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1
The Merit Health
Network
MACRA Overview –
July 2016
Background
2
MACRA permanently eliminates the
SGR (and annual rate cuts)
Consolidates Medicare PQRS, MU,
VBM reporting programs
Establishes a path to predominant
Value-Based payment methodologies
Passed in Senate 92-8; Passed
in House 392-37
Fears
3
Medicare projects 70% of rural practices
with 2-9 docs will be penalized via MIPS
50% of non-pediatric physicians have
never heard of MACRA
MIPS program is budget neutral;
penalized providers will pay rewards
for other providers
It is widely reported MACRA will force
further consolidation
MIPS: National Financial Impact
4
• MIPS is Budget Neutral
• Government expects $833 million will be redistributed
• Additional $500 million in bonuses for top performers
MACRA Progression
5
Today vs. Tomorrow
6
Currently: QRUR MU PQRS/VBMNon-
Existent
QPP: MIPS? APM? Both….
7
Merit Incentive Based Payment
System (MIPS)
Default Program (≈90% of Medicare
Providers): A portion of Medicare
Revenue at the TIN/Individual Provider
Level is at risk based on the following
performance categories:
Alternative Payment Models (APMs)
Generic term for providers who receive
significant revenue through 2-sided risk-
based contracts.
Currently Proposed Options:
• Medicare Shared Savings Program
(MSSP) Tracks 2 & 3
• Next Generation ACO
• Oncology Care Model Two-sided Risk
Arrangement (Available 2018)
• Comprehensive End-Stage Renal Disease
Care (CEC) Model
Ultimate Goal: APM’s
8
• Requires:
• “More than nominal” Risk
• Quality measurement
• Very advanced Value-
Based Design
(Technology, Analytics,
Workflow, Contracts, etc.)
• Provides:
• Prospective 5% Lump-
Sum annual bonus in
2019-2024
• Exemption from MIPS
requirements
2019
–
2020
2021–
2022
25% N/A
50%
N/A 25%
50%
OROption 1 Option 2
Required for All
Providers
2023
and
on
75%
N/A 25%
75%
Required Percentage of Revenue
Under Risk-Based Payment Models
Option 1
Medicare Only
Option 2
Medicare +
Commercial
Contracts
Current Focus: MIPS
9
• MIPS is the Default Program;
AKA New Medicare FS
• CMS anticipates 90% of all
physicians will be paid via MIPS
in 1st year of the Quality Payment
Program (QPP)
• Adjusts Medicare payments
based on performance on a
single budget-neutral payment
beginning in 2019 (2-year Look-
Back)
• Applies to physicians, NPs,
clinical nurse specialists,
physician assistants, and
certified RN anesthetists
MIPS: Composite Performance Scores
10
4 Categories = 100%
1. Quality = 50%
2. Advancing Care Information = 25%
3. Clinical Practice Information Activities = 15%
4. Cost = 10%
11
Components of the MIPS Score
12
MIPS Category: Quality (50% Yr 1 MIPS Score)
13
 From 9 PQRS Measures to 6 total Measures
 During Open Comment period, many pushed towards specialty and
practice-specific measures
Final Rule to show many changes
Focus today on ability to incorporate 6 measures into workflow
MIPS Category: ACI (25% Yr 1 MIPS Score)
14
Key Takeaways:
High, historical MU compliance does not guarantee a high ACI score.
Unlike Historical MU, ACI Scoring is a CONTINUOUS scale, Not All-Or-Nothing
• Replaces Meaningful Use
• Potential to Participate as a group (If Final Rule allows)
• Advanced Practice Providers – exempt (Midlevels, NPs, PAs, etc.)
• Split Into Base Score & Performance Score
• Proposed Rule = Complicated Scoring (130 total points, only 100
needed to earn full score in ACI category)
ACI Base Score (50 Points)
15
6 Objective and Measure Categories
1. Protect Patient Health Information - Y/N (Required)
2. Patient Electronic Access - N/D
3. Coordination of Care & Patient Education - N/D
4. Electronic Prescribing - N/D
5. Health Information Exchange – N/D
6. Public Health/Registry Reporting – Y/N
*N/D = Numerator/Denominator
ACI Performance Score (80 Points)
16
3 Objective and Measure Categories
1. Patient Electronic Access - N/D
2. Coordination of Care & Patient Education – N/D
3. Health Information Exchange – N/D
** Immunization Registry – Mandatory
** Bonus Point – Pub Health reporting beyond immunizations
* N/D = Numerator/Denominator
MIPS Category: Clinical Practice
Improvement Activities (15% of MIPS Score)
17
* Max Score = 60
* PCMH Participation Guarantees 100%
CPIA Score
* Largely Undefined Currently
* Secretary shall give consideration to
practices <15 Eps, rural practices, and Eps
in underserved areas
90 Proposed activities – 9 Categories
1. Expanded Practice Access
A. After hours hotline
B. Same-day appointments
2. Beneficiary Engagement
A. Care Plans
B. Self-assessment training
C. shared decision-making, etc.)
3. Achieving Health Equity
4. Population Health Management
1. Qualified clinical data registry
2. Monitoring conditions
5. Patient Safety & Assessment
1. Use of Surgical Checklists
2. Assessments related to maintaining Certifications
6. Emergency Preparedness & Response
7. Care Coordination
8. Participation in Advanced APM or Medical HomeModel
9. Integrated Behavioral Health
MIPS Category: Cost (10% 1st Yr MIPS Score)
18
1. Replaces cost component / resource use of VBMP.
2. Scored on Medicare claims = NO REPORTING.
3. 40 specific episode measures – among specialists.
4. Must see at least 20 patients in respective category.
5. Each cost measure max out at 10 points.
Score Summary Recap
19
Key Questions & Suggestions
20
Key Questions
1. Do you use CEHRT (Certified EHR Technology)?
2. Do you feel comfortable with your reporting process? (Proposed Full-year
reporting)
3. Do you know the measures your EHR is capable of reporting? (These metrics will
become public under MACRA) http://oncchpl.force.com/ehrcert
Key Suggestions
1. Stay familiar with CMS’ Core Measures as CMS & AHIP agree to harmonize
metrics
2. Improving your PQRS reporting process will pay dividends
3. 2017 Reporting Year will be 50 % PQRS & 25% ACI (Formerly Meaningful Use)
4. Download QRUR
5. Prepare to adjust workflows
6. Focus resources on specific PQRS measures. Identify workflow adjustments
7. Assess EHR/technological capability to comply
Strategic Plan
21
1. Short-run: Focus on Coding, PQRS Workflow, Care-Coordination
(CCM 99490), Chronic Care management, CPC+*, analytics
2. Long-Term: Learn via MIPS; Prepare APM contracts by expanding
to MA plans, then commercial FFV arrangements
3. Educate staff on initiatives
A. Many metrics involve strong communication & non-physician
reporting processes
B. Cultural change management in pursuit of Triple Aim
4. Establishing a CIN provides the architecture to strategically step
towards value-based payments to shift from MIPS to APMs & receive
further incentive-rewards
* CPC+ (Comprehensive Primary Care Plus) Regions are to be announced August 1, 2016
Sample Roadmap
22
Acronyms Reference Guide
23
• ACO – Accountable Care
Organization
• APM – Advanced Alternative
Payment Model
• CMS – Centers for Medicare &
Medicaid Services
• CPC+ – Comprehensive
Primary Care Plus
• EHR – Electronic Health
Record
• EP – Eligible Professional
• HHS – U.S. Department of
Health & Human Services
• MACRA – The Medicare Access
and CHIP Reauthorization Act of
2015
• MIPS – Merit-Based Incentive
Payment System
• MSSP – Medicare Shared
Savings Program
• PQRS – Physician Quality
Reporting System
• QPP – Quality Payment Program
• QRUR – Quality and Resource
Use Report
• VBPM – Value-Based Payment
Modifier
Summary: Merit Health QPP Plan
24
1. More education for members
2. Continue CIN objectives
3. Analytics implementation
4. More clinical workgroups
5. Analytics support
6. Partnership
25

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MACRA

  • 1. 1 The Merit Health Network MACRA Overview – July 2016
  • 2. Background 2 MACRA permanently eliminates the SGR (and annual rate cuts) Consolidates Medicare PQRS, MU, VBM reporting programs Establishes a path to predominant Value-Based payment methodologies Passed in Senate 92-8; Passed in House 392-37
  • 3. Fears 3 Medicare projects 70% of rural practices with 2-9 docs will be penalized via MIPS 50% of non-pediatric physicians have never heard of MACRA MIPS program is budget neutral; penalized providers will pay rewards for other providers It is widely reported MACRA will force further consolidation
  • 4. MIPS: National Financial Impact 4 • MIPS is Budget Neutral • Government expects $833 million will be redistributed • Additional $500 million in bonuses for top performers
  • 6. Today vs. Tomorrow 6 Currently: QRUR MU PQRS/VBMNon- Existent
  • 7. QPP: MIPS? APM? Both…. 7 Merit Incentive Based Payment System (MIPS) Default Program (≈90% of Medicare Providers): A portion of Medicare Revenue at the TIN/Individual Provider Level is at risk based on the following performance categories: Alternative Payment Models (APMs) Generic term for providers who receive significant revenue through 2-sided risk- based contracts. Currently Proposed Options: • Medicare Shared Savings Program (MSSP) Tracks 2 & 3 • Next Generation ACO • Oncology Care Model Two-sided Risk Arrangement (Available 2018) • Comprehensive End-Stage Renal Disease Care (CEC) Model
  • 8. Ultimate Goal: APM’s 8 • Requires: • “More than nominal” Risk • Quality measurement • Very advanced Value- Based Design (Technology, Analytics, Workflow, Contracts, etc.) • Provides: • Prospective 5% Lump- Sum annual bonus in 2019-2024 • Exemption from MIPS requirements 2019 – 2020 2021– 2022 25% N/A 50% N/A 25% 50% OROption 1 Option 2 Required for All Providers 2023 and on 75% N/A 25% 75% Required Percentage of Revenue Under Risk-Based Payment Models Option 1 Medicare Only Option 2 Medicare + Commercial Contracts
  • 9. Current Focus: MIPS 9 • MIPS is the Default Program; AKA New Medicare FS • CMS anticipates 90% of all physicians will be paid via MIPS in 1st year of the Quality Payment Program (QPP) • Adjusts Medicare payments based on performance on a single budget-neutral payment beginning in 2019 (2-year Look- Back) • Applies to physicians, NPs, clinical nurse specialists, physician assistants, and certified RN anesthetists
  • 10. MIPS: Composite Performance Scores 10 4 Categories = 100% 1. Quality = 50% 2. Advancing Care Information = 25% 3. Clinical Practice Information Activities = 15% 4. Cost = 10%
  • 11. 11
  • 12. Components of the MIPS Score 12
  • 13. MIPS Category: Quality (50% Yr 1 MIPS Score) 13  From 9 PQRS Measures to 6 total Measures  During Open Comment period, many pushed towards specialty and practice-specific measures Final Rule to show many changes Focus today on ability to incorporate 6 measures into workflow
  • 14. MIPS Category: ACI (25% Yr 1 MIPS Score) 14 Key Takeaways: High, historical MU compliance does not guarantee a high ACI score. Unlike Historical MU, ACI Scoring is a CONTINUOUS scale, Not All-Or-Nothing • Replaces Meaningful Use • Potential to Participate as a group (If Final Rule allows) • Advanced Practice Providers – exempt (Midlevels, NPs, PAs, etc.) • Split Into Base Score & Performance Score • Proposed Rule = Complicated Scoring (130 total points, only 100 needed to earn full score in ACI category)
  • 15. ACI Base Score (50 Points) 15 6 Objective and Measure Categories 1. Protect Patient Health Information - Y/N (Required) 2. Patient Electronic Access - N/D 3. Coordination of Care & Patient Education - N/D 4. Electronic Prescribing - N/D 5. Health Information Exchange – N/D 6. Public Health/Registry Reporting – Y/N *N/D = Numerator/Denominator
  • 16. ACI Performance Score (80 Points) 16 3 Objective and Measure Categories 1. Patient Electronic Access - N/D 2. Coordination of Care & Patient Education – N/D 3. Health Information Exchange – N/D ** Immunization Registry – Mandatory ** Bonus Point – Pub Health reporting beyond immunizations * N/D = Numerator/Denominator
  • 17. MIPS Category: Clinical Practice Improvement Activities (15% of MIPS Score) 17 * Max Score = 60 * PCMH Participation Guarantees 100% CPIA Score * Largely Undefined Currently * Secretary shall give consideration to practices <15 Eps, rural practices, and Eps in underserved areas 90 Proposed activities – 9 Categories 1. Expanded Practice Access A. After hours hotline B. Same-day appointments 2. Beneficiary Engagement A. Care Plans B. Self-assessment training C. shared decision-making, etc.) 3. Achieving Health Equity 4. Population Health Management 1. Qualified clinical data registry 2. Monitoring conditions 5. Patient Safety & Assessment 1. Use of Surgical Checklists 2. Assessments related to maintaining Certifications 6. Emergency Preparedness & Response 7. Care Coordination 8. Participation in Advanced APM or Medical HomeModel 9. Integrated Behavioral Health
  • 18. MIPS Category: Cost (10% 1st Yr MIPS Score) 18 1. Replaces cost component / resource use of VBMP. 2. Scored on Medicare claims = NO REPORTING. 3. 40 specific episode measures – among specialists. 4. Must see at least 20 patients in respective category. 5. Each cost measure max out at 10 points.
  • 20. Key Questions & Suggestions 20 Key Questions 1. Do you use CEHRT (Certified EHR Technology)? 2. Do you feel comfortable with your reporting process? (Proposed Full-year reporting) 3. Do you know the measures your EHR is capable of reporting? (These metrics will become public under MACRA) http://oncchpl.force.com/ehrcert Key Suggestions 1. Stay familiar with CMS’ Core Measures as CMS & AHIP agree to harmonize metrics 2. Improving your PQRS reporting process will pay dividends 3. 2017 Reporting Year will be 50 % PQRS & 25% ACI (Formerly Meaningful Use) 4. Download QRUR 5. Prepare to adjust workflows 6. Focus resources on specific PQRS measures. Identify workflow adjustments 7. Assess EHR/technological capability to comply
  • 21. Strategic Plan 21 1. Short-run: Focus on Coding, PQRS Workflow, Care-Coordination (CCM 99490), Chronic Care management, CPC+*, analytics 2. Long-Term: Learn via MIPS; Prepare APM contracts by expanding to MA plans, then commercial FFV arrangements 3. Educate staff on initiatives A. Many metrics involve strong communication & non-physician reporting processes B. Cultural change management in pursuit of Triple Aim 4. Establishing a CIN provides the architecture to strategically step towards value-based payments to shift from MIPS to APMs & receive further incentive-rewards * CPC+ (Comprehensive Primary Care Plus) Regions are to be announced August 1, 2016
  • 23. Acronyms Reference Guide 23 • ACO – Accountable Care Organization • APM – Advanced Alternative Payment Model • CMS – Centers for Medicare & Medicaid Services • CPC+ – Comprehensive Primary Care Plus • EHR – Electronic Health Record • EP – Eligible Professional • HHS – U.S. Department of Health & Human Services • MACRA – The Medicare Access and CHIP Reauthorization Act of 2015 • MIPS – Merit-Based Incentive Payment System • MSSP – Medicare Shared Savings Program • PQRS – Physician Quality Reporting System • QPP – Quality Payment Program • QRUR – Quality and Resource Use Report • VBPM – Value-Based Payment Modifier
  • 24. Summary: Merit Health QPP Plan 24 1. More education for members 2. Continue CIN objectives 3. Analytics implementation 4. More clinical workgroups 5. Analytics support 6. Partnership
  • 25. 25