Avoid Revenue Shortfalls with MIPS Know-how

Posted on 21 Aug, 2018 |comments_icon 0|By Elizabeth
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If you decide to participate in Merit-based Incentive Payment System (MIPS), you will earn a performance-based payment adjustment to your Medicare payment.

You earn the payment adjustment based on evidence-based and practice-specific quality data. You show you provided high quality, efficient care supported by technology by sending in information in the following categories:

  1. Quality
  2. Cost
  3. Improvement Activities
  4. Advancing Care Information

MIPS provides you with the flexibility to choose the activities and measures that are most meaningful to your practice. Refer to the table below to review weights assigned to each category for the transition year 2017. The weights are default weights set in the original Final Rule. The 2018 Final Rule changes these weights. Be aware that the weights assigned to each category can be adjusted by CMS in certain circumstances regardless of what year you are calculating.

Transition Year Weights (2017):
60% Quality
15% Improvement Activities
25% Advancing Care Information
0% Cost

For 2018, the Performance Category Weights for MIPS change to reflect the introduction of the Cost category this year instead of next year as CMS originally proposed. Cost this year weighs in at 10%, so CMS is decreasing Quality’s weight to 50% to compensate. The other two categories, Advancing Care Information and Improvement Activities, remain at 25% and 15%, respectively.

Year 2 (2018 MIPS Performance Period):
50% Quality
15% Improvement Activities
25% Advancing Care Information
10% Cost

Nix the Old Quality Measures

The Quality Measures outlined by CMS will replace PQRS and the Quality Portion of the Value Modifiers to provide an easier transition due to familiarity and similarity to the current measures.

Providers can select six of about 300 quality measures (minimum of 90 days to be eligible for maximum payment adjustment).

Key: One of the measures must be an Outcome measure OR High-priority measure — defined as outcome measure, appropriate use measure, patient experience, patient safety, efficiency measures, or care coordination. Providers may also select a specialty-specific set of measures

Remember: There are different requirements for groups reporting through a CMS Web Interface or those in MIPS APMs. Also, for the Readmission measure for group submissions that have ≥ 16 clinicians and a sufficient number of cases, there is no requirement to submit.

Smart idea: To determine the Quality Measures to report, go to the Quality Measures page at: www.cms.gov and follow these instructions:

  1. Review and select measures that best fit your practice.
  2. Add up to six measures from the list, including one outcome measure. You can use the search and filters capabilities at CMS to help find the measures that meet your needs or specialty.
  3. If an outcome measure is not available that is applicable

Download a CSV file of the measures you have selected for your records. The tool that CMS provides is for informational and estimation purposes only. You cannot use this tool to submit or attest to measures or activities.

Improvement Activities Reap Rewards

Clinical Practice Improvement Activities are those that improve clinical practice or care delivery and that, when effectively executed, are likely to result in improved outcomes. This category allows you to attest to participation in activities that meet these goals. You choose from activities listed under the Improvement Activity inventory, like these:

  • Shared decision-making
  • Patient safety
  • Coordinating care
  • Increasing access

For 2018, providers can choose from over 100 activities under eight subcategories:

  1. Expanded Practice Access
  2. Population Management
  3. Care Coordination
  4. Beneficiary Engagement
  5. Patient Safety and Practice Assessment
  6. Achieving Health Equity
  7. Integrating Behavioral and Mental Health
  8. Emergency Preparedness and Response

In this performance category, you are rewarded for care focused on three Improvement Activities: care coordination, beneficiary engagement, and patient safety. In summary, MIPS-eligible clinicians or groups must submit data on improvement activities that are performed for at least a continuous 90 days during the performance period. MIPS-eligible clinicians must submit a “yes” response for activities within the Improvement Activities Inventory.

Nail Down Improvement Activities Reporting

The 2018 Final Rule implements 21 new Improvement Activities (some with modification) and changes 27 previously adopted improvement activities (some with modification and including one removal). These changes are effective for the Quality Payment Program Year 2 (CY 2018) and future years Improvement Activities Inventory.

To determine what activities to report, go to the Improvement Activities page at www.cms.gov and follow these instructions:

Review and select activities that best fit your practice:

  • Most participants: Attest that you completed up to four improvement activities for a minimum of 90 days.
  • Groups with fewer than 15 participants or if you are in a rural or health professional shortage area: Attest that you completed up to two activities for a minimum of 90 days.
  • Participants in certified patient-centered medical homes, comparable specialty practices, or an APM designated as a Medical Home Model: You will automatically earn full credit.
  • Participants in certain APMs under the APM scoring standard, such as Shared Savings Program Track 1 or OCM: You will automatically be scored based on the requirements of participating in the APM. For all current APMs under the APM scoring standard, this assigned score will be full credit. For all future APMs under the APM scoring standard, the assigned score will be at least half credit.
  • Participants in any other APM: You will automatically earn half credit and may report additional activities to increase your score.

Download a CSV file of the activities you have selected for your records. The tool that CMS provides is for informational and estimation purposes only. You cannot use this tool to submit or attest to measures or activities.

Get to Know Advancing Care Information Reporting

Advancing Care Information replaces the EHR Incentive Program, or Medicare Meaningful Use (MU). So, this is another category that might be familiar to you. This category promotes patient engagement and improved healthcare quality through the electronic exchange of information using certified EHR technology. It also provides greater flexibility in choosing measures.

In 2017, there were two options for reporting. The option you used to submit your data was, and still is, based on your electronic health record edition:

Option 1: Advancing Care Information Objectives and Measures

  • If you have technology certified to the 2015 edition; or
  • If you have a combination of technologies from 2014 and 2015 editions that support these measures

Option 2: 2017 Advancing Care Information Transition Objectives and Measures

  • If you have technology certified to the 2015 edition; or
  • If you have technology certified to the 2014 edition; or
  • If you have a combination of technologies from 2014 and 2015 editions.

In 2018, MIPS-eligible clinicians have the option to report the Advancing Care Information Transition Objectives and Measures using 2014 edition CEHRT, 2015 edition CEHRT, or a combination of 2014 and 2015 edition CEHRT, as long as the EHR technology you possess can support the objectives and measures to which you plan to attest.

Similarly, you will have the option to attest to the Advancing Care Information Objectives and Measures using 2015 edition CEHRT or a combination of 2014 and 2015 edition CEHRT, as long as their EHR technology can support the objectives and measures to which they plan to attest.

To determine what measures to report, go to the Advancing Care Information page at www.cms.gov and follow these instructions:

  1. Review the Advancing Care Information Measures available. Remember, in order to get credit for advancing care information, you must submit information for the required measures.
  2. Download a CSV file of the measures for your records. This tool is only for informational and estimation purposes. You can’t use it to submit or attest to measures or activities.

Take a Giant Leap Forward with Cost Measures in 2018

Cost measures replace the Value-based Payment Modifier Program this year. A cost measure represents the Medicare payments for the items and services furnished to a beneficiary during an episode of care. The episode of care is the basis for identifying items and services through claims that are furnished to address a condition within a specified time frame.

Clinicians are assessed on Medicare claims data. CMS will provide feedback on how you performed in this category in 2017, but it will not affect your 2019 payments.

The CMS goal is to align cost measures with quality of care assessment so that patient outcomes and smarter spending can be pursued together. Building cost measures involves five essential components:

  1. Defining an episode group
  2. Assigning costs to the episode group
  3. Attributing the episode group to one or more responsible clinicians
  4. Risk adjusting episode group resources or defining episodes to compare like beneficiaries and to the fullest extent possible
  5. Aligning episode groups with indicators of quality

Before cost measures can be fully developed, episode groups should be built and interpreted in the context of the quality of clinician care. Events such as hospitalizations, readmissions, and certain complications can be identified through claims analysis and can show the quality of care furnished during an episode.

Because these events can be captured using claims analysis, no additional data submission is required. Other strategies for aligning cost measures with quality of care include pairing episode group costs with quality measures that share similar characteristics, as well as considering indicators of patient outcomes, such as functional status, that can be interpreted side-by-side with cost.

Remember: This category uses measures previously used in the physician Value-based Modifier Payment Program or reported in the Quality and Resource Use Report (QRUR). Only the scoring is different.

Learn More

Don’t let piecemeal information or complex, barely-intelligible MACRA guidelines torpedo your earnings. Gear up for payment rewards now with TCI’s MACRA Quality Measures Guide 2018.

Author

Elizabeth


Elizabeth works on an array of projects at TCI, researching and writing about modern reimbursement challenges. Since joining TCI in 2017, she has also covered the nuts and bolts of cybersecurity, compliance with federal laws, and how to tap into the advantages of telehealth services.

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