Preparing Your Practice for the Merit-Based Incentive ... · PDF filetied to a single Tax...

Healthcare Management ConsultingPresents:

Healthcare Management Consulting, LLCEHR · Revenue Cycle · Quality & Compliance Programs · Coding · Billing

Belinda Holmes, BS, CPC, CCP-P

Preparing Your Practice for the Merit-Based Incentive Program

(MIPS)

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Healthcare Management ConsultingAbout Us:



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MIPS & MACRA Compliance Strategies

EMR System Implementation & Configuration

Documentation Templates Billing & Operational

Analysis Presentations & Training

Chart Auditing & Coding RAC & Payor Audit

Defense Revenue Cycle & A/R

Management Security Risk

Assessments Acquisitions, Mergers &

Start-Ups

HMC takes care of your Practice, so you can take care of your Patients. We can help streamline your business:

Our passion is closing the gap between technology and clinical practice so doctors can focus on caring for their patients while increasing revenues and meeting quality standards. The HMC team

helps Practices customize their EMR and use automation to maximize reporting and reimbursement, while reducing “clicks” and administrative burdens.

Healthcare Management ConsultingSpeaker Bio:



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Belinda is the founder and owner of Healthcare ManagementConsulting. She is a Healthcare Executive with over 25 years’ experiencein healthcare; with fifteen years on the Florida Suncoast. Belinda hashelped hundreds of practices, large and small, through their start-upphase, rescued and re-engineered billing departments, modernizedclinical and administrative operations, and successfully defended medicalproviders from every type of audit. As a Certified Coder and ComplianceOfficer, and former auditor with the Department of Health and Hospitals,she also brings a unique perspective to compliance, auditing, billing,coding, and quality programs.

CPC = Certified Professional Coder

CCP = Certified Compliance Professional

Where we have been:



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Meaningful Use bonusescould be obtained by doing the minimum.

Quality reporting could be low and still meet standards.

Where We Are Going



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In 2015, Congress approved the Medicare Access and CHIP Reauthorization Act (MACRA).

Repeals Medicare Part B Sustainable Growth Rate (SGR) reimbursement program.

Separate payment adjustments under PQRS, VM, and EHR-MU sunset based on 2016 reporting.

January 1, 2017 – Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) reporting begins.

Where We Are Going



Based on the MIPS score, Medicare providers may receive an upward payment adjustment, a downward payment adjustment, or no payment adjustment.

Doing the minimum will NO longer work; penalties are now assessed

WHAT is reported and ADHERANCE to QUALITY GUIDELINES is now more important than just simply reporting something

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Where We Are Going



Eligible Professionals (EPs) can

participate in MIPS or qualifying

Alternative Payment Models (APMs)

MIPS – Can receive positive, negative or

zero payment adjustment (budget

neutral).

APM Participant – If criteria are met, can

receive 5 percent incentive payment per

year for 6 years.

Implementation: The Basics



2017 MIPS eligible providers include:

• Physicians

• MD, DO, DPM, OD, DDS, DMD, DC

• Physician Assistants

• Nurse Practitioners

• Clinical Nurse Specialists

• Nurse Anesthetists

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2019 MIPS-eligible providers added:

• Physical and occupational therapists

• Speech-language pathologists

• Audiologists

• Nurse midwives

• Clinical social workers

• Clinical psychologists

• Dietitians and nutrition professionals

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Only a few exceptions:

APM participants

Less than $30,000 in Medicare

charges and less than 100 Medicare

patients

First time Medicare Part B provider

during a performance year

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Implementation: APMs



2017 Advanced APMs:

• Comprehensive ESRD Care (CEC)

• Comprehensive Primary Care Plus (CPC+)

• Next Generation ACO Model

• Shared Savings Program - Track 2 or 3

• Oncology Care Model (OCM)

• Comprehensive Care for Joint

Replacement (CJR) Payment Model

• Vermont Medicare ACO Initiative

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MIPS: The Bottom Line



Maximum MIPS payment adjustment starts at +/-4% in 2019 (based on 2017 reporting).

Medicare payments are based on provider’s total score with +/-9% baseline adjustment factor by 2022.

Exceptional performers can receive up to +10% additional performance bonus (119%-127% of Medicare) by 2022.

MIPS is designed to be budget-neutral (incentives vs. penalties).

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For each performance year CMS sets a performance threshold (PT)

Number of points at which providers receive a 0% adjustment to their Medicare Part B payments.

Each incremental point earned above the PT results in progressively higher incentives

Each point below the threshold, results in a proportional penalty until a floor is reached.

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Four tracks for 2017:

• Do Not Participate = -4%

• TEST - Minimum Data ≤ 90 days = 0%

• PARTIAL YEAR – Submit minimum data requirements >90 days = 0% to small +%

• FULL YEAR –Submit required data, plus possible bonus data all year = 0% to +12% (more than 70 pts earned)

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MIPS: Reporting Options



Individual - An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number.

Send individual data for each of the MIPS categories through an electronic health record, registry, or a qualified clinical data registry. May also send in quality data through routine Medicare claims process.

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Group - Group is defined as a set of clinicians sharing a common TIN, no matter the specialty or practice site.

Will send in group-level data for each of the MIPS categories through CMS web interface EHR, registry, or a QCDR. To submit data through CMS web interface, must register as a group by June 30, 2017. Otherwise do not have to pre-register as GPRO.

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Manual – Identify the patient population for each measure selected

• Staff manually key in each patient’s information and measure results into a registry for each measure

Automated – Use measures certified within the EHR software

• Configure EHR and train staff to complete structured data for electronic reporting

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The Components of MIPS



The Merit-Based Incentive Payment System

(MIPS) annually generates a score out of 100

points for Medicare Part B providers using:




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Components of the MIPS Score 2017- Year 1

MIPS 0 - 100 points

Quality Measure Reporting

MU-Advancing Care Information

Clinical Practice Improvement

Cost-Calculated but not assessed in 2017

60% 25% 15% 0%




QUALITY

• 60% of total score in year 1 -

combines PQRS, CQMs and VBM):

• Clinicians choose at least six

measures to report on > 50% of

all qualified Medicare patients

• Include at least one high priority

measure

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QUALITY

• There are almost 300 Quality

Measures to choose from

• Specialty Measure Sets available

• Select by reporting method

• Each measure applies to a specific

patient population

• No more Measure Groups 22




QUALITY SCORING

• Performance Score: 60-70 points depending on

group size

• Each measure worth 3-10 points

• Bonus points are available for reporting

additional measures in certain categories

• Category score calculated by summing point

value for all activities and dividing by the highest

potential score of 60 or 70 points

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ADVANCING CARE INFORMATION

(25 percent of total score in year 1; replaces MU2):

• Must use certified EHR technology (CEHRT 2014 or

above

• Report on customizable measures that reflect how

they use electronic health record (EHR) technology

• Emphasis on interoperability and information

exchange.

• Does not require all-or-nothing EHR measurement

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• Fulfill the required measures for a

minimum of 90 days:

• Security Risk Analysis

• e-Prescribing

• Provide Patient (Portal) Access

• Send Summary of Care

• Request/Accept Summary of Care

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• Choose to submit up to 9 measures for a

minimum of 90 days for additional credit.

• For bonus credit, you can:

• Report Public Health and Clinical Data

Registry Reporting measures

• Use (2014+) certified EHR technology to

complete certain improvement

performance activities

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ADVANCING CARE SCORING

• Performance Score: Up to 80 points towards

the total ACI score (note: ACI score can exceed

100 points, but anyone who score 100 points

or above will receive the maximum 25 points

towards the MIPS score).

• Clinicians select measures that best fit their

practice

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ADVANCING CARE SCORING

• Public Health Registry Bonus Point:

Immunization registry reporting is

required. In addition, clinicians may

choose to report on more than one

public health registry, and will receive

one additional point for reporting

beyond the immunization category.

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Advancing Care Information



Total Score: Base, performance, and bonus point(s)

added for total of up to 131 points. If >100 points,

receive full 25 points in ACI category. If <100

points, total MIPS score declines proportionately

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CLINICAL PRACTICE IMPROVEMENT

(15 percent of total score in year 1):

• Clinicians rewarded for clinical practice

improvement activities focused on care coordination,

beneficiary engagement, and patient safety.

• Clinicians may select activities that match their

practices’ goals from a list of more than 90 options.

• In addition, clinicians would receive credit for

participating in APMs and in PCMH.

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CLINICAL PRACTICE IMPROVEMENT

• Complete up to 4 improvement

activities for a minimum of 90 days

• Groups with fewer than 15

participants or if you are in a HPSA:

Attest that you completed up to 2

activities for a minimum of 90 days

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CLINICAL IMPROVEMENT SCORING

• Maximum total points in CPI category = 60pts

• Score determined by weighting activities

• Highly weighted activities = 20 points

• Other activities = 10 points.

• Highly weighted activities examples = PCMH,

collection and follow-up on patient experience, or

seeing Medicaid patients in a timely manner.

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COST

(10 percent of total score in year 1; replaces the cost

component of the Value Modifier Program, also

known as Resource Use):

• The score would be based on Medicare claims,

meaning no reporting requirements for clinicians.

• This category would use more than 40 episode-

specific measures to account for differences among

specialties (In line with HEDIS).

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COST

• Each cost measure = 10 points.

• Min. 20 patients per measure to be scored

• Based on average score of all cost measures

• If not enough patient volume for a cost measure,

then a cost score is not calculated.

• Then reweight the cost category to zero, and adjust

the other MIPS performance category scores to

make up the difference in the MIPS score.

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MIPS Final Rule: Who’s In, Who’s Out, and Who Cares? By Martie Ross on October 20, 2016




Four tracks for 2017:

DO NOT PARTICIPATE = -4%

TEST – Earn 3 Points > 90 days = 0%

• Report at least one quality measure

• At least one improvement activity

• Or all five base measures in the ACI

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QUALIFY FOR BONUS: >90 day reporting

• Quality – more than 1 Measure or report Specialty set, bonus for additional Measures

• ACI – At least 5 base Measures, bonus for clinical registries and addtl Measures

• CIA – 2 to 4 Improvement Activities (based on size)

• COST – Evaluated only in 201737




MAXIMUM BONUS: >90 day reporting

• Quality – at least 6 Measures or Specialty set, bonus for additional Measures

• ACI – At least 5 base Measures, bonus for clinical registries and addtl Measures

• CIA – 2 to 4 Improvement Activities (based on size)

• COST – Evaluated only in 2017

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Exceptional performers who achieve a MIPS Composite Performance Score of at least 70 out of 100 will be eligible for an additional positive adjustment from a bonus pool of $500 million.

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MIPS Summary



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Maximum Incentives and Penalties

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YearMax

Penalty

Max

Increase$$ Penalty $$ Increase

2016/2018 -7% +4% -$35,000 +$20,000

2017/2019 -4% +12% -$20,000 +$60,000

2018/2020 -5% +15% -$25,000 +$75,000

2019/2021 -7% +21% -$35,000 +$105,000

2020/2022 -9% +27% -$45,000 +$135,000

Total -$160,000 +$395,000

*1 d

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$4

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in M

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MIPS Scores will be publicly reported for consumer knowledge.

Every provider's MIPS score will appear on the Physician Compare website.

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Why MIPSPreparation Matters



Physician Compare Website to add the following 2016 VM information to the database in 2018:

Quality tiers for cost and quality noting if the group practice or EP is high, low, or neutral on cost and quality per the VM.

A notation of the payment adjustment received based on the cost and quality tiers

An indication if the individual EP or group practice was eligible to but did not report quality measures to CMS.

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How This Affects YourPractice



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MEANINGFUL USE DOES NOT GO AWAY!

PQRS and CQMs are combined

OUTCOMES are measured and rewarded

Cost of care is assessed and evaluated

Full Year Reporting to earn bonuses

The Future of Healthcare Reimbursement



Electronic Medical Records

+ Higher Quality/Outcomes

+ Provider Coordination

+ Cost Containment____

= Greater Profit45




You need to start NOW:

The 2019 payment adjustment

schedule will be based on the 2017

performance metrics.

Provider performance in 2017 will

be measured on the MIPS model

and impacts payments in 2019.

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MIPS: WHAT TO DO RIGHT NOW



Use EMR CEHRT certified 2014 or later

Build STRUCTURED patient data collection into your system

“Fill in the boxes”

Align workflows to provide accurate and efficient data collection and reporting

Customize the EMR to suit your Practice

CALL US FOR HELP!47

Healthcare Management Consulting



Mention you saw us at FPMA and get 25% off our MIPS

Implementation Package or 10% off any other service.

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Healthcare Management Consulting



Belinda Holmes, BS, CPC, [email protected]

(941) 378-8800hmcexperts.com

“Transforming Practices for the Future of Healthcare.”

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Preparing Your Practice for the Merit-Based Incentive ... · PDF filetied to a single Tax...

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