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MACRA and the New Quality Payment Program

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The Medicare Access and CHIP Reauthorization Act (MACRA) overhauls the payment system for Medicare providers. It’s a complex program that requires careful study so physicians can make the best choice for how they want to report. This choice ultimately impacts reimbursement and the potential bonuses or penalties associated with each reporting option.

This FAQ covers both tracks of the new rule, the Merit-based Incentive Payment System (MIPS), and the Advanced Alternative Payment Model (APM), with a background review and a comprehensive list of questions and answers.

It’s a practical guide complete with next steps for strategic and tactical planning.

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MACRA and the New Quality Payment Program

  1. 1. MACRA and the New Quality Payment Program: Most Frequently Asked Questions
  2. 2. © 2016 Health Catalyst Proprietary and Confidential Responses from webinar in May 2016 after release of proposed regulations Are we ready? 2 12% 23% 56% 8% 1% 0% 10% 20% 30% 40% 50% 60% Not at all Somewhat Unsure Ready Very Ready How ready are you to participate in MACRA?
  3. 3. © 2016 Health Catalyst Proprietary and Confidential • New rule on how Medicare pays doctors • Broader push to overhaul Federal health spending • New bonus and penalties tied to performance • Anne Phelps, U. S. healthcare regulatory director, Deloitte “It’s a disruptive law.” October 14- Wall Street Journal Article 3 Source: U.S. Officials Finalize Rule for Medicare Payment to Doctors Melanie Evans, Oct 14, 2016
  4. 4. © 2016 Health Catalyst Proprietary and Confidential (1)Support care improvement by focusing on better outcomes for patients, decreased provider burden, and preservation of independent clinical practice; (2) Promote adoption of alternative payment models that align incentives across healthcare stakeholders; (3) Advance existing efforts of Delivery System Reform, including ensuring a smooth transition to a new system that promotes high-quality, efficient care through unification of CMS legacy programs. Aims of Quality Payment Program 4
  5. 5. © 2016 Health Catalyst Proprietary and Confidential What is a good source? Qpp.cms.gov 5
  6. 6. © 2016 Health Catalyst Proprietary and Confidential Disruption signs New future New language New economics Source: Healthcare Disrupted, Jeff Elton and Anne O’Riordan Are we at a tipping point? 6
  7. 7. © 2016 Health Catalyst Proprietary and Confidential Two Tracks 7 2017 2019 2020 2018 .5% annual update thru 2019 Combine MU, PQRS, VBM 2018 MIPS APM QP 2019 Performance year +/- 5% 2021 2022 +/-4% +/- 7% +/- 9% 2017 Performance year 2023 20242020 2021 2022 2023 2024
  8. 8. © 2016 Health Catalyst Proprietary and Confidential Why is 2017 so important? Transition Year 8
  9. 9. © 2016 Health Catalyst Proprietary and Confidential CMS Expenditures 9 30% 28% 19% 11% 4% 4% 2% 2% 0% 5% 10% 15% 20% 25% 30% 35% Inpatient OP PAC Physician E&M Hospice Part B DME Ambulance 2014 Breakout of CMS Expenditures Source: Geographic variation file from CMS 89% of beneficiaries used E&M code 13,058 encounters per 1,000 beneficiaries
  10. 10. © 2016 Health Catalyst Proprietary and Confidential Potential for Bonus Points 10
  11. 11. © 2016 Health Catalyst Proprietary and Confidential • Removed for first year, weighted at 10% for 2020 • Based on per capita and 10 episodes Examples: Lens and cataract procedures Hip repair or replacements Knee arthroplasty • CMS will calculate from claims Cost Performance – Weighted 0% 11
  12. 12. © 2016 Health Catalyst Proprietary and Confidential Did you know this data is available? State with high spending 12
  13. 13. © 2016 Health Catalyst Proprietary and Confidential Reporting period will be annual - only see your results once a year First report due March 2018 First feedback report – August 2017 When do I need to report for 2017? 13
  14. 14. MIPS Merit-based Incentive Payment System
  15. 15. © 2016 Health Catalyst Proprietary and Confidential Status quo 15
  16. 16. © 2016 Health Catalyst Proprietary and Confidential Interesting Fact #1: A survey conducted in March, 2016 by Weill Cornell Medical College and the Medical Group Management Association (MGMA) found that physicians spend an average of ??? hours every week processing quality metrics.
  17. 17. © 2016 Health Catalyst Proprietary and Confidential Interesting Fact #2: The time physicians spend processing quality metrics translates to an average cost of $40,069 per physician, per year
  18. 18. © 2016 Health Catalyst Proprietary and Confidential MIPS combines 3 existing programs: EHR (MU) Incentive Program VBPM (Value Based Payment Modifier) PQRS (Physician Quality Reporting Program) And ADDS Clinical Practice Improvement Activities Between approximately 592,000 and 642,000 eligible clinicians will be required to participate in MIPS in its transition year. Practices with fewer than 15 providers and in rural areas may be qualified for technical assistance. Estimate of 14% providers will be low volume and excluded. CMS expects MIPS to evolve and change 18
  19. 19. © 2016 Health Catalyst Proprietary and Confidential19 The rule defines a group as a single Taxpayer Identification Number (TIN) with two or more MIPS eligible clinicians, as identified by their individual National Provider Identifier (NPI), who have reassigned their Medicare billing rights to the TIN.
  20. 20. © 2016 Health Catalyst Proprietary and Confidential Are you in the low volume threshold that is excluded? This is $30,000 in Part B charges OR less than or equal to 100 Medicare patients. Newly Medicare-enrolled EP’s are also excluded from reporting the first year. Or you are a QP (Qualified Provider) as part of an APM For MIPS do I need to report individually or as a group? 20 Are you part of the Exclusion Criteria?
  21. 21. © 2016 Health Catalyst Proprietary and Confidential Additional considerations for reporting as an individual or a group: 21 1. Do you report to other external agencies today with your TIN or NPI number? Do you participate in MU, PQRS or other reporting today? If so, review the performance and how successful you are. 2. The submission requirements for Groups and Individuals are different. You must participate in MIPS as a whole, either as a group or an individual; not mixed. Group reporting performance will be assessed and scored across the TIN and MIPS payment adjustments applied to the group level of the eligible clinicians in the group. 3. You can join virtual groups in the future years once CMS has determined that definition.
  22. 22. © 2016 Health Catalyst Proprietary and Confidential Composite Performance Score (CPS) 22 Area Weight in 2019 (Changes by year) Quality 60% Cost 0% Improvement activities 15% Advancing care information (Meaningful use of certified EHR technology) 25%
  23. 23. © 2016 Health Catalyst Proprietary and Confidential • Stay in the pit and get penalty • Try one lap • Try one lap for 90 days • Go for the entire race Pick your pace in 2017 23
  24. 24. © 2016 Health Catalyst Proprietary and Confidential Full vs Minimal Participation 24 Report on 6 quality measures OR 1 specialty- specific or subspecialty specific measure set one of those should be an outcome measure if available, if no outcome measure available then report on a high priority measure Report on 4 medium weighted activities OR 2 high weighted activities in the Improvement Activities performance category Report on 5 Advancing Care measures; additional measures for potential bonus3. Report on 1 quality measures if not a group submission; if a group submission via CMS Web Interface, more measures are required Report on 1 high weighted measure in the Improvement Activities performance category 3. Report on the 5 required Advancing Care measures 2. 1. 2. 1. 90 Days Minimal-Full Year And/Or And/Or
  25. 25. © 2016 Health Catalyst Proprietary and Confidential Neutral MIPS adjustment because the performance threshold is set at 3 points Scoring Minimal Participation for the first year 25 Individual A: Submits 1 Quality Measure, No Improvement activity or ACI data Quality 3 pts out of 60 ((5% * 60%) + (0%* 15%) + (0%* 25%) * 100) Improvement 0 pts out of 40 ACI 0 pts out of 100% CPS 3 Points
  26. 26. © 2016 Health Catalyst Proprietary and Confidential Neutral MIPS adjustment because the performance threshold is set at 3 points Scoring Minimal Participation for the first year 26 Group A: Submits 0 Quality Measure, 1 Improvement Activity and no ACI Quality 0 pts out of 60 ((0% * 60%) + (.25%*15%) + (0%*25%) *100) Improvement 10 pts out of 40 ACI 0 pts out of 100% CPS 3.75 Points
  27. 27. © 2016 Health Catalyst Proprietary and Confidential Clinicians who achieve a final score of 70 or higher will be eligible for the exceptional performance adjustment, funded from a pool of $500 million. Scoring Full Participation for the first year 27 Individual or Group A: Submits 6 Quality Measures, 4 Improvement activities and 5 required ACI measures Quality 50 pts out of 60 ((83% * 60%) + (75%*15%) + (60%*25%) *100) Improvement 30 pts out of 40 ACI 60 pts out of 100% CPS 76 Points
  28. 28. © 2016 Health Catalyst Proprietary and Confidential 1. What is your organization currently doing? 2. Alignment efforts with Medicaid measure sets and Core Quality Measure Collaborative is under way: “Our strategic interest is a future state where measurement in multi-payer systems, Medicaid, and Medicare can be seamlessly integrated into CMS programs.” page 424 CMS-5517FC.pdf 3. This is 60% of your composite score the first year. Existing measures finalized in CMS-1631-FC What Quality Measures should you report? 28
  29. 29. © 2016 Health Catalyst Proprietary and Confidential 1. There are 13 High Quality Measures and at least one must be selected from these 8 subcategories: 2. Are you participating in other activities such as a registry, Million Hearts, CMS Transforming Clinical Practice Initiative, Health Information Exchange, Patient Experience and Satisfaction Survey, Consumer Assessment of Healthcare Providers and Systems Survey, Domestic or International volunteer work for 60 or more days as an example as these are included in the Improvement activity measures. 3. Review what activities you are currently doing and align these Improvement Activities to what is important to your practice. 4. This is 15% of your composite score the first year. Improvement Activities 29 Expanded Practice Access Population Management Care Coordination Beneficiary Engagement Patient Safety and Practice Assessment Achieving Health Equity Emergency Response and Preparedness Integrated Behavioral and Mental Health
  30. 30. © 2016 Health Catalyst Proprietary and Confidential *Refer to Section II.E.5.g(7)(a) of final rule for final changes 30 Advancing Care Information Objective Advancing Care Information Measure* Required/ Not Required for Base Score (50%) Performance Score (up to 90%) Reporting Requirement Protect Patient Health Information Security Risk Analysis Required 0 Yes/No Statement Electronic Prescribing e-Prescribing Required 0 Numerator/ Denominator Patient Electronic Access Provide Patient Access Required Up to 10% Numerator/ Denominator Patient-Specific Education Not Required Up to 10% Numerator/ Denominator Health Information Exchange Send a Summary of Care Required Up to 10% Numerator/ Denominator Request/Accept Summary of Care Required Up to 10% Numerator/ Denominator Clinical Information Reconciliation Not Required Up to 10% Numerator/ Denominator Coordination of Care Through Patient Engagement View, Download, or Transmit (VDT) Not Required Up to 10% Numerator/ Denominator Secure Messaging Not Required Up to 10% Numerator/ Denominator Patient-Generated Health Data Not Required Up to 10% Numerator/ Denominator Public Health and Clinical Data Registry Reporting Immunization Registry Reporting Not Required 0 or 10% Yes/No Statement Syndromic Surveillance Reporting Not Required Bonus Yes/No Statement Electronic Case Reporting Not Required Bonus Yes/No Statement Public Health Registry Reporting Not Required Bonus Yes/No Statement Clinical Data Registry Reporting Not Required Bonus Yes/No Statement Bonus (up to 15%) Report to one or more additional public health and clinical data registries beyond the Immunization Registry Reporting measure 5% bonus Yes/No Statement Report improvement activities using CEHRT 10% bonus Yes/No Statement Advancing Care Information Performance Category
  31. 31. © 2016 Health Catalyst Proprietary and Confidential31 Webinar in February 2017 We are working to help organizations and providers align their efforts, measure their performance and help gather the necessary data for reporting.
  32. 32. © 2016 Health Catalyst Proprietary and Confidential Work towards 32 Alignment of Effort
  33. 33. Advanced APM Advanced Alternative Payment Model
  34. 34. © 2016 Health Catalyst Proprietary and Confidential Goals of CMS • Overall goal – 90% of Medicare payments shifted to quality or value by 2018 • Encourage participation in APMs • Expand to other payers • Goals: • Better care • Smarter spending • Healthier people 34
  35. 35. © 2016 Health Catalyst Proprietary and Confidential • Participants use CEHRT • Payment received on quality measures comparable to quality measures under MIPS • Bear risk for monetary loss or be “MACRA” Medical Home Model Advanced APM requirements 35
  36. 36. © 2016 Health Catalyst Proprietary and Confidential • Comprehensive ESRD Care Model (Two sided risk)- 12 participants • Medicare Shared Savings Program—Track 2 and Track 3 – 24 participants • Next Generation ACO Model -21 participants • Comprehensive Primary Care Plus (CPC+) • Oncology Care Model Two-Sided Risk Arrangement FINAL LIST to be published by January 2017 Models that Qualify for Advanced APM 36
  37. 37. © 2016 Health Catalyst Proprietary and Confidential During a specific period comparing actual to expected expenditures: • Withhold payments to AMP entity • Reduce payments to AMP entity • Require APM entity to owe payment to CMS Separate Medical Home Model Financial Risk Standard Standard Provisions for Financial Risk 37
  38. 38. © 2016 Health Catalyst Proprietary and Confidential • New Medicare ACO Track 1+ Model for 2018 • New voluntary bundled payment model • Comprehensive Care for Joint (CEHRT) • Advancing Care Coordination thru Episode (CEHRT) • Medical Home Model List will grow, forecast 25% of clinicians by 2018 Pathways to performance-based risk 38
  39. 39. © 2016 Health Catalyst Proprietary and Confidential Alternative Payment Model Advanced APM Advanced APM Entity Qualifying Participant Process 39
  40. 40. © 2016 Health Catalyst Proprietary and Confidential First qualify as advanced APM, then go to next step QP Qualified Participants Estimate 70,000 to 120,000 providers in 2017 Advanced APM Entity 40
  41. 41. © 2016 Health Catalyst Proprietary and Confidential Quality Participants (QP) Thresholds Payment amount formula Patient Count formula-more flexible ** Partial QP could select MIPS Professional services at CAH, FQHC ACO, RHC ACO 41 2019 QP 25% 2019 Partial QP 20% 2019 QP 20% 2019 Partial QP 10% OR Snapshots- Three times in 2017 March, June, Aug
  42. 42. © 2016 Health Catalyst Proprietary and Confidential Now QP in advanced APM • Do not participate in MIPS • Get 5% increase in fee schedule Met all criteria 42
  43. 43. Physicians
  44. 44. © 2016 Health Catalyst Proprietary and Confidential Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, groups that include clinicians who bill under Part B. However, any practitioner that does not exceed the low volume threshold of $30,000 in Part B allowed charges; that has 100 or fewer Medicare patients; is newly enrolled in Medicare; or is a Qualified Participant in an Advanced APM. Who are eligible clinicians subject to MIPS? 44
  45. 45. © 2016 Health Catalyst Proprietary and Confidential Final Rule The Changes Hospital-Based MIPS eligible clinician who furnishes 75 percent or more of covered professional services in an inpatient hospital, on-campus outpatient hospital or emergency room setting in the year preceding the performance period. Change from Proposed Rule: The threshold to determine hospital-based MIPS eligible clinicians lowered from 90 percent to 75 percent. On-campus outpatient hospital was added as a site of service. Non-Patient Facing • Individual MIPS eligible clinician who bills 100 or fewer patient-facing encounters (including Medicare telehealth services) during the non- patient facing determination period. • A group where more than 75% of the NPIs billing under the group’s TIN meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period. Change from Proposed Rule: The threshold to determine non-patient facing status increased from 25 to 100 encounters. Revision to the methodology of identifying a non- patient facing group finalized. Defining Providers in Unique Situations 45
  46. 46. © 2016 Health Catalyst Proprietary and Confidential CMS estimates that between 592,000 and 642,000 Eligible clinicians will be required to participate in MIPS in 2017. How many clinicians will be eligible for MIPS? 46
  47. 47. © 2016 Health Catalyst Proprietary and Confidential Physicians “who are practicing in big, well-organized organizations . . . we’re not worrying about MACRA”…if he were in a small practice, “there would be no way I could deal with this . . . . It requires scale and leadership and management to respond.” Thomas H. Lee, M.D. CMO for the Press Ganey patient experience consulting firm “MIPS and APM are very bad for the solo practitioner. They likely signify the destruction and death of the one- and two-doctor practices, particularly primary care physicians.” A family practitioner in Georgia “I’m frankly not going to report and take the penalty. It’s not worth it to report”. Family physician in Southern California What doctors are saying about MACRA 47
  48. 48. © 2016 Health Catalyst Proprietary and Confidential How did MACRA benefit practitioners? 48 Without the passage of MACRA, physicians could have been subject to negative payment adjustments of 11% or more in 2019 as a result of the MU, PQRS and VBM programs, with even greater penalties in future years. In contrast, under MACRA, the largest penalty a physician can experience in 2019 is 4%. MACRA also provides incentives for physicians to develop and participate in different models of health care delivery and payment known as alternative payment models (APMs).
  49. 49. © 2016 Health Catalyst Proprietary and Confidential Another reason to report: it’s all reported publicly! Physician Compare
  50. 50. © 2016 Health Catalyst Proprietary and Confidential Doctors have urged CMS to "Make the transition to MACRA as simple and as flexible as possible." Andy Slavitt, Acting CMS Director Is CMS Listening? 50
  51. 51. © 2016 Health Catalyst Proprietary and Confidential “The AMA believes the actions that the administration announced today will help give physicians a fair shot in the first year of MACRA implementation. This is the flexibility that physicians were seeking all along.” Andrew Gurman, M.D., President, AMA AMA commends CMS 51
  52. 52. © 2016 Health Catalyst Proprietary and Confidential • New opportunities to earn incentive payments for above average performance. MIPS presents the 1st real opportunity for physicians to earn substantial bonuses for providing a higher quality of care. Additional funding is provided for separate bonuses of up to 10% for exceptional performance, up to $500 million per year, from 2019 through 2024. • A streamlined performance reporting system, which should be more easily managed than the multiple existing reporting systems. The CMS currently allows group practices to report via QCDRs starting in 2017, and MACRA encourages eligible professionals to use these registries for MIPS reporting. • Improvements in performance scoring over current quality programs: • Sliding scale assessment. • Flexible selection of measures. Flexible weighting. The law has guidelines for the weighting of the 4 performance categories, yet specifically allows administrative flexibility for those in practices or specialties that are at a disadvantage in meeting quality or Advancing Care Information measure requirements. • Credit for Improvement Activities. • New measurement components. Small practices will receive $100 million in technical assistance. • From fiscal years 2016 through 2020, $20 million per year will assist practices of up to 15 professionals to participate in the MIPS program or transition to new payment models. What are the Main Benefits Of Participation In MIPS? 52
  53. 53. © 2016 Health Catalyst Proprietary and Confidential Fifty percent say they have never heard of the law and 32 percent recognize it by name but are not familiar with its requirements. Twenty-one percent of self-employed or independent physicians say they are somewhat familiar with the law, compared to nine percent of physicians employed by hospitals, health systems, or medical groups owned by them. Eight-in-ten say they prefer traditional fee-for-service (FFS) or salary-based compensation as opposed to value-based payment models, some of which qualify under MACRA's alternative payment model (APM) track. Seventy-four percent of surveyed physicians believe that performance reporting is burdensome and 79 percent do not support tying compensation to quality, both requirements under MACRA. Fifty-eight percent of physicians say they would opt to be part of a larger organization to reduce individual increased financial risk and have access to supporting resources and capabilities. How Ready are Physicians for MACRA? 53 The Deloitte Center for Health Solutions 2016 Survey of US Physicians
  54. 54. © 2016 Health Catalyst Proprietary and Confidential Beginning December of 2016 MACRA will provide $100 million to fund training and education ($20 million each year for 5 years). Medicare clinicians in individual or small group practices of 15 clinicians or fewer and those working in underserved areas are eligible to receive this training. The training will be conducted through local, experienced organizations using this funding to help small practices select appropriate quality measures and health IT to support their unique needs, train clinicians about the new improvement activities and assist practices in evaluating their options for joining an Advanced APM. Watch websites for additional details. Assistance Needed! 54
  55. 55. © 2016 Health Catalyst Proprietary and Confidential 1. Evaluate where you fall under MACRA (MIPS, APM or exempt?) 1. AMA payment model evaluator 2. Are you participating in a qualified clinical data registry, if not, contact your specialty society about participating in theirs (data registries can streamline reporting and assist with MIPS performance scoring) 3. If you practice with >1 eligible clinician decide whether to report individually or as a group. 4. Determine whether you meet the requirements for small, rural or non-patient- facing physician accommodations. What are steps can we take to prepare? 55
  56. 56. © 2016 Health Catalyst Proprietary and Confidential 5. Access and review the 2014 annual PQRS feedback reports to see where improvements can be made. 6. Review cost data from CMS in summer of 2017 for 2020 ramifications (attribution). 7. Consider how you plan to report through claims, electronic health record (EHR), clinical registry, qualified clinical data registry (QCDR) or group practice reporting option (GPRO) Web-interface. The GPRO Web-interface is only available for physicians in practices of 25 or more eligible clinicians. Steps to take-continued 56
  57. 57. © 2016 Health Catalyst Proprietary and Confidential Connect locally with organizations and use their websites AMA https://www.ama-assn.org/practice-management/medicare-payment- delivery-changes AHA http://www.aha.org/advocacy-issues/physician/index.shtml AAFP http://www.aafp.org/practicemanagement/payment/macraready.html ONC https://chpl.healthit.gov/#/search list of certified vendors CMS Quality Payment Program qpp.cms.gov Resources MACRA READY programs
  58. 58. © 2016 Health Catalyst Proprietary and Confidential Questions 58 Bobbi Brown Bobbi.brown@healthcatalyst.com Bryan T. Oshiro, M.D. Chief Medical Officer Bryan.oshiro@healthcatalyst.com Dorian DiNardo Dorian.dinardo@healthcatalyst.com
  59. 59. © 2016 Health Catalyst Proprietary and Confidential Appendix
  60. 60. © 2016 Health Catalyst Proprietary and Confidential • MACRA – Medicare Access and CHIP Reauthorization Act of 2015 • SGR – Sustainable Growth Rate (replaced by MACRA) • MIPS – Merit-based Incentive Payment System • APM – Alternative Payment Models (Advanced) • EP – Eligible professional becomes EC Eligible clinician • ACI- Advancing Care Information (replaces Meaningful Use) • CPIA –Clinical Practice Improvement Activity • CPS – Composite Performance Score Acronyms 60
  61. 61. © 2016 Health Catalyst Proprietary and Confidential Proposed Rule Final Rule Quality • 6 individual measures or 1 measure set with at least one cross-cutting measure and outcome measure (if no outcome measure, one other high priority measure) • Required reporting on 80% of patients(claims method ) or 90% (other submission methods) 6 quality measures (including outcome measure) or 1 measure set (if no outcome measures are available in the measure set, report another high priority measure ) Requires reporting on 50% of patients (all submission methods) Advancing Care Information (ACI) 11 required measures 5 required measures Clinical Practice Improvement Activities (CPIA) • 6 medium-weighted activities or • 3 high- weighted activities • 4 medium-weighted activities OR • 2 high-weighted activities Cost (previously called Resource Use) Continues measures from the Value Modifier program and episode-based measures, as applicable to MIPS eligible clinicians Not measured in 2017 performance year What do we have to report? 61
  62. 62. © 2016 Health Catalyst Proprietary and Confidential Maximum negative adjustment of 4% in MIPS Reporting Option 1: No Reporting 62
  63. 63. © 2016 Health Catalyst Proprietary and Confidential Report some data in 2017 to the Quality Payments Program (QPP). Protected from negative payment adjustment in MIPS, but no positive payment adjustment available either. Not exactly defined as to what “some data” actually means. CMS considers this a test of how doctors will be ready for more intense reporting requirements in the following years. Reporting Option 2: Minimal Reporting 63
  64. 64. © 2016 Health Catalyst Proprietary and Confidential Participate for part of 2017. Eligible for positive payment adjustment Protected from negative payment adjustment Participants will be testing their systems for future MACRA compliance and may end up with a small Medicare pay increase. Reporting Option 3: Partial reporting 64
  65. 65. © 2016 Health Catalyst Proprietary and Confidential Participate for all of 2017. Doctors who begin reporting data on January 1st 2017 will be eligible for a “modest” pay increase in 2019 Data on quality measures, use of technology and practice improvement must be reported Reporting Option 4: full reporting 65
  66. 66. © 2016 Health Catalyst Proprietary and Confidential Participate in an Advanced Alternative Payment Model Doctors who begin reporting data on January 1st 2017 will be eligible for a “modest” pay increase in 2019 Data on quality measures, use of technology and practice improvement must be reported Reporting Option 5: Advanced APM 66

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