THE APMA REGISTRY & MIPS

Dyane Tower, DPM, MPH, MS Chad Appel, JD Gail Reese, JD

Agenda • What is MIPS & Who is Eligible in 2018 • 2018 MIPS Performance Period & Scoring • Performance Categories

– Quality – Promoting Interoperability (PI, formerly ACI) – Improvement Activities (IA) – Cost

• APMA Registry • APMA Resources • Questions

Quality Payment Program (QPP) & MIPS Year 2

• Established in 2015 by MACRA • MACRA replaced the SGR • Two paths to participation –

– Advanced Alternative Payment Models (APMs) – Merit-Based Incentive Payment System (MIPS)

• Almost all podiatrists will participate via MIPS

MIPS Year 2 – Who is Excluded? • Excluded:

– EPs with: • ≤ $90,000 in Part B allowed charges OR • ≤ 200 Part B beneficiaries

– Newly Medicare-enrolled eligible clinicians – Qualifying APM Participants (QPs) – Certain Partial Qualifying APM Participants (Partial

QPs)

MIPS Year 2 – Who is Excluded? • Clinicians affected by Harvey, Irma, Maria can

file a hardship exemption for 2018 reporting period for Quality, PI, and IA

• This exception was automatic for such clinicians in 2017, but you will need to file a proactive request for the hardship in 2018

MIPS Year 2 – Who is Eligible? Check your doctor’s participation status by going to:

https://qpp.cms.gov/participation-lookup

2018 MIPS Performance Period • The performance period started on 1/1/2018

– Quality = 365 days – PI (formerly ACI) = 90 days – IA = 90 days – Cost = 365 days

• Reporting for the 2018 performance period will start on 1/1/2019

• Payment adjustments for the 2018 performance period will start on 1/1/2020

2018 MIPS Scoring • Highest total score is 100 points • Eligible physicians (EPs) will receive either a

positive, negative, or neutral payment adjustment in 2020 to their Medicare Part B fee schedule payments based on their MIPS score

-5% up to +5%

Future MIPS Adjustments • 2021: -7% to +7% (based on 2019 score) • 2022 : -9% to +9% (based on 2020 score)

*Note – the negative adjustments are a flat, guaranteed reduction. The positive adjustments are budget neutral in coordination with the total amount of negative adjustments.

2018 MIPS Scoring – Practices with More than 15 EPs

• Performance Category weights for MIPS Final Score: – Quality – 50% – PI (ACI) – 25% – IA – 15% – Cost – 10%

2018 MIPS Scoring – Practices with 15 or Fewer EPs

• Practice eligible for the PI category exception* • Reweights the performance categories:

– Quality = 75% – PI = 0% – IA = 15% – Cost 10%

* Your practice must proactively apply for this exception, when CMS opens the exception application, likely available in late August

2018 MIPS Scoring – Small Practice Bonus

• New for 2018 performance period • 5 MIPS points added to final score of any EP

or group that qualifies as a small practice (15 or fewer clinicians)

• In order to receive this bonus, the EP or group must submit data for at least one performance category

2018 MIPS Scoring – Minimum Score to Avoid a Penalty

Threshold for avoiding a penalty =

15 MIPS points

Your doctor can avoid this penalty by simply

reporting successfully for just the IA performance category - more on this later!

MIPS Performance Categories – Quality

• 50% or 75% weight depending on whether or not your practice qualified/applied for small practice exception

• Report up to SIX measures – One must be an outcome measure – If outcome measure not available, must report on

at least one high priority measure • All six must be reported by the same

mechanism

MIPS Performance Categories - Quality

New Podiatry Specialty Measure Set for 2018 NQF # Quality # Measure Name Submission Method Measure Type

0417 126 Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy

Registry Process

0416 127 Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention Evaluation of Footwear

Registry Process

0421 128 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan

Claims, Registry, EHR, Web Interface

Process

0101 154 Falls: Risk Assessment Claims, Registry Process

010 155 Falls: Plan of Care Claims, Registry Process

0028 226 Preventative Care and Screen: Tobacco Use: Screening and Cessation Intervention

Claims, Registry, EHR, Web Interface

Process

MIPS Performance Categories - Quality

• When choosing quality measures, keep in mind the following: – Check minimum case requirements

• Most minimum case requirements are 20

MIPS Performance Categories - Quality • Example of documentation for Quality measure #128 Preventive

Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan with claims:

Denominator • 18 or older • E&M

Numerator – Performance MET • G8420 - BMI is

documented within normal parameters and no follow-up plan is required

• G8417 - BMI is documented above normal parameters and a follow-up plan is documented

• BMI is documented below normal parameters and a follow-up plan is documented

Numerator – Performance NOT Met • G8421 - BMI not

documented and no reason is given

• G8419 - BMI documented outside normal parameters, no follow-up plan documented, no reason given

MIPS Performance Categories – Quality

www.apma.org/MIPS2018

MIPS Performance Categories – PI • Formerly the Advancing Care Information

(ACI) performance • 25% weight • Small practice exception available, will

reweight the performance category to 0% – This exception must be proactively applied for by

the practice in order to be exempt from this performance category

MIPS Performance Category – PI Reporting Options

2015 CEHRT Only OR

2014 + 2015 CEHRT • 5 required base measures • 10 additional optional

performance measures Additional 10 bonus points for using 2015 edition certified EHR exclusively

2014 CEHRT Only • 4 required base measures • 7 additional optional

performance measures

MIPS Performance Category – PI

www.apma.org/MIPS2018

MIPS Performance Category - IA • 15% weight • Avoid a penalty in 2020 by simply reporting

fully for this category!

MIPS Performance Category - IA • List of 112 options

– Medium weight = 10 points – High weight = 20 points

• Activities double weighted if solo practitioner or in a group of 15 or fewer

• Score = practice’s awarded points / 40

MIPS Performance Category - IA • Group of more than 15 clinicians:

– Choose 4 medium weight or 2 high weight activities; or

– Chose 1 high weight + 2 medium weight

• Group of 15 or fewer clinicians or solo: – Choose 2 medium weight or 1 high weight

activity(s)

MIPS Performance Category - IA • APMA has narrowed down the 112 options to just 19 for your doctor to

select from, found here, at www.apma.org/MIPS2018

• Recommended measures include: – Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real- Time

Access to Patient's Medical Record (HIGH) – Implementation of Use of Specialist Reports Back to Referring Clinician or

Group to Close Referral Loop (MEDIUM) – Regularly assess the patient experience of care through surveys, advisory

councils and/or other mechanisms (MEDIUM) – Consultation of the Prescription Drug Monitoring Program (HIGH)

MIPS Performance Category – Cost • 10% weight • No proactive action required AT ALL by your

doctor – CMS calculates measure performance based off

administrative claims data, using the following two measures:

• Total Per Capita Cost • Medicare Spending Per Beneficiary

MIPS Performance Category – Cost

Check out APMA’s MACRA Made Easy Webinar

The One Free, Easy-to-Use Portal for MIPS Reporting Every APMA member can use the APMA Registry to avoid a penalty. Follow these four steps: 1. Sign up to participate at www.apma.org/registry. 2. Complete the sign-up process, including the business

associate/data use agreement. 3. Identify measures/activities on which to report, and

perform them by December 31. 4. Submit attestations in Q1 of 2019.

What is the Registry? • A vehicle to collect, sort, and use data for multiple

purposes. • Data can be collected from individual providers and

groups and submitted to agencies, like CMS, on behalf of those providers.

• CMS allowed this submission method for the Physician Quality Reporting System (PQRS) and continues to allow it for the Merit-based Incentive Payment System (MIPS) in 2018 as directed under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Why you need the Registry • With a properly structured registry there is the

potential to demonstrate the value of services provided by podiatrists.

• We aim to allow members who provide data to the registry the ability to look at the mix of procedures and diagnoses they use and compare it against data provided by all registry participants.

• The registry may also serve as a resource for industry to request specific queries relating to products or services that our members perform or use.

What does the Registry look like?

https://apma-provider.rexdb.net

APMA MIPS Year 2 Resources www.apma.org/MIPS2018

APMA MIPS Year 2 Resources APMA MACRA Made Easy Webinar Series

www.apma.org/MACRAWebinars All past webinars and materials are posted online

Save the date! August 2, 2018 Webinar on 2019 MIPS If Proposed Rule released

Webinar Topic Date

2018 MIPS IA Category June 19, 2018

2018 MIPS Overview in 30 Minutes May 23, 2018

2018 MIPS Quality Measures Category May 2, 2018

2018 MIPS Cost Performance Category April 25, 2018

How to Avoid a 2020 Penalty for 2018 MIPS Reporting F February 12, 2018

MIPS Year 2 Final Rule November 30, 2017

Registry Reporting October 30, 2017

APMA MIPS Year 2 Resources – Coming Soon!

New MIPS Flowcharts Example – Flowcharts for Quality Measure #226 – there are three different submission criteria options

Questions? For follow-up questions and information on additional resources – contact the APMA Health Policy and Practice Department at healthpolicy.hpp@apma.org