Folder Contents

Agenda 10:00AM – 10:20AM Registration

10:20AM – 10:30AM Welcome and Introduction

10:30AM – 11:15AM Highlights of the MACRA Rule

11:15AM – 12:00PM Tips and Tricks for MU and PQRS

12:00PM Lunch

12:15PM – 1:15PM Panel: Optimizing Your Practice for MU, PQRS, MACRA Success

1:15PM – 1:30PM Break

1:30PM – 2:00PM HIPAA Scan: Top Threats and Success Strategies for Practices

2:00PM – 2:30PM Getting Ready for Practice Transformation

2:30PM – 3:00PM Open Q & A/Closing Remarks

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Today’s Hashtag: #kytransform

Today’s Hashtag: #kytransform

Carol Steltenkamp, MD, MBA

CMIO, UK HealthCare

Trudi Matthews, Managing Director, Kentucky REC

Highlights of MACRA Final Rule

Moving to Value-Based Payment

Understanding the What & Why

What is Value Based Payment?

Quality Cost

VA

LUE

Volume to Value Based Shift Recent legislative, regulatory and marketplace developments suggest that the transition from volume to value-based payment is accelerating from a “testing” phase to a “scaling” phase

Affordable Care Act Enacted

March 2010

January 2012

Pioneer ACO Program

Launched

October 2012

Hospital Value Based Purchasing

Program

April 2013

Bundled Payments for Care Improvement

(BPCI)

CMS Announces Value-Based Payment Goals;

Value Modifier Program Begins

January 2015

Medicare Access and CHIP Reauthorization Act (MACRA) Enacted

April 2015

Testing Phase Scaling Phase

April 2016

MACRA NPRM, Medicaid Managed

Care Final Rule Released

July 2016

Cardiac & CJR Episode Payment NPRM

Released

MACRA Final Rule

Released

October 2016

In January 2015, the Department of Health and Human Services announced

new goals for value-based payment and APMs in Medicare

2015: CMS Accelerates Shift to Value-Based Payment

April 2016: Medicaid Managed Care Regulations

Among other provisions State Medicaid Agencies may require an MCO to:

• Implement value based purchasing models for provider reimbursement

• Participate in multi-payer delivery system reform or performance improvement

• Phase out of supplemental payments – with option to move payments into value-based payment models

Commercial Insurers Accelerate VBP

“Our industry is in the midst of a profound shift from fee-for-service, or volume-based care, to value-based care. Aetna has successfully built more than 72 ACO relationships with providers, growing from very small numbers in 2011 to more than 2 billion dollars in revenue today. …We plan to maintain 75 percent of our medical spending in value-based contracts by 2020.”

- Charles Kennedy, MD, chief population officer for Healthagen, Aetna

Source: Health Care Learning & Action Network

Highlights of the Medicare Access and CHIP Reauthorization Act (MACRA)

Final Rule

Released in October 2016

APM MIPS

April 2016 MACRA Final Rule: New Medicare Part B Payment Program

Merit-based Incentive Payment System

Alternative Payment Models

88% CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources: The Advisory Board; CMS, “Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models,”

81 FR 28161, Federal Register, May 9, 2016,

For most health care organizations, the only real MACRA survival strategy:

SUCCEED IN MIPS

MACRA Glossary of New Terms • New program name for MACRA’s change in Medicare

Part B payments Quality Payment Program (QPP)

• New pay for performance approach under Medicare Merit-Based Incentive Payment

System (MIPS)

• New payment models (e.g., ACOs) that move away from fee-for-service reimbursement

Alternative Payment Models (APMs)

• Overall clinician score from 0-100 calculated based on four weighted performance categories

Final Score

• Category that replaces PQRS; worth 60% of final score in Yr 1

Quality

• New name for resource use category; replaces value modifier program; not assessed in Yr 1 Cost

• Category that replaces the Medicare EHR Incentive Program for meaningful use; worth 25% in Yr 1

Advancing Care Information (ACI)

• New category; worth 15% of final score; includes activities aimed at improving care

Improvement Activities

MACRA Eligible Clinicians (ECs)

• Physicians, PAs, NPs, CNS, CRNA

• After 2020, CMS may expand to other clinicians in Medicare FFS: PT, OT, NMW, CSW, Clinical Psychologists, Dieticians and Nutrition professionals

5 Types of Eligible Clinicians (ECs)

• Hospitals/Medicare Part A payments

• FQHCs/RHCs and Medicaid Providers

Not covered by MACRA:

• 1st year ECs

• “Non-patient facing” provider

• Low volume providers who do not bill at least $30,000 under the Medicare Physician Fee Schedule or care for more than 100 Medicare patients yearly

• Advanced APM Qualifying Provider not scored under MIPS

Exclusions:

MACRA Timeline

October 14, 2016:

Release of Final Rule

Jan – Dec 2017:

1st Performance Period for MACRA

March 31, 2018: Reporting Deadline for First Year

Jan – Dec 2019:

1st Payment Year = +/- up to 4%

Physician Compare

Coming Soon – Your MACRA performance score!

2017 Transition Year: “Pick Your Pace” Options

Option 1:

Test Submission

Option 2:

Partial Submission

Option 3:

Full Submission

Option 4:

Advanced APM

QPP

MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)

Physician Value-Based

Modifier

Physician Quality

Reporting System

EHR Incentive Program and

Meaningful Use

MIPS: A Consolidation of Programs

Providers will receive a MIPS final score based on 4 weighted performance categories:

MIPS

Final

Score

0-100

Quality

Cost

Advancing

Care

Information

Improvement

activities

How will MIPS measure performance?

CY19 60% 0% 15% 25%

CY20 50% 10% 15% 25%

CY21 30% 30% 15% 25%

Maximum MIPS Payment Adjustments

Source: Leavitt Partners - MACRA: Quality Incentives, Provider Considerations, and the Path Forward

Quality

% Score: Measures:

Requirements

Methods:

Makes up 60% of your final score for PY 2017 Replaces PQRS;

# of measures from 9 down to 6 measures

200+ measures

to choose from

6 Measures Except: Groups using

CMS web interface report 15 quality measures

MIPS – APMS report via CMS web interface

1 measure must be: Outcome

measure OR High-priority

measure

Measures updated each year

Specialist sets available

QCDR EHR Qualified

Registry Web interface

(groups only) Claims

(individual only)

Improvement Activities

% Score: Measures:

Requirements:

Method:

Makes up 15% of your final score for PY 2017 Full points for: Certified

PCMH/PCSP Medical Home

Model or Advanced APMs

MIPS - APMs get 50% of full pts

90+ Activities in 9 subcategories Access Population Management Beneficiary Engagement Care Coordination Patient Safety Equity

2- 4 Activities required: Highly weighted = 20 pts Medium weighted = 10 pts

Special consideration for small groups and ECs in rural and underserved areas

Simple attestation suffices for reporting Must be performed for a 90 consecutive day period

Advancing Care Information

% Score: Measures:

Requirements:

Reporting:

Makes up 25% of your final score for PY 2017 Replaces Medicare MU Program New Data Blocking Requirements

Base Score: Submit 5

Required Objectives

Performance Score: Submit up to 9

measures for additional credit

Flexible Scoring: 1. Base 2. Performance 3. Bonus

Bonus Credit: Public

Health/Clinical Data Registry

Use of CEHRT for improvement activities

Individual or Group/TIN Level reporting available

2017 Options: 1. ACI

Objectives 2. 2017 ACI

Specific measures

Cost

% Score: Measures:

Requirements:

Method:

Makes up 0% of your final score for PY 2017 2018 – category - 15% weight ECs will get feedback on this category in Quality and Resource Use Report (QRUR)

Score is based off of Medicare Part B claims, including: Measure 1: Spending per Beneficiary (MSPB) Measure 2: Total costs per capita for all attributed beneficiaries

New 10 episode-specific cost measures When clinician bills Medicare for diagnosis code gets included in episode Minimum # of patients sample. Typically 20 or > 35 for MSPB

No data submission required Validation of data is important!

APM MIPS

April 2016 MACRA Final Rule: New Medicare Part B Payment Program

Merit-based Incentive Payment System

Alternative Payment Models

What’s the big deal about APMs?

Stated intention of CMS that more and more of its $ will be spent in APMs over time

5% Annual Participation Bonus for Advanced APM participants from 2019-2025

Favorable scoring under MIPS for all APM participants

Annual update after 2025 is 0.75% for APM entities versus 0.25% for MIPS entities

Next Generation ACO Model

Medicare Shared Savings Program – Tracks 2 & 3

Comprehensive Primary Care Plus (CPC+)

Comprehensive ESRD Care Model

Oncology Care Model Two-Sided Risk Arrangement (in 2018)

Cardiac & CJR Episode Model (in 2018)

In new

MACRA

Final

Rule,

Advanced

APMs

include:

Advanced APM participants are eligible for 5% bonus payment. But, only some APMs are risk-bearing Medicare payment models that qualify for this bonus payment.

30

• MACRA does not change how any particular APM rewards value. • APM participants who are not “Qualifying Providers” (QPs) will receive favorable

scoring under MIPS.

Advanced Alternative Payment Models

All APM

Participants

QPs in

Advanced

APMs

Only providers in Advanced APMs will be deemed qualifying APM participants (“QPs”): 1. Report APM quality measures 2. Use of Certified EHR 3. Meet Advanced APM criteria (risk-bearing

or medical home model) 4. Must meet APM thresholds for payment and

patient volumes

Most physicians and practitioners who participate in APMs will be subject to MIPS and will receive favorable scoring under the MIPS clinical practice improvement activities performance category.

Not Every APM Will Qualify for 5% APM Bonus

Impact of MACRA on Medicare Providers

Financial & Strategy Implications

• MACRA moves Medicare payment from one size fits all to a meritocracy

• Market share will shift from low performers to high performers over time

• Delay means disaster; exponential leaps in value will be needed to catch up with those that perform better as thresholds increase over time

Reputational Status

Publicly available scores on quality and value that compare organizations/professionals will affect:

• Health plan negotiations

• Talent recruitment

• Consumer choice

How can clinicians and staff prepare?

"People's lives can be absolutely transformed by being nudged along a slightly altered route.“

- Dr. Ben Fletcher

Sample QRUR

Immediate Actions to Consider

• Engage leadership & key clinicians

• Medical home recognition a critical first step

• Dominate your quality data

• Analyze QRUR and other payer feedback

• Review compensation models

Some clinicians think MACRA means…

• Stop seeing sick, non-compliant patients

• Start accepting only patients who are healthy

• But successful VBP/APM leaders understand

the 5-50 Rule.

5% of patients are responsible for 50% of costs.

Focus on Common Elements on the Payment Innovation Journey

Culture of Continuous Quality Improvement & Team Based Care

Patient Attribution & Empanelment

Performance Measurement, Data Analysis and Identification of Gaps in Care

Identification of Higher Risk, High Cost Patients & Targeted Care Management

Care Coordination across the Medical Neighborhood

Patient Engagement & Experience of Care

Kentucky REC & the Great Lakes PTN

• Great Lakes PTN is one of 29 Practice

Transformation Networks (PTNs) • GLPTN works with 10 Support and Alignment

Networks (SANs) GLPTN State Level Leadership: • Indiana University (primary grant recipient) • University of Kentucky (Kentucky) • Purdue Healthcare Advisors (Indiana) • Northwestern University (Illinois) • Altarum Institute (Michigan)

CMS established the Transforming Clinical Practices Initiative (TCPI) to help clinicians achieve large-scale health transformations through collaborative and peer-based learning networks

Thank you!

Questions?

Getting Ready for 2016 Reporting:

Tips and Tricks for PQRS

Healthcare Transformation

Regional Roadshows

Date here

Tip 1: List of Eligible Providers (EPs)

Tip 2: Reporting Methods

Individual Reporting Methods:

Claims

Qualified PQRS Registry

EHR Direct using certified EHR Technology (CEHRT)*

CEHRT via Data Submission Vendor (DSV)

Qualified Clinical Data Registry (QCDR)

Group Reporting Methods:

Qualified PQRS Registry

Web Interface (for groups of 25 or more)

EHR Direct using certified EHR Technology (CEHRT)*

CEHRT via Data Submission Vendor (DSV)

CAHPS for PQRS via CMS-certified survey vendor (for group practices of 2+)

* Requires obtaining a CMS Enterprise Identity Management (EIDM) account formerly known as the IACS account

Tip 3: Reporting Criteria

Required to submit 9 measures over 3 domains and one cross

cutting measure

Cross-cutting measures are defined as measures that are broadly

applicable

There are 6 National Quality Strategy Domains

Satisfactorily reporting measures requires that the measure

performance percentage must be greater than 0%

Tip 4: Reporting Timeframe

Claims – report through out the program year, note cannot re-submit claim just

to add PQRS modifiers

Qualified PQRS Registry – selected registry will have from Jan.1,2017

through Mar. 31, 2017 to submit on behalf of the EP

EHR Direct using certified EHR Technology (CEHRT) – EPs will be able to

submit appropriate data files through the CMS portal from Jan.1, 2017 through

Feb. 28, 2017

CEHRT via Data Submission Vendor (DSV) – Vendor can start submitting

data on behalf of EPs from Jan. 1, 2017 through Feb. 28, 2017

Qualified Clinical Data Registry (QCDR) – selected QCDR will have from

Jan.1,2017 through Mar. 31, 2017 to submit on behalf of the EP

Trick 1: PQRS Measure Selection

Considerations

Step 1: Review reporting year Measures list on PQRS website

Step 2: Consider Important Factors

Clinical conditions usually treated

Types of care typically provided – e.g., preventive, chronic, acute.

Other quality reporting programs in use or being considered – e.g.

Value-Based Modifier Program, upcoming Quality Payment Program

Step 3: Review Measure Specifications

After making a selection of potential measures, review the

specifications for the selected reporting mechanism for each measure

under consideration.

Select those measures that apply to services most frequently provided

to Medicare patients by the EP or PQRS group practice.

Trick 2: Leverage all Available Information

Download PQRS feedback reports from previous years to see

past performance to identify improvement trends

Obtain annual Quality Resource User Reports (QRURs) to

review quality previous quality scores *

* Requires obtaining a CMS Enterprise Identity Management (EIDM)

account formerly known as the IACS account

Trick 3: Obtain EIDM Account Early

Registration for an account is online using the CMS portal

Individual requesting access will be required to enter their

Social Security Number and Date of Birth for verification

Trick 4: Importance of Focusing on

PQRS

2016 the last performance year for PQRS as you know it

Starting performance year 2017 PQRS measures will be

used to calculate 60% of the Merit-Incentive Payment

System (MIPS) performance score proposed under the

Medicare Access and CHIP Reauthorization Act (MACRA)

QUESTIONS?

Lynn Grigsby Tiller, MBA, MSIS

Project Manager, Kentucky REC

Tips & Tricks for MU

Meaningful Use Tips & Tricks 2016

Meaningful Use is Still Here

Meaningful Use Measure Summary

CQMS Requirements for 2016

Incentives and Payment Adjustments

Meaningful Use is Still Here

Meaningful Use – Medicare versus Medicaid

• Continue to attest – 2016 LAST year for the Medicare EHR Incentive Program

• MACRA Implements, Sunsets and Incorporates Medicare MU Program for EPs

• No changes yet to Medicaid MU requirements for both EPS and EHs • Continue on 2016 path monitoring regulations • Since Medicaid MU program continues to 2021, dual

reporting will be required under current regulations

Breaking News: OPP Final Rule

• Aligns MU & Advancing Care information objectives Aligns

• 2016 reporting period: 90 days

• 2017 reporting period: 90 days

Reporting Period

• Removes CPOE

• Removes CDS Rules

Objective Changes

Important Deadlines for 2016

*Medicare – February 28, 2017 *Medicaid – March 31, 2017

• 60 days from start of reporting period • Last reporting period will be Oct 3 – Dec 31 • PH addendums must be signed by Dec 1 • Electronic Lab Reporting – If missed Oct 1 deadline – contact KHIE

Last Y ear to Enroll in Medicaid EHR Incentive Program

Attestation Deadlines

Public Health

Clinical Quality Measures – Reporting Mechanism

• 2016 is last year for EPs to enroll in the Medicaid EHR Incentive Program • Feb 28, 2017 – Last day to register for 2016 Medicaid EHR Incentive Program

• Dual eligible providers in danger of PQRS – VM Penalty – determine reporting mechanism ASAP

Objective Measure

Protect Patient Health Information • Security Risk Analysis*

Clinical Decision Support • 5 CDS Rules tied to 4 CQMS

Computerized order entry • >60 % Medication Orders • >30 % Lab Orders • >30 % Radiology Orders

Electronic Prescribing • >60% ePrescribing*

Health Information Exchange • >10 % Exchange information with other physicians*

Patient Education • >10 % Patient-Specific Education**

Medication Reconciliation • >50% Patient Transitioned into EPs care has medication reconciliation performed

Patient Electronic Access • >50% Patient Access* • 2016: 1 patient 2017: >5% View, Download and Transmit

(VDT)**

Secure Electronic Messaging • 2016: 1 patient 2017: >5 % Secure Messaging**

Public Health Reporting • Immunization registry reporting** (& Bonus) • Syndromic surveillance reporting (Bonus) • Specialized registry

Stage 2 Objectives 2016 - 2017

*ACI Base Score ** ACI Performance Score

• All participants in Medicaid MU will attest to Stage 3 beginning in 2018

Exception: Medicaid providers in their first year of demonstrating meaningful use report on 90 days

• All providers must use EHR technology certified to 2015 Edition for a full calendar year for 2018 EHR reporting period

• Providers choosing option to attest to Stage 3 in 2017 MUST have 2015 CEHRT

Stage 3 Objectives

2016 CQM Reporting Options:

• Submit though Medicare attestation

• Submit through PQRS Portal Medicare

• Submit individual through PQRS Portal

• Submit group through PQRS Portal

• Report group through ACO

Quality Programs

• Submit through Medicaid attestation Medicaid

CQM Requirements for 2016 Dual EH & CAHs

• Option 1: Attest to 16 of 29 possible CQMs through the EHR

Registration & Attestation System

• Option 2: eReport 4 CQMs through Hospital Inpatient Quality Reporting (IQR) through QualityNet Secure Portal

• Note: The CQM reporting options for EPs and hospitals in 2016 are the same as the options that were available in 2015. Medicaid-only hospitals report their CQMs via their state's portal.

• For more information on the 2016 program requirements and clinical quality measures, visit the 2015 CQM Reporting Options page on the CMS EHR Incentive Programs website.

Medicare EHR Incentives

Payment Amount

First Payment 2011

First Payment 2012

First Payment 2013

First Payment 2014

2011 $18,000

2012 $12,000 $18,000

2013 $7,840 Reduction ($160)

$11,760 Reduction ($240)

$14,700 Reduction ($300)

2014 $3,920 Reduction ($80)

$7,840 Reduction ($160)

$11,760 Reduction ($240)

$11,760 Reduction ($240)

2015 $1,960 Reduction ($40)

$3,920 Reduction ($80)

$7,840 Reduction ($160)

$7,840 Reduction ($160)

2016 $1,960 Reduction ($40)

$3,920 Reduction ($80)

$3,920 Reduction ($80)

Total Incentive Payments

$43,720 $43,720 $38,220 $23,520

Medicaid EHR Incentives

2018 Payment Adjustments Based on 2016 Eps Participation

Medicare EHR Incentive Program

–3% penalty based on participation in 2016

PQRS

–2% penalty based on participation in 2016

Value Based Payment Modifier (VM)

Mandatory quality-tiering for PQRS reporters

• Groups 2-9 EPs and solo physicians will see +/-2% adjustment based on quality-tiering

• Groups with 10+ EPs will see +/-4% adjustment

• Non-PQRS reporters will see automatic 2% penalty unless in group of 10+ and they will see 4% penalty

2018 Payment Adjustments Based on 2016 participation – EH/CAH

2016 – Prepare for MIPS

• Attest to Meaningful Use (MU)

• Submit Physician Quality Reporting System (PQRS)

• Review and Understand your Quality Resource and Use Reports (QRURs)

• Understand Implications of non-participation in CMS’ Quality Programs on your PRACTICE REVENUE

Thank you!

Questions?

Kentucky Medicaid EHR Incentive Program

You can find more information about the Kentucky Medicaid EHR

Incentive Program at http://chfs.ky.gov/dms/ehr.htm

For all other EHR questions, please send a note to the

CHFS DMS EHR Incentive Program Mailbox

EHR Information Center Help Desk

• (888) 734-6433 / TTY (888) 734-6563

• Hours:Monday-Friday 8:30 a.m.–4:30 p.m. in all time zones (Except Federal

holidays)

NPPES Help Desk

• Visit https://nppes.cms.hhs.gov/NPPES/Welcome.do

• (800) 465-3203 - TTY (800) 692-2326

PECOS Help Desk

• Visit https://pecos.cms.hhs.gov/

• (866)484-8049 / TTY (866)523-4759

Identification & Access Management System (I&A) Help Desk

• PECOS External User Services (EUS) Help Desk Phone: 1-866-484-8049

• TTY 1-866-523-4759

• E-mail: EUSSupport@cgi.com

Additional information available on new 2015 Program Requirements page:

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/indextml

CMS Help Desks

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Contact us by Phone: 859-323-3090

Connect with Kentucky REC!

LUNCH & PANEL DISCUSSION

Optimizing Your Practice for MU, PQRS, and MACRA Success

Facilitator: Polly Mullins-Bentley Panelists: Lynn Grigsby-Tiller: Kentucky REC Margie Banse: QSource Carla Cooper: Kentucky DMS Jennifer NeSmith: Kentucky Health Center Control Network

Brent McKune, CHPS, CPHIMS

Project Manager, Kentucky REC

HIPAA Scan

Agenda

• Why a Security Risk Analysis should be conducted and/or reviewed on an annual basis

• Review the National Institute of Standards and Technology (NIST) and OCR’s recommended steps to conducting a thorough Security Risk Analysis

• Best practices and tactics to reduce breaches in your organization

Definitions • Business Associates (BA) - A person or entity, other than a member of the workforce of a

covered entity, who performs functions or activities on behalf of, or provides certain services to, a covered entity that involve access by the business associate to protected health information.

• Business Associates Agreement (BAA) - A covered entity’s contract or other written arrangement with its business associate must contain that describes the permitted and required uses of protected health information by the business associate.

• Code of Federal Regulations (CFR) - The codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the federal government of the United States.

• Covered Entity (CE) - Defined in the HIPAA rules as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with transactions for which HHS has adopted standards.

• Electronic- Protected Health Information (e-PHI) - Any protected health information (PHI) that is covered under Health Insurance Portability and Accountability Act of 1996 (HIPAA) security regulations and is produced, saved, transferred or received in an electronic form.

• Health Insurance Portability and Accountability Act (HIPAA) - is the federal Health Insurance Portability and Accountability Act of 1996. The primary goal of the law is to make it easier for people to keep health insurance, protect the confidentiality and security of healthcare information and help the healthcare industry control administrative costs.

• National Institute of Standards and Technology (NIST) - a federal technology agency that works with industry to develop and apply technology, measurements, and standards

Definitions • Security Rule - The HIPAA Security Rule establishes national standards to protect

individuals’ electronic personal health information that is created, received, used, or maintained by a covered entity. The Security Rule requires appropriate administrative, physical and technical safeguards to ensure the confidentiality, integrity, and security of electronic protected health information.

• Security Risk Analysis (SRA) – the process of identifying the risks to system security and determining the likelihood of occurrence, the resulting impact, and the additional safeguards that mitigate this impact.

• Privacy Rule - The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients’ rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.

• Protected Health Information (PHI) - Any information about health status, provision of health care, or payment for health care that can be linked to a

Evolution of HIPAA

1996 HIPAA was enacted

2005 Security Rule

2013 Omnibus

2009 HITECH

2003 Privacy Rule

Security Risk Analysis Overview

Reasons to Complete a Security Risk Analysis

HIPAA Security

Rule

Performing a Security Risk Analysis

How often should I conduct a security risk analysis?

Security Risk Analysis Beneficiaries

Patients

Business Associates

Covered Entities

Security Risk Analysis Steps

The National Institute of Standards and Technology (NIST) recommends a 9 step

methodology approach to conducting a security risk assessment

Risk Analysis Steps

Step 9: Results Documentation

Step 8: Control Recommendations

Step 7: Risk Determination

Step 6: Impact Analysis

Step 5: Likelihood Determination

Step 4: Control Analysis

Step 3: Vulnerability Identification

Step 2: Threat Identification

Step 1: System Characterization

What does compliance look like?

Is compliance one size fits all?

Approaches for Conducting a Security Risk Analysis

Mitigating Risks

Should I mitigate all risks?

OCR Settlement Highlights

• Cancer Care Group ($750,000 settlement, August 31, 2015) – OCR found widespread non-compliance, and lack of policies, after

laptop bag with unencrypted media exposed records of 55,000 patients

• Feinstein Institute for Medical Research (research institute organized as NY non-profit corporation ($3.9M settlement and substantial corrective action plan, March 17, 2016) – Laptop computer with ePHI of approx.13K patients stolen from

employee’s car

• Raleigh Orthopedic – ($750,000 settlement, April 14, 2016) – For providing PHI for 17,300 patients to potential business partner

without first executing a BAA

• St. Joseph Health – ($2,140,500 settlement, October 17, 2016) – Unrestricted access to PDF files containing ePHI of 31,800 individuals

Audits and Preparation

Kentucky REC Can Help!

• Kentucky REC offers the following services performed by AHIMA Certified HIPAA Privacy & Security professionals:

– Security Risk Analysis addressing HITECH requirements for Meaningful Use

– Review of Administrative, Technical & Physical safeguards

– Remediation plan and timeline to eliminate or mitigate identified gaps

– HIPAA compliant sample policies

– Breach Notification

Thank you!

Questions?

Robin Huffman

Kentucky Regional Extension Center

Getting Ready for Practice

Transformation

Providers will receive a MIPS final score based on 4 weighted performance categories:

MIPS

Final

Score

0-100

Quality

Cost

Advancing

Care

Information

Improvement

activities

How will MIPS measure performance?

CY19 60% 0% 15% 25%

CY20 50% 10% 15% 25%

CY21 30% 30% 15% 25%

Improvement Activities

Expanded Practice Access

Population Management

Care Coordination

Beneficiary Engagement

Patient Safety and Practice Assessment

Participation in an APM, including a medical home model

Achieving Health Equity

Emergency Preparedness and Response

Integrated Behavioral and Mental Health

PCMH/PCSP Certification = Full Points for Category

“The Gold Standard” for Primary Care Transformation

A journey of a thousand miles begins with a single step…

Meaningful Use

Care Delivery Innovation (PCMH)

Payment Innovation

Health IT & HIE + Quality Improvement

PCMH is a model that provides specific standards for transforming the organization and delivery of primary care to be more:

Comprehensive Patient-Centered Coordinated Accessible Safe

PCMH: A Roadmap

Patient-Centered Medical Neighborhood

Patient-Centered Specialty Practice • An innovative program for improving specialty

care.

• Organizes care around patients

• Promotes team based care

• Coordinating and tracking care over time with primary care and other specialists

• Improve quality

• Reduce redundancies and negative patient experiences

• Proactive coordination

• Patient centered

• Encourages the use of health information technology

• Meaningful Use Alignment

Benefits of a PCMH

• Long-term partnerships, not hurried visits

• Care that is coordinated among providers

• Better access

• Shared decision-making with patients

• Reduced cost of care

• Decreased ER visits, hospitalizations

• More satisfied providers and patients

Benefits of PCSP

• Effective care coordination • Greater efficiency • Improved patient safety

• Readiness for a delivery/reimbursement model that

focuses on outcomes and reduced duplication of services. • Promoting a practice’s suitability for newly proposed

physician delivery and payment models.

PCMH Recognition

For outpatient primary care

Practice-site level

Recognizes PCPs at the site, including NPs and PAs who can be designated as a personal clinician

3-year Recognition period

Practice may add/remove clinicians

Who is eligible for PCMH Recognition?

• Recognized Practices: • Internal Medicine • Family Medicine • Pediatrics

• Recognized Providers: • Physicians (MD or DO) • APRNs • PAs

PCSP Recognition

Practice-based evaluation for clinicians who provide care in non-primary care specialties

Recognizes eligible specialty clinicians at the practice

NCQA defines a practice as one or more clinicians who practice together and provide patient care at a single geographic location.

3-year Recognition period

Practice may add/remove clinicians

Who is eligible for PCSP Recognition?

• Recognized Practices: • Non-primary care specialties

• Recognized Providers: • Physicians (MD or DO) • APRNs • PAs • Certified Midwives • Behavioral Health Practitioners

• Doctoral or Master’s-level (state certified or licensed): • Psychologists • Social workers • Marriage and family counselors

Who is not eligible for PCSP?

• Chiropractors, Optometrists, Podiatrists are not eligible for the PCSP program.

• Primary care clinicians who are eligible for NCQA PCMH Recognition are not eligible for NCQA PCSP Recognition.

• All clinicians who do not share or have their own panel of patients.

NCQA PCMH 2014 Standards

Standard 1. Enhance Access and Continuity

Standard 2. Team-Based Care

Standard 3. Population Management

Standard 4. Plan and Manage Care

Standard 5. Track and Coordinate Care

Standard 6. Measure and Improve Performance

NCQA PCSP 2016 Standards

Standard 1: Working with Primary Care and Other Referring Clinicians

Standard 2: Provide Access and Communication

Standard 3: Identify and Coordinate Patient Populations

Standard 4: Plan and Manage Care

Standard 5: Track and Coordinate Care

Standard 6: Measure and Improve Performance

Scoring Components

PCMH 2014 Recognition 6 Standards 27 Elements 178 Factors*

*Factors are the scored items within an element.

• 6 Must-Pass Elements – Most important aspects of PCMH

• Critical Factors

– Required to receive at least some (if any) points

PCSP 2016 Recognition 6 Standards 26 Elements 164 Factors*

*Factors are the scored items within an element. • 6 Must-Pass Elements

– Most important aspects of PCSP

• Critical Factors – Required to receive at least some (if

any) points

Levels of Recognition

• 3 levels of NCQA PCMH Recognition • Each level reflects the degree to which a practice meets the requirements • Allows practices with a range of capabilities to meet the requirements

successfully

PCMH Recognition PCSP Recognition

Recognition Levels Required Points

Level 3 85 – 100 points

Level 2 60 – 84 points

Level 1 35 – 59 points

Recognition Levels Required Points

Level 3 75 – 100 points

Level 2 50 – 74 points

Level 1 25 – 49 points

A look at the numbers…

PCMH Recognition

In Kentucky:

• 880 Clinicians/Sites

In the US:

• 67,652 Clinicians/Sites

PCSP Recognition

In Kentucky:

• 10 Clinicians/Sites – 2 Sites

– 8 Clinicians

In the US:

• 1,467 Clinicians/Sites

Why Become a PCMH or PCSP? What’s in it for the practice?

Big Picture Payment Reform

Incentives Competition

Why Become a PCMH or PCSP? What’s in it for the provider?

Maximizing the Use of My Skills

Experiencing Satisfaction

from Positive Patient

Interaction

Enjoying Greater

Efficiency in My Job

Why Now?

In order to earn full credit for IA you will need to have recognition for 3 months in 2017.

You should submit for recognition by July 31st, 2017 to meet this requirement.

IA Credit The PCMH 2014

Standards are expiring!

PCMH 2017 comes out March 2017. NCQA is expected to once again raise the bar for recognition.

PCMH 2014

Strategies for Success

Set Direction

Mission

Vision

Strategy

Develop a Realistic Plan

Form a Team

Physician Lead

Practice Manager

Administrative Lead

Clinical Lead (i.e. LPN, MA, care coordinator, etc.)

Develop a Communication Plan

Staff

Providers

Patients

Devote Resources

Protected Time

Financial Resources

Data

Technology

Staffing

Engage Physicians

Create Segmented Plans

Be wise in their involvement

Respect their time

Important Dates

3/31/17

• Last day to purchase PCMH 2014 survey licenses • Redesigned process and 2017 standards become available

5/31/17 • Last day to submit PCMH 2014 Corporate Survey

6/30/17 • Last day to request PCMH 2014 Add-On Surveys

7/31/17 • Last day to submit PCMH 2014 Corporate Add-On Tools

9/30/17 • Last day to submit all PCMH 2014 Site Surveys

Thank you!

Questions?