Meaningful Use
MACRA
MIPS/APM
May 2016
• 960+ regulations
• Our understanding
• May not have everything correctly
• Stayed tuned, more webinars
Disclaimer
Public Comment
• Nothing changes in 2016 (maybe 90 days)
• PQRS, VBM, MU
• Comments accepted July 27,2016
• Final rule doesn’t usually change significantly
• Final rule not likely before 4th quarter 2016
• Proposed starting date January 1, 2017, payment adjustment
is 2 years later
• CMS Budget neutral
• Priority, BCBS and others are adopting similar programs
MACRA PROPOSED Rule
• Relates to Medicare Part B FFS
• RHC/FQHC ? (believe included)
• MACRA begins 2017
• 2017 Performance
• 2019 Payment adjustments
• 2017 Activity/2019 payment adjustments
• MIPS: +/- 4% Medicare FFS,
• +12% for “exceptional performance”
• APS: + 5% Medicare FFS
MACRA Financial Implications
JC
MACRA – Financial Summary
JC
MACRA Strategy
• Focusing on improving the way clinicians are paid to
incentivize quality and value of care over simply quantity of
services;
• Improving the way care is delivered by providing clinical
practice support, data and feedback reports to guide
improvement and better decision-making; and
• Making data more available and enabling the use of certified
EHR technology to support care delivery.
MACRA Strategy
JC
4 Main Terms
• MACRA: Medicare Access and CHIP Reauthorization Act
of 2015
• QPP: Quality Payment Program
• MIPS: Merit based Incentive Payment System
• APM: Advanced Alternative Payment Models
JC
Advanced Alternative Payment Models (APM)
Advanced APMs meet certain criteria
JC
APM, What is it?
JC
APM’s Criteria
JC
APM, How do I become Qualified
JC
APM, Medical Home Models
JC
MACRA: MIPS
Change from MU to MACRA/MIPS
MIPS – Payment Adjustment/Incentive
Outstanding Performance:
additional 3 times upper limit,
approximately top 10% of
country
Who Qualifies (MIPS)
• MU was only concerned about MD, DO, NP (some PA)
• MIPS
• Year 1:MD, DO, DMD, DDS, NP, PA, Clinical Nurse Specialist
and Certified Registered Nurse Anesthetists.
• Year 3+: add physical/occupational therapist, speech language
pathologist, audiologist, Nurse midwives, clinical social workers,
clinical psychologist, dietitians/nutrition professionals
• Medicare billing (Part B) under their own name.
Who Does NOT Qualifies (MIPS)
Current Medicare at Risk
-9%
-2%
+/-4%
-3%
Proposed Medicare at Risk
MIPS % in 2017/2019 Similar to Requires
Quality 50% PQRS Report on 6 measures
Resource Use
(Cost)
10% Cost CMS calculation from
claims data
Clinical Practice
Improvement
Activities
15% PCMH PCMH certification or
specific practice
activities
Advancing Care
Information
25% MU Eliminates all or nothing
threshold values *
MACRA/MIPS Composite Score
MIPS – Weight Changes Over Time
MIPS Composite Score
MIPS
MIPS - Quality
MIPS - Quality
• 50% of your score (will change over time)
• PQRS and VBM
• Compare yourself against the rest of providers
• Select those measures that count
• 9 (PQRS/VBM) in 2016
• 6 in 2017+ • Check what is certified for your EHR
Quality
• 9 measures, 2016 PQRS
• 6 measures, 2017+, MIPS
MIPS, ACI (old Meaningful Use)
MIPS ACI (it’s all about the score)
100 points maximum
MIPS, ACI, Base
MIPS, API, Base Score
• Base Score: 50 points • Base Score involves reporting the numerator (of at least one) and denominator for 6
objectives comprising 11 measures
• To receive the base score, clinicians must provide the numerator/denominator or yes/no for
each objective and measure. Only "yes" responses count
• No thresholds for the base score
• No more CPOE or Clinical Decision Support
• Security Risk Assessment (all or nothing), mitigation plan
Number Objective Measure
1. Protect Patient Health Information Security Risk Analysis
2. Electronic Prescribing ePrescribing
3. Patient Electronic Access a. Patient Access
b. Patient-Specific Education
4. Coordination of Care Through Patient Engagement a. View, Download or Transmit (VDT)
b. Secure Messaging
c. Patient-Generated Health Data
5. Health Information Exchange a. Patient Care Record Exchange
b. Request/Accept Patient Care Record
c. Clinical Information Reconciliation
6. Public Health and Clinical Data Registry Reporting Immunization Registry Reporting
(Optional) Syndromic Surveillance Reporting
(Optional) Electronic Case Reporting
(Optional) Electronic Case Reporting
(Optional) Public Health Registry Reporting
MIPS, API, Performance
MIPS, ACI, Performance Score
MIPS, ACI, Performance
• Performance Score: 80 points (50 points is all you
need)
• Based on 8 measures with 10% per measure
• Providers select the 8 measures that are best for
them, must report on all 8.
MIPS
MIPS – Clinical Improvement Process
JC
MIPS – Clinical Improvement Process
MIPS
MIPS - Cost
MIPS Summary
• 2016
• Monitor and improve MU performance %
• Identify and improve practice appropriate PQRS measures
• Evaluate ACO and PCMH opportunities
• Design Clinical Improvement Activities
• CEHRT upgrade strategy
• 2017
• Select MIPS or APM
• Monitor MU (ACI) performance
• Monitor and improve Quality Metrics
• Implement Clinical Improvement Activities
• Upgrade CEHRT to 2015 (MU 3) version
Recommended Strategies
JC
• 2016 and 2017
• Current CEHRT acceptable
• 2015 CERHT might be preferable
• ~=MU 3
• 2018
• 2015 CEHRT required
• ~=MU 3
Certified EHR Upgrade
MACRA Payment at Risk
• MACRA will eventually account for 10% of the
payment of the Medicare bill (expect to grow in the
future)
• Medicare ONLY (Priority, BCBS, etc. have similar
programs)
• Fee for service: 100% based on service
• Fee for service – 10% (not new money).
MACRA Big Picture
• Nothing changes for 2016 (maybe 90 days)
• MACRA/MIPS/APR Proposed Rule. Final in September
• Rule deals with “at risk payment” (value verses volume)
• All practices need a strategy for 2017 and beyond
• ~9% of Medicare fees
• Only applies to Medicare EP’s (not Medicaid)
• Payment adjustment 2 years later
• Budget Neutral
Proposed Medicare at Risk
(MU)
MACRA MIPS 2017/2019
2016/2018 MACRA Transition
• Proposed Rule
• MACRA strategy
• Financial
• MACRA/MIPS
• MACRA/APS
• Medicaid MU Incentive $
• CEHRT
• Recommended Strategies
MACRA Overview
Composite Score
• MIPS: 100 point scale known as Composite Performance
Score (CPS), 2017 performance/2019 payment
• Quality: 50 percent of total score
• Resource Use: 10 percent of total score
• Clinical Practice Improvement Activities (CPIA): 15 percent of total
score
• Advancing Care Information (formerly Meaningful Use): 25 percent
of total score