This presentation, “Merit-Based Incentive Payment System: Strategic Deployment Within Your Organization,” outlines the requirements for MIPS participation and scoring in 2018. It also provides strategic guidance for creating an opportunity for positive financial impact for practices.

1. STRATEGIC DEPLOYMENT WITHIN YOUR ORGANIZATION
PREPARED FOR GA HFMA
JANUARY 24, 2018
Merit-Based Incentive Payment System
(MIPS)

2. Page 2
Agenda
1. MIPS Overview
2. Scoring Methodology
3. Advanced APMs
4. Strategy

3. MIPS Overview

4. Page 4
MIPS Participation Election
 Final Score assigned to each NPI/TIN
 Group reporting must include all NPIs who
reassign to TIN; cannot pick and choose
 NPI who reassigns to TIN reporting as a group
may also report individually

5. Page 5
Years 1 (2017) and 2 (2018) Years 3+
Physicians
(MD/DO, DPM, OD, DC, DMD/DDS)
PAs, APRNs, CNSs, CRNA
Physical or occupational therapists,
speech-language pathologists,
audiologists, nurse midwives, clinical
social workers, clinical psychologists,
dieticians/nutritional professionals
Eligible Clinicians

6. Page 6
Low-Volume Threshold
 For 2018, individual or group exempt from MIPS if:
 $90,000 or less in allowable Part B charges; or
 Billing for 200 or fewer traditional Medicare beneficiaries
 If elect group reporting, NPIs who would be exempt if
reporting individually are NOT exempt
 Two determination periods (both with 30-day claims run-
out)
 September 1, 2016, to August 31, 2017
 September 1, 2017, to August 31, 2018
Hint: Use the CMS Lookup tool to determine whether providers are excluded from MIPS; note that
results for multiple TIN/NPI combinations are reported if the provider bills under more than one TIN.

7. Page 7
Reporting Requirements
Score Component Reporting Policy
Quality
12 months of quality measure
data
Advancing Care Information
Minimum of 90 consecutive
days of data
Improvement Activities Minimum of 90 consecutive
days of data
Cost Performance
No reporting requirements, as
CMS will calculate both cost
measures using Medicare
claims data
Note: A minimum of 15 points required to avoid penalty, making 2018 another
transition year. Significantly higher points will be required in 2019 to avoid
penalty.

8. Page 8
MIPS Final Score Components
Quality
Cost
Performance
Improvement
Activities
Advancing Care
Information
60%
0%
15%
25%
30%
30%
15%
25%
2017 Performance
Year
2018 Performance
Year
2019+ Performance
Years
Impacts 2019
Payments
Impacts 2020
Payments
Impacts 2021
Payments
50%
10%
15%
25%

9. Scoring Methodology

10. Page 10
Quality Component
Manner of
Participation
Reporting
Mechanism
Measure
Requirements
Data Completeness
Individual Part B Claims
6 measures (at least
1 outcome measure)
OR specialty-specific
measure set
(including oncology)
60% of all
applicable
Medicare Part B
patient encounters
Individual or
Group
QCDR
Qualified Registry
EHR
6 measures (at least
1 outcome measure)
OR specialty-specific
measure set
(including oncology)
60% of individual’s
or group’s patient
encounters that
meet measure
denominator (all
payer)
Group
CMS Web Interface
(registration deadline
06/30/18)
All 15 web interface
measures
CMS-selected
sample of Part B
patients

11. Page 11
Quality Component Scoring
 Quality measure benchmarks established prior to
performance period (benchmarks for 2018 based on
2016 results)
 Points given for actual performance, split into deciles
 Decile 1 = 1 point (lowest possible)
 Decile 10 = 10 points (highest possible)
 Bonus points for:
 Reporting high-priority measures (1-2 bonus points per
measure)
 Using QCDR or CEHRT for reporting (1 bonus point)
 If you report more than the minimum, CMS will select
your best measures
Scoring Methodology

12. Page 12
Improvement Activity Component
 Activities weighted as either “high” or “medium”
 Eight different subcategories of activities, plus participation in an APM
• Same-day
appointments
• After-hours access to
clinician advice
• Use of telehealth services
• Collection of patient
experience and
satisfaction data
Expanded
Practice Access
• Monitoring health
conditions
• Participating in qualified
data registries
• Participating in Million
Hearts
• Participating in research
for targeted patient
populations
Population
Management
• Timely communication of
test results
• Implementation of regular
care coordination training
• Development of care
plans for at-risk patients
Care
Coordination
• Establishment of care
plans
• Use of shared decision-
making mechanisms
• Use of group visits for
common chronic
conditions
Beneficiary
Engagement
• Use of clinical and
surgical checklists
• Practice assessments
• Use of decision support
and protocols
Patient Safety
Practice
Assessment
• See new and follow-up
Medicaid patients in a
timely manner
• Use QCDR to screen for
social determinants of
health
Achieving Health
Equity
• Participate in
humanitarian volunteer
work
• Participate in Disaster
Medical Assistance
Teams
Emergency
Response and
Preparedness
• Engage patients with
behavioral health
conditions
• Offer behavioral health
services
Integrated
Behavioral and
Mental Health

13. Page 13
IA Component Scoring
Improvement Activities Component Score (capped at 100) =
(# of Medium Activities * 10) + (# of High Activities * 20) / 40 possible points
Most participants
Attest to completion of 40 points
(up to 4 activities)
for minimum of 90 days
Groups (a) with fewer than 15
participants, (b) located in
rural area or HPSA
Attest to completion of 20 points
(up to 2 activities)
for minimum of 90 days
Participants in certified PCMH
(50% of practice sites)
Full credit
Participants in MIPS APM Full credit
Participants in other APMs Half credit

14. Page 14
Cost/Resource Use Component
 No reporting requirements – CMS automatically
calculates based on administrative claims
 Still using a beneficiary attribution process
Scoring Methodology
Resource use benchmarks set during the actual performance year
(benchmarks for 2017 based on 2017 actual)
Points given for actual performance, split into deciles:
Decile 1 (highest cost) = 1 point
Decile 10 (lowest cost) = 10 points
Average of points for all applicable resource measures

15. Page 15
Advancing Care Information
Base Score (Required) Measures
(50% of total score; Y/N or report numerator/
denominator)
Performance Score Measures
(0 to 10 points each based on level of
performance)
Security Risk Analysis Patient Specific Education
E-Prescribing View, Download, or Transmit
Provide Patient Electronic Access Provide Patient Electronic Access
Health Information Exchange Health Information Exchange
Medication Reconciliation
Secure Messaging
Immunization Registry Reporting (Y/N)
2018 Option 1: Clinicians with CEHRT 2014 or CEHRT 2015

16. Page 16
Advancing Care Information
Base Score (Required) Measures
50% of total score; Y/N or report numerator/
denominator)
Performance Score Measures
(0 to 10 points each based on level of
performance)
Security Risk Analysis Patient Specific Education
E-Prescribing View, Download, or Transmit
Provide Patient Electronic Access Provide Patient Electronic Access
Send a Summary of Care Send a Summary of Care
Request and Accept Summary of Care Request and Accept Summary of Care
Secure Messaging
Patient-Generated Health Data
Clinical Information Reconciliation
Immunization Registry Reporting (Y/N)
2018 Option 2: Clinicians with CEHRT 2015**
* To incentivize implementation of 2015 Edition CEHRT, CMS finalized a bonus of 10% in the ACI category for ECs and
groups that exclusively use 2015 Edition CEHRT to report the five ACI base measures. This bonus will not be awarded if
2015 Edition CEHRT is used to report the four transitional base measures.

17. Page 17
ACI Component
Scoring Methodology
Base Score
50 Points
Performance
Score
80 Points
Composite ACI
Score
100 Points (Maximum)
**Opportunity for 1 bonus point for
public health registry participation
Note:
Potential to score more than 100 points based on
performance score; however, score will be capped at 100.

18. Page 18
2018 Final Score Calculation
Quality
Component Score
Cost
Performance
Component Score
Improvement
Activities
Component Score
Advancing Care
Information
Component Score
Multiply Each By
Component Weight
Final
Score

19. Page 19
MIPS Final Score Calculation
 Sum of each of the products of each component score
and each component’s assigned weight, multiplied by
100
 0 Points = Nonparticipation; negative payment adjustment
 15 Points = Neutral payment adjustment
 16-69 Points = Positive adjustment (sliding scale)
 ≥ 70 Points = Positive adjustment + exceptional performance bonus (0.5%)
 Example:
 Quality = (55 points / 70 possible points) x 50%
 Advancing Care Information = (84 points / 100 possible points) x 25%
 Improvement Activities = (40 points / 40 possible points) x 15%
 Cost = (40 points / 100 possible points) x 10%
 FINAL SCORE = 83.21
 Positive Adjustment + Exceptional Performance Bonus

20. Advanced APMs

21. Page 21
Advanced APMs (Traditional Medicare)
Medicare Shared Savings Program
(Tracks 1+, 2, & 3)
Next Generation ACO Model
Comprehensive ESRD Care
(Two-Sided Risk)
Comprehensive Primary Care Plus
(unless participating in MSSP or starting in 2018 parent organization has more
than 50 MIPS-Eligible Clinicians)
Oncology Care Model
(Two-Sided Risk)
Vermont All-Payer ACO Model
Comprehensive Care for Joint Replacement Payment Model
(CEHRT Track)

22. Page 22
Be excluded from MIPS
Minimum % of patients/ payments
through Advanced APM
Receive 5% lump sum bonus
Bonus applies in 2019-2024;
QPs receive higher MPFS
updates starting in 2026
QPs:
QPAdvanced APM
Partial QPs not eligible for bonus,
but can opt out of MIPS payment
adjustments
QPs and Partial QPs

23. Page 23
Qualifying Participant
Qualifying Participant
 Higher % of patients or payments
 Bonus = 5% of MPFS payments
Partial Qualifying Participant
 Lower % of patients or payments
 No bonus, no MIPS
Non-Qualifying Participant
 Subject to MIPS
Payment Year 2017 2018 2019 2020 2021 2022
and
later
Payment Amount
Threshold
25% 25% 50% 50% 75% 75%
Patient Count
Threshold
20% 20% 35% 35% 50% 50%
Payment Year 2019 2020 2021 2022 2023 2024
and
later
Payment Amount
Threshold
20% 20% 40% 40% 50% 50%
Patient Count
Threshold
10% 10% 25% 25% 35% 35%
Requirements for Incentive Payments for
Significant Participation in Advanced APMs
Medicare-Only Partial QP Thresholds in
Advanced APMs

24. Page 24
APM Scoring Standard
 Applies to those eligible clinicians identified on MIPS APM
participant list
 MIPS APM
 Advanced APMs
 Track 1 MSSP ACO
 Oncology Care Model (one-sided model)
 Included on participant list as of March 31, June 30, August 31, or
December 31 of performance year

25. Page 25
Applying the APM Scoring Standard
 50% Quality
 Based on APM performance
measures
 20% Improvement Activities
 Full Credit
 30% Advancing Care Information
 Weighted mean average of APM
participants’ reported scores
APM Scoring Standard
50%
20%
30%

26. Strategy

27. Page 27
Consider Group vs Individual Reporting
 Is an aggregate score better versus individual?
 May consider if most providers within group are high performers
 Group reporting will reduce the burden of reporting for
each individual provider

28. Page 28
Consider Impact of Reporting Method
 EHR reporting allows for potential to earn more points for
the same measures
 Some measures not available depending upon reporting
option
 Potential to earn bonus points on certain measures if
reported through an EHR
 1 extra point for each measure reported using CEHRT for end-to-
end electronic reporting up to 10% of total possible points

29. Page 29
Point Assignment Based on Deciles
Measure Name
Submission
Method
Decile 3 Decile 4 Decile 5 Decile 6 Decile 7 Decile 8 Decile 9 Decile 10
Topped
Out
Preventive Care
and Screening:
Influenza
Immunization
(#110)
Claims
22.64 -
31.75
31.76 -
43.13
43.14 -
54.68
54.69 -
66.38
66.39 -
77.47
77.48 -
92.03
92.04 -
99.99
100 No
EHR
11.22 -
18.57
18.58 -
24.99
25.00 -
31.84
31.85 -
38.92
38.93 -
47.86
47.87 -
59.99
60.00 -
79.01
>= 79.02 No
Registry/ QCDR
11.57 -
21.39
21.40 -
31.39
31.40 -
41.31
41.32 -
51.13
51.14 -
62.04
62.05 -
74.27
74.28 -
91.83
>= 91.84 No
Sample Benchmarks for 2018 MIPS Quality Reporting and
Measurement
Source: 2017 MIPS benchmarks as provided by CMS through qpp.cms.gov
Example:
Provider A
Provider B
Claims
EHR
61%
61%
6 points
9 points
Submission Method Performance Points Earned

30. Page 30
Avoid “Topped Out” Measures
#21. Perioperative Care: Selection of Prophylactic Antibiotic-First or Second
Generation Cephalosporin
#23. Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When
Indicated in ALL Patients)
#52. Chronic Obstructive Pulmonary Disease (COPD): Inhaled Bronchodilator
Therapy
#224. Melanoma: Overutilization of Imaging Studies in Melanoma
#262. Image Confirmation of Successful Excision of Image Localized Breast Lesion
#359. Optimizing Patient Exposure to Ionizing Radiation: Utilization of a
Standardized Nomenclature for Computerized Tomography (CT) Imaging
Description

31. Page 31
Point Assignment Based on Deciles
Sample Benchmarks for 2018 MIPS Quality Reporting and Measurement
Source: 2017 MIPS benchmarks as provided by CMS through qpp.cms.gov
Example:
Provider A
Provider B
Claims
EHR
98.6%
98.6%
4 points
10 points
Submission Method
Performance Points Earned
Measure Name
Submission
Method
Decile 3 Decile 4 Decile 5 Decile 6 Decile 7 Decile 8 Decile 9 Decile 10
Topped
Out
Preventive Care
and Screening:
Tobacco Use:
Screening and
Cessation
Intervention
(#226)
Claims
95.60 -
97.85
97.86 -
99.25
99.26 -
99.99
-- -- -- -- 100 Yes
EHR
72.59 -
81.59
81.60 -
86.68
86.69 -
90.15
90.16 -
92.64
92.65 -
94.67
94.68 -
96.58
96.59 -
98.51
>= 98.52 No
Registry/ QCDR
76.67 -
85.53
85.54 -
89.87
89.88 -
92.85
92.86 -
95.14
95.15 -
97.21
97.22 -
99.10
99.11 -
99.99
100 No

32. Page 32
Assess Quality Measures
 Select measures that best fit your specialty
 Review prior year QRUR report for quality measure
performance
 Example- Surgical Specialty should not report on blood
pressure measurement
 Report more than the minimum; CMS will pick top scoring
measures
 Consider bonus points:
 Quality bonus points for add’l outcome/ patient experience quality
measure
 Quality bonus point for reporting other high-priority quality
measures
 ACI bonus points for reporting to a public health agency, clinical
data registry, or immunization registry

33. Page 33
Minimum Threshold Strategy
Must report a minimum of 15 points; options may
include:
 Fully participate in one component:
 IA
 Partially participate in multiple components:
 ACI
 Quality
 IA
 Partially participate in one component:
 ACI
 Quality
Use 2018 as 2nd transition year to prepare for 2019
where requirements to succeed are more stringent

34. Page 34
Pace Yourself or Full-Speed Ahead?
 Go “all-in” or do minimum to avoid penalty?
Benefit of
Going “All-In”
Benefits of
Doing the
Minimum

35. Page 35
Action Items
 Gather your team
 Define baselines
 Continue educating providers
 Monitor dashboards and refine performance
 Decisions
 Group vs. individual reporting
 Quality measure selection and corresponding performance
improvement
 Improvement activities selection and execution
 Keep 2019 requirements in mind when determining 2018 strategy
 Assess potential reporting mechanism(s)
 Review previous cost performance (QRUR) reports
 Evaluate future APM participation

36. Page 36
Action Items
 Continue educating providers
 Decisions
 Group vs. individual reporting
 Reporting mechanism
 Quality measure selection and corresponding performance
improvement
 Improvement activities selection and execution
 Keep 2019 requirements in mind when determining 2018
strategy
 Review previous cost performance (QRUR) reports
 Evaluate future APM participation
 Monitor dashboards and refine performance

37. Page 37
Contact Information
Allison P. Wilson, CMPE, PHR, PCMH CCE
Manager
awilson@pyapc.com
PYA, P.C.
(404) 266-9876
www.pyapc.com