACO or PCMH.


Simplifying MACRA Participation

Minimize confusion and disruption as you tackle MACRA and MIPS challenges.

Contact us: 877-932-6301


Greenway Health’s systems can help simplify meeting and exceeding minimum MIPS requirements.Install Greenway Health’s 2015 CEHRT edition and add 2.5 points to your composite score. Report the base ACI measures, which requires only a 1 in the numerator, for 12.5 points. Use Greenway Health’s EHR to report on six quality measures, meet the data submission criteria, and you get 15 points (the minimum is 2.5 points per measure). Greenway supports all 53 EHR-based measures through Intergy and Intergy Practice Analytics. Because that qualifies as electronic reporting, it brings you to 20 points.

Just meeting the reporting requirements with our systems gets you 35 points when the threshold for next year is 15.


preparing your practice for macra - greenway health...per beneficiary medicare expenditures did not...

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