1. Quality Payment Program Robin Huffman & Kelly Fountain The information contained in this presentation is for general information purposes only. The information is provided by UK HealthCare’s Kentucky Regional Extension Center and while we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to content.

2. Kentucky Regional Extension Center Services
UK’s Kentucky REC is a trusted advisor and partner to healthcare organizations, supplying expert guidance to maximize quality, outcomes and financial performance.
To date, the Kentucky REC’s activities include:
Helping bring over $100 million incentive dollars to providers throughout the Commonwealth
Assisting more than 3,400 individual providers across Kentucky, including primary care providers and specialists
Helping more than 95% of the Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) within Kentucky
Working with more than 1/3 of all Kentucky hospitals
Supporting dozens of practices and multiple health systems with practice transformation and preparation for value based payment
Physician Services
Meaningful Use & Mock Audit
HIPAA Security Risk Analysis & Project Management
Patient Centered Medical Home (PCMH) Consulting
Patient Centered Specialty Practice (PCSP) Consulting
Value Based Payment & MACRA Support
Hospital Services
Meaningful Use
HIPAA Security Analysis
Electronic Quality Reporting Support
REC Service Lines
Kentucky REC Description
Trudi

3. Overview QPP & Eligibility
Objectives
Overview QPP & Eligibility
MIPS Track
APM/MIPS APM Track

4. MACRA: Quality Payment Program
APM
MIPS
Merit-based Incentive Payment System
Alternative Payment Models

5. New 2017 Reporting Options Option 1: Test Submission
Option 2: Partial Submission
Option 3: Full Submission
Option 4: Advanced APM Participation
QPP

6. Recommended QPP Options
Never Submitted PQRS/MU
MIPS Option 1: Test the QPP
MIPS Option 2: Participate for Partial Year
Limited Success with Submitting PQRS/MU
MIPS Option 3: Participate for Full Year
Successfully Submitted PQRS/MU
Option 4: Participate in APM

7. Clinical Nurse Specialists
Eligible Clinicians
Clinicians billing more than $30,000 a year in Medicare Part B allowed charges and providing care for more than 100 Medicare patients a year. These clinicians include:
BILLING
> $30,000
> 100
AND
Physicians
Physician Assistants
Nurse Practitioners
Clinical Nurse Specialists
CRNA

8. Who is Exempt from MIPS? Significantly participating in Advanced APMs
Newly enrolled in Medicare
- Enrolled in Medicare for the first time during the performance period (exempt until following performance year)
Below the low-volume threshold
- Medicare Part B allowed charges less than or equal to $30,000/year; or
- See 100 or fewer Medicare Part B patients/year
Significantly participating in Advanced APMs
- Receive 25% of their Medicare payments; or
- See 20% of their Medicare patients through an Advanced APM
Clinicians who are

9. Eligibility for Clinicians in Specific Facilities
Rural Health Clinics (RHC) and Federally Qualified Health Centers (FQHC)
Eligible clinicians billing under the RHC or FQHC payment methodologies are not subject to the MIPS payment adjustment.
However….
Eligible clinicians in a RHC or FQHC billing under the Physician Fee Schedule (PFS) are required to participate in MIPS and are subject to a payment adjustment.

10. Eligibility Examples:
Provider A:
Provider B:
Billing 100,000
110 Patients
Eligible Clinician
Billing 100,000
82 Patients
Exempt

11. NPI Lookup Quick Checks: Go to: www.qpp.cms.gov
Type in every provider’s NPI.
Scroll down to confirm eligibility at Individual and TIN level.
Remember that a provider can be eligible multiple times.
When in doubt report at least a test!

12. Example 1:

13. Example 1:
Dr. Jane Doe

14. If You Are Exempt…
You may choose to voluntarily submit quality data to CMS to prepare for future participation, but you will not qualify for a payment adjustment based on your 2017 performance.
This will help you hit the ground running when you are eligible for
payment adjustments in future years.

15. Special Considerations

16. Eligibility for Non-Patient Facing Clinicians
Non-patient facing clinicians are eligible to participate in MIPS as long as they exceed the low-volume threshold, are not newly enrolled, and are not a Qualifying APM Participant (QP) or Partial QP that elects not to report data to MIPS.
The non-patient facing MIPS-eligible clinician threshold for individual MIPS- eligible clinicians is < 100 patient facing encounters in a designated period.
A group is non-patient facing if > 75% of NPIs billing under the group’s TIN during a performance period are labeled as non-patient facing.
There are more flexible reporting requirements for non-patient facing clinicians.

17. MIPS Track

18. MIPS: 2017 Reporting Categories
Quality:
Improvement Activities:
ACI:
Cost:
PY 2017 = 60%
6 Measures are reported, except for:
Groups using CMS web interface report 15 quality measures
MIPS – APMS report via CMS web interface
1 outcome or High Priority measure
7th Measure based off of claims for large groups
PY 2017= 15%
Full points for:
Certified PCMH/PCSP
Medical Home Model
MIPS - APMS
APMS
40 points raw score required
PY 2017 = 25%
Replaces Medicare EHR Incentive Program
Flexible Scoring:
Base Score
Performance Score
Bonus
Reweighting for certain EC’s
Hardship(s)
PY 2017 = 0%
Score is based off of Medicare claims, including:
Measure 1: Spending per Beneficiary (MSPB)
Measure 2: Total costs per capita for all attributed beneficiaries
CMS is testing new condition measures

19. MIPS: 2017 Reporting Categories
Quality:
IA:
ACI:
Cost:
Reporting Range:
days
Reporting Range:
At least 90 days in program year
Reporting Range:
days
No reporting required.
However validation of QRUR data recommended
Must Submit by March 31st 2018

20. Year 1 Thresholds Already Set
0 Points =
Full 4% Penalty
3 Points Minimum Threshold =
No Penalty,
No Reward
Between 4-69 Points =
Some Bonus Possible
70+ =
Exceptional Performance
Split $500M Pool

21. Individual vs. Group Reporting
Options
Individual
Under a NPI number and TIN where they reassign benefits
Group
2 or more clinicians (NPIs) who have reassigned their billing rights to a single TIN*
As an APM Entity

22. Advancing Care Information
Submission Methods
Category
Individual
Group/TIN
Quality
Qualified Data Registry (QCDR)
Qualified Registry
EHR
Claims
QCDR
Administrative Claims
CMS Web Interface
CAHPS for MIPS Survey IA
Attestation
ACI
Advancing Care Information

23. Bonus Points Opportunities
Report an additional high priority measure for 1 point
Report an additional outcome measure for 2 bonus points
Use of End to End Electronic Submission for 1 bonus point
Total Quality Score= (Points earned on required # measures + Bonus points)/ Total weight
End to End Electronic Submission for 1 point
Report additional public health and clinical data registries beyond the Immunization Registry Reporting measure will result in a 5-point bonus to the raw score.
Total ACI = (Base Score + Performance Score + Bonus) x 0.25 = Category Score
IA CEHRT- Reporting “yes” to the completion of at least 1 of the specified Improvement Activities using CEHRT will result in a 10-point bonus in ACI raw score. Use Appendix B of the final rule and report at least 90 days during the reporting period.
Advancing Care Information
Improvement Activities
Quality

24. APM & MIPS APM Track

25. APM and MIPS APM Track
Alternative Payment Model (APM) is a payment approach that gives added incentive payments to provide high-quality and cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population.
Advanced APMs are a subset of APMs, and let practices earn more for taking on some risk related to their patients' outcomes. You may earn a 5% incentive payment by going further in improving patient care and taking on risk through an Advanced APM.

26. MIPS APMS 50% 0% 20% 30% Category Quality Cost IA ACI Weight
APM Entity Submission
Requirement
SSP ACOs submit quality measures to the CMS Web Interface
MIPS eligible clinicians will not be assessed on cost.
ACOs only need to report if the CMS-assigned IA scores is below the maximum IA score.
All ACO participant TINs in the ACO submit under this category according to the MIPS group reporting requirements.
Performance
Score
Will be used to determine the MIPS quality performance category score at the ACO level.
N/A
CMS will assign the same score to each APM Entity group based on the activities required of participants in the SSP.
All ACO participant TIN scores will be aggregated as a weighted average
based on the number of MIPS Ecs to yield one APM Entity group score.

27. Advanced Alternative Payment Models
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.
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:
MACRA does not change how any particular APM rewards value.
APM participants who are not “Qualifying Providers” (QPs) will receive favorable scoring under MIPS.

28. Qualifying APM Participants
Almost 100% of eligible clinicians in the following Advanced APMs will be Qualifying APM Participants (QP) based on performance year meaning that they will be eligible to receive a 5% APM Incentive Payment in An unauthenticated QP determination status lookup QP Lookup Tool is available for eligible clinicians to review.
There are approximately 75,000 NPIs included in this initial QP analysis. This assessment was completed using Medicare claims with dates of service between January 1, 2017 and March 31, that were processed between January 1, 2017 and June 30, and APM participation lists as of March 31, 2017.

29. Next Steps Determine Eligibility Determine Level TIN/NPI
Pick your Pace
Determine Submission Method(s)
Choose Measures to Monitor/Report
Report before March 31st 2018
Eligibility at all TIN/NPI Levels
TIN/NPI evaluate feasibility of current systems (pro vs. con)
Have a plan A and plan B
Timelines, depending on submission near term long term
Monitoring reports
Submit

30. Questions

31. Value-Based Payment Support Services
QPP SURS Technical Assistance: Free, high-level assistance for organizations with 15 or fewer eligible clinicians as they navigate the Quality Payment Program. The Resource Center include: straightforward, self-directed resources and tools, up-to-date materials, and access to expert Quality Improvement Advisors. Sign up:
VBP Individualized Assistance: months of planning and transformation support tailored to meet specific client needs and support success in value-based payment. This includes current state analysis, recommendations for action, collaborative goal setting and project planning, education, strategic decision support and ongoing advisory services.
Advanced APM Support (coming in 2018): Ongoing support, research, work plan development and application support for transition to advanced alternative payment models (APM).

32. Our Partnership with KPCA
VBP Individualized Assistance: 12 months of planning and transformation support tailored to meet specific client needs and support success in value-based payment. This includes current state analysis, recommendations for action, collaborative goal setting and project planning, education, strategic decision support and ongoing advisory services.
Designated Practice Transformation Advisor
Currently engaged with 24 practices across Kentucky
Next cohort –early 2018

33. Connect with Kentucky REC!
Follow us on Like us on Facebook: facebook.com/KentuckyREC Follow us on LinkedIn: linkedin.com/company/kentucky-rec Check out our Website: Call us: us: