Post on 26-Mar-2020
MIPS: Quality Measures and Scoring
Sam Ross, QPP Advisor and Manager Quality Payment Program of Illinois
July 19th, 2017
Visit our website at http://qpp-il.org! We will help you navigate the complexities of the new CMS payment models so you can focus on what you do best – taking extraordinary care of your patients.
When you sign up for the QPP Resource Center, you get access to resources that help you establish your baseline, identify goals, learn about requirements, and monitor progress. Plus, QPP Advisors are available to answer questions as they come up. All assistance is offered free-of-charge thanks to a grant from CMS.
Agenda
Merit-based Incentive Payment
System at-a-glance
Quality performance category measures and scoring
NOTE: Information in this presentation applies to rules for the 2017 performance year. Future years will have modifications established through additional rulemaking.
Merit-Based Incentive Payment System
(MIPS)
MIPS Eligible
Individual clinicians or groups exceeding the low-volume
threshold ($30,000 to Medicare Part B AND providing care for
more than 100 Medicare patients over 12-month period)
Check eligibility at https://qpp.cms.gov
Enter NPI into search box
Click Check NPI button
Review individual and group eligibility
PhysiciansPhysician Assistants
Nurse Practitioners
Clinical Nurse Specialists
Certified Registered
Nurse Anesthetists
GROUPINDIVIDUAL
Individual vs. Group
Individuals are included in MIPS based on claims for single NPI at each associated TIN
Individuals may be required to report at multiple TIN
MIPS score based on performance of single NPI at associated TIN
Payment adjustment based on performance of single NPI at associated TIN
Groups are included in MIPS based on claims for all NPI billing to TIN
Groups must report for all eligible clinicians billing to TIN (individually or in aggregate)
If reporting in aggregate, group receives MIPS score based on performance of all members
If reporting in aggregate, all members receive same payment adjustment based on group MIPS score
MIPS Excluded
Below the low-volume threshold
• Medicare Part B allowed charges less than or equal to $30,000 a year
OR• See 100 or fewer
Medicare Part B patients a year
Newly-enrolled in Medicare
• Enrolled in Medicare for the first time during the performanceperiod (exempt until following performanceyear)
Significantly participating in
Advanced APM*
• Receive 25% of your Medicare paymentsthrough an Advanced APM
OR• See 20% of your Medicare
patients through an Advanced APM
* Refer to https://qpp.cms.gov/apms/overview for a list of 2017 Advanced APM
Eligible clinicians and groups may be excluded from MIPS reporting
MIPS Concepts & Categories
Moves Medicare Part B clinicians to performance-based payment system
Provides clinicians with flexibility to choose the activities and measures
that are most meaningful to their practice
Combines PQRS, Value-Based Modifier and EHR Incentive (Meaningful Use) into one system with four categories
Quality (replaces PQRS), Cost (replaces Value-Based Modifier), Advancing Care Information (replaces Meaningful Use)
Improvement Activities is a new concept
Quality CostImprovement
Activities
Advancing Care
Information
2017 MIPS Scoring
Improvement Activities
Advancing Care Information
Note: These are default weights; the weights can be adjusted in certain circumstances and will change in future performance years
Quality
60%
Cost
0% 15% 25%
Clinicians and groups scored from 1 to 100
Each category contributes a percentage of total score
Today’s webinar covers how to earn these points!
MIPS Timeline
• Submit some data after
January 1, 2017
• Neutral or small
payment adjustment
Test Partial Year
• Report for 90-day
period after January 1,
2017
• Small positive payment
adjustment
MIPS Pick your Pace
Full Year
• Fully participate
starting January 1,
2017
• Modest positive
payment adjustment
Not participating in the Quality Payment Program for the Transition Year will resultin a negative 4% paymentadjustment.
MIPS Submission Methods
Individual Group
Quality QCDR (Qualified Clinical
Data Registry) Qualified Registry EHR Claims
QCDR (Qualified Clinical Data Registry) Qualified Registry EHR Administrative Claims CMS Web Interface
(groups of 25 ormore)
CAHPS for MIPS Survey
Advancing Care Information
Attestation QCDR Qualified Registry EHR
Attestation QCDR Qualified Registry EHR CMS Web Interface
(groups of 25 ormore)
Improvement
Activities Attestation QCDR Qualified Registry EHR
Attestation QCDR Qualified Registry EHR
Quality Performance Category
Quality Concepts
Promotes measurement and improvement of care
processes, outcomes, patient experience, patient safety,
efficiency and care coordination
Ends and replaces the Physician Quality Reporting System (PQRS) and the Quality component of the Value-Based Payment Modifier (VM)
Greater flexibility in choosing measures that fit your practice
Variation in available measures, reporting requirements and scoring depending on submission method
Quality Measures
Quality category has 271 available measures*
CMS has created 30 specialty measure sets to help clinicians identify appropriate measures
Participants report at least 6 measures, including one “outcome” or “high priority” measure (reporting all measures from a measure set with <6 is also acceptable)
Measures available depend on submission method
Must submit all measures through same method CAHPS Survey measure is exception if selected as one of 6 All-cause hospital readmissions measure is automatically
calculated/scored for groups of 16+ with at least 200 cases
* Refer to https://qpp.cms.gov/mips/quality-measures for full list of measures, which can be filtered based on high-priority, submission method and specialty measure set
Measures by Method
Submission Method
Available For MeasuresAvailable
Measures Required
Reporting Period
Claims Individuals only 74 6+ 90 days
QCDR/Qualified Registry
Individuals and Groups
243 6+ 90 days
EHR Individuals and Groups
53 6+ 90 days
CMS Web Interface
Groups 25+ only
14 14 Full calendar year
CAHPS Survey Groups only 1 1 Full calendar year
Measure Benchmarks
• Claims, registry, EHR benchmarks are based on 2015 PQRS
• CAHPS benchmarks based on 2015 PQRS or CAHPS for ACO
• CMS Web Interface benchmarks based on shared-savings program
• Re-admissions has no benchmark in 2017
• All reporters (individuals and groups regardless of specialty or practice size) are combined into one benchmarkfor the submission method
• Benchmarks will be updated each MIPS performance year
Benchmarks only established for measures reported by 20 individuals/groups that also:
• Meet or exceed minimum case volume
• Meet or exceed data completeness criteria
• Have performancegreater than 0 percent
* Download complete quality benchmark data at https://qpp.cms.gov/docs/QPP_Quality_Benchmarks_Overview.zip
Measure Scoring
If a measure can be reliably scoredagainst a benchmark, then cliniciancan receive up to 10points
• Reliably scored means the following:• Benchmark exists• Sufficient case volume (>=20
cases for most measures; >=200 cases for readmissions)
• Data completeness met (report at least 50% of eligible patients)
• “Topped out” measures require 100% performance to earn 10 points
If a measure cannot be reliably scored against a benchmark, then clinician receives 3 points
• Benchmark doesn’t exist (may wish to avoid selecting these)
• Sufficient case volume failed (report data over longer period to avoid this)
• Data completeness criteria failed (report on all patients for whom measure applies to avoid this)
CMS will attempt to score each measure submitted against benchmarks. If reporting more than 6 measures, CMS will assign the ones that earn the most points.
Points by Benchmark
Measure benchmarks are divided into deciles
Measure performance in range of decile 3 earns between 3 and 3.9 points, in range of decile 4 earns between 4 and 4.9 points, etc.
“Topped out” measures may skip deciles
Measures will have different deciles/scoring for each submission method
* The above image is a real sample from https://qpp.cms.gov/docs/QPP_Quality_Benchmarks_Overview.zip
Points by Benchmark
Clinicians can receive up to 10% of maximum points for each of the following:
Submitting an additional high-priority measure
2 bonus points for each additional outcome and patient experience measure
1 bonus point for each additional high-priority measure
Using CEHRT to submit measures to registries or CMS
1 bonus point foreach measure submittedelectronically "end-to-end"
Bonus Points
Clinicians can receive a maximum number of points depending on submission method:
Claims, Registry, EHR
• 10 points max for 6 measures + 1 readmission measure
• if readmission measure does not apply
70POINTS
60POINTS
Maximum Points
CMS Web Interface
• for groups with complete reporting(14 measures) and readmissionsmeasure
• for groups with complete reporting(14 measures) and no readmissions measure
120POINTS
110POINTS
* Only 11 of 14 measures have a benchmark. The 3 measures that don’t will not be scored if you report all the measures, but you would be penalized for not reporting all the measures
Points earned on required quality
measures=
Maximum number
of points
Total Quality Performance
Category Score
Note: Maximum score cannot exceed 100%; a score of 100% or greater will result in full 60 points for the Quality performance category of MIPS total score (85 points if ACI is re-weighted)
Any bonus points
+
Total Quality Score
Quality Scoring Examples
Scoring Example A
Measure Performance Benchmark Decile (Range) Points
Diabetes: Medical Attention for Nephropathy
80.3% 5 (79.17 - 83.01) ~5.1
Diabetes: Eye Exam 93.5% 4 (89.69 - 95.95) ~4.5
Diabetes: Foot Exam 40.1% 6 (39.81 - 55.87) ~6
Hypertension: Controlling BP* 72.2% 9 (71.93 - 75.11) ~9
Falls: Risk Assessment* 99.8% 7 (84.17 - 99.82) ~7.9
Falls: Plan of Care* 99% 9 (98.08 - 99.99) ~9.5
Group of 3 clinicians reporting minimum 6 measures for 90-day period using registry submission method
* High-priority measure
Scoring Example A
Points earned on required measures = 42 (estimated)
Bonus points = 2 (two additional high-priority measures x 1 point each, no electronic “end-to-end” reporting)
Maximum points = 60 (not eligible for readmissions measure)
(Total + Bonus) / Maximum = 44/60, 73.33%
73.33% * maximum 60 points for Quality performance category = 44
ECs in this group earn 44 points in the Quality category towards
total MIPS score
Scoring Example B
Measure Performance Benchmark Decile (Range) Points
Diabetes: Hemoglobin A1c Poor Control* 11.5% 7 (14.14 – 9.10) ~7.5
Diabetes: LDL-C Control* 70% 10 (>=69.36) 10
Breast Cancer Screening 51.5% 7 (47.92 - 55.25) ~7.5
Hypertension: Improvement in BP* 28% 9 (27.62 – 39.04) ~9
Colorectal Cancer Screening** 33.5% 6 (33.46 – 44.39) ~6
Cervical Cancer Screening 50% 8 (45.00 – 54.77) ~8.5
Anti-depressant Medication Management 85% 10 (>=80.63) 10
All-cause hospital readmissions*** 75% TBD 9
Group of 20 clinicians reporting 8 measures for a 365-day period using EHR submission method
1 clinician is a hospitalist and elects to re-weight ACI (25 pts) to Quality
* Outcome measure
** Measure thrown out because there are 6 submitted measures with higher scores
*** Included automatically (no submission) as a 7th measure
Scoring Example B
Points earned on required measures = 61.5 (estimated)
Bonus points = 10 (two additional outcome measures x 2 points each, six submitted using electronic “end-to-end” reporting x 1 point each)
Maximum points = 70 (eligible for readmissions measure)
(Total + Bonus) / Maximum = 71.5/70, 102.1%
102.1% * maximum 60 points for Quality performance category = 60
ECs in this group earn full 60points in the Quality category
towards total MIPS score
Hospitalist EC earns full 85 points
Scoring Example C
Measure Performance Benchmark Decile (Range) Points
Pneumonia Vaccination Status for Older Adults*
62% 5 (61.68 – 70.47) 3
Pain Assessment and Follow-Up* 93.5% 4 (89.69 - 95.95) 3
Advance Care Plan* 70% 5 (62.87 – 86.91) 3
Individual clinician reporting 3 measures for less than 90-day period using claims submission method
* Not enough data submitted for scoring against benchmarks, maximum 3 points allowed (no bonus points available)
Scoring Example C
Points earned on required measures = 9
Bonus points = 0 (none allowed when reporting <90 days)
Maximum points = 60 (not eligible for readmissions measure)
(Total + Bonus) / Maximum = 9/60, 15%
15% * maximum 60 points for Quality performance category = 9
EC earns 9 points in the Quality category towards total MIPS
score
Quality Reporting Considerations and
Resources
• Submit a minimum of 1
patient in numerator of
1 quality measure
• Earn minimum 3 points, ensure avoidance of MIPS negative adjustment
Test Partial Year
• Report measures for
minimum 90 days
• Earn points based on
number of measures
submitted and
reliably scored against
benchmarks
Quality Pick your Pace
Full Year
• Report measures
for entire year
• Earn points based on
number of measures
submitted and
reliably scored
against benchmarks
Not reporting anything will result in 0 points for the Quality category towards your overall MIPS score
Claims Reporting
Only available for individual reporting
Requires coding of Medicare claim forms* Denominator criteria based on demographics,
diagnoses, procedure codes (usually CPT/HCPCS) Numerator usually based on CPTII codes with “cost” of
$0.00 or $0.01 Exclusion usually based on modifier codes
Measure scores determined from analysis of claims; does not require submission of any additional information
Data completeness criteria = 50% of eligible patient population for each measure (Medicare patients only)
* Download measure coding specifications at https://qpp.cms.gov/docs/QPP_quality_measure_specifications.zip
EHR Reporting
Only available if using 2014 or 2015 CEHRT
Limited to reporting measures supported by your CEHRT
Requires careful adherence to documentation workflows Request quality measure guides from vendor Train staff on documentation best practices Run quality reports often to check for accuracy
Measure scores submitted directly to CMS by CEHRT vendor, on behalf of clinicians
Data completeness criteria = 50% of eligible patient population for each measure (all payers)
Registry Reporting
Qualified registry/QCDR are CMS-approved entities that collect and submit data on behalf of MIPS participants
Typically designed with more robust analytics than EHR
QCDR are different from qualified registry because it is not limited to measures within MIPS (can develop and submit new measures for CMS approval)
Registries may offer to submit for Advancing Care Information and Improvement Activities as well
Data completeness criteria = 50% of eligible patient population for each measure (all payers)
* View list of qualified registries at https://qpp.cms.gov/docs/QPP_2017_Qualified_Registries.pdf
* View list of QCDR at https://qpp.cms.gov/docs/QPP_2017_CMS_Approved_QCDRs.pdf
Web Interface Reporting
Formerly known as the GPRO Web Interface
Secure internet-based submission for groups of 25 or more MIPS clinicians reporting to CMS
Pre-populated with claims data from Medicare beneficiaries assigned to the group
Eliminates need to search for and select measures (required to report all 15)
Requires registration by June 30 (too late this year!)
Data completeness criteria = meet CMS patient sampling requirements (Medicare patients only)
* Read about CMS Web Interface at https://qpp.cms.gov/docs/QPP_CMS_Web_Interface_Fact_Sheet.pdf
Resources
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-
Assessment-Instruments/Value-Based-Programs/MACRA-
MIPS-and-APMs/QPP-MIPS-Quality-and-Cost-Slides.pdf
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-
Assessment-Instruments/Value-Based-Programs/MACRA-
MIPS-and-APMs/MIPS-Scoring-Methodology-slide-deck.pdf
https://www.qualityinsights-
qin.org/getattachment/Events/Archived-Events/MIPS-
Quality-webinar_FINAL_4-19-17_508.pdf.aspx
Quality Payment Program of Illinois
http://qpp-il.org
Program Info: info@qpp-il.org
QPP Questions: qpphelp@chitrec.org
OR
844-QPP-DESK (844-777-3375)