Regulatory Outlook: Knock MACRA Out of the Park
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Review the latest changes to the regulatory landscape, including HIPAA, MACRA, and the NC HIE. Learn how these changes impact your clients and your business.
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Regulatory Outlook: Knock MACRA Out of the Park
- 1. Knock MACRA out of the Park Presented By Marina Verdara
- 2. 22 Marina Verdara • Over 8 years of experience working directly with several hundred small practice clinicians on a variety of projects specializing on CMS Incentive programs such as Meaningful Use, PQRS, and MACRA. • In my current role, I help clinicians understand the Quality Payment Program and maximize the use of Kareo Clinical EHR to meet the requirements for MIPS. Sr. Training Specialist CMS Incentive Programs About me
- 3. 3 Agenda • Welcome & Introductions • Understanding MACRA • Team 1: APM • Team 2: MIPS • What’s Your Strategy • Payment Adjustments • Questions
- 4. You Can’t Steal First Base. You Must Understand MACRA.
- 5. 55 MACRA Layout and Dimensions MACRA MIPS Quality 45% - Report up to 6 measures - Full year reporting Promoting Interoperability 25% - 4 objectives - 90 days up to a full year reporting Improvement Activities 15% - Submit 40 points to earn full credit Cost 15% - 10 measures evaluated - Data submission not required APM ACOs Specialty Specific Programs State Specific Programs
- 6. Team #1 Alternative Payment Models (APMs)
- 7. 77 APMs are CMS’s payment approach that gives additional incentive payments to clinicians who provide high-quality and cost efficient care to their patients. Types of APMs: • APMs • MIPS APMs • Advanced APMs • Advanced MIPS APMs • All-Payer/Other-Payer Option Alternative Payment Models
- 8. 88 Important facts to know about APMs: • These are Medicare Incentive programs • They are managed by local medical entities such as hospitals, medical groups, or IPAs • Most are known ACOs • The APM/ACO administrator assigns quality measures to clinicians • Clinicians might also be required to submit data for MIPS • Every kind of APM has it’s own requirements and thresholds • Encourage your clinicians to partner up with the medical entity who invited them to join APM Alternative Payment Models
- 9. 99 2019 Approved APMs • Bundled Payments for Care Improvement Advanced Model (BPCI Advanced) • Comprehensive ESRD Care (CEC) Model LDO Arrangement • Comprehensive ESRD Care (CEC) Model non-LDO Two-Sided Risk Arrangement • Comprehensive ESRD Care (CEC) –Model non-LDO one-Sided Risk Arrangement • Comprehensive Primary Care Plus (CPC+) • Medicare Accountable Care Organization (ACO) Track 1+ Model • Next Generation ACO Model • Shared Savings Program - Track 2 • Shared Savings Program - Track 3 • Oncology Care Model (OCM) - Two-Sided Risk • Oncology Care Model (OCM) - One-Sided Risk • Vermont Medicare ACO Initiative • Maryland Primary Care Program • Independence at Home Demonstration Alternative Payment Models
- 10. Team #2 Merit-Based Incentive Payment System (MIPS)
- 11. 1111 How are Players Drafted? Clinicians are eligible if they meet or exceed the three low-volume threshold criteria: 1. Bill Medicare over $90,000 in Part B allowed charges a year, and 2. Provide care to more than 200 Medicare Part B patients, and 3. Provide 200 or more covered professional services to Part B patients Clinician Types: • Physician • Physician Assistant • Nurse Practitioner • Clinical Nurse Specialist • Certified Registered Nurse Anesthetist • Physical Therapist • Occupational Therapist • Clinical Psychologist • Qualified Speech-Language Pathologist • Qualified Audiologists • Registered dietitians or Nutrition Professionals
- 12. 1212 Eligibility Determination The Review Periods to determine a clinician’s eligibility is: • October 1, 2017 – September 30, 2018 • October 1, 2018 – September 30, 2019 There are three participation options: Eligible Opt-In Option Voluntary Participation Meets or Exceeds ALL Low-Volume Threshold Criteria Meets or Exceeds One or Two Low-Volume Threshold Criteria Does NOT Meet or Exceed ANY Low-Volume Threshold Criteria ≥ 90k in Part B Charges, and ≥ 200 Part B Beneficiaries and ≥ 200 Professional Services ≥ 90k in Part B Charges, or ≥ 200 Part B Beneficiaries, or ≥ 200 Professional Services < 90k in Part B Charges < 200 Part B Beneficiaries < 200 Professional Services Will Receive Feedback Will Receive Feedback Will Receive Feedback Eligible for a Payment Adjustment Eligible for a Payment Adjustment NOT Eligible for a Payment Adjustment
- 13. 1313 Merit-based Incentive Payment Systems (MIPS) Quality • 6 Measures or a Full Specialty Set • 1 Outcome Measure or 1 High Priority Measure • Full Year Reporting • Submission Methods include Claims and Registry Submission •Improvement Activities (IA) • 10 Measures Evaluated • Based on Part B Claims Submitted All Year Long • No Additional Data Submission is Required Promoting Interoperability (PI) • ePrescribing • HIE (Health Information Exchange) • Provider to Patient Exchange • Public Health & Clinical Data Exchange • Protect Patient Health information •Cost • Submit 40 Points • Medium = 10 Points • High = 20 points • Points Double for Clinicians with a Special Status 45% 25% 15% 15%
- 14. 1414 2019 Score Board Quality 45% PI 25% IA 15% Cost 15% 100% 0 - 29 30 - 74 75 - 100 30 In MIPS, you have three options: 1. Hit a homerun: Submit as many points as possible to try to earn an incentive 2. Walk to first base: Submit enough points to avoid a negative payment adjustment 3. Strikeout: Earn a negative payment adjustment -7%
- 15. Loading the Bases What’s Your Strategy
- 16. 1616 MIPS 2019 Score Board Submit 60 points to earn full credit Submit 100 points to earn full credit Submit 40 points to Earn full credit Earn 100 points to earn full credit Get Creative: • Submit Quality Measures via claims • Help clinicians select Improvement Activities • Encourage clinicians to track their PI score • Ensure they submit their MIPS data during attestation period • Guide them during an audit Keep in Mind: • Extra points in the Quality Category • Extra points for additional Outcome measures • Extra points for additional High Priority Measures
- 17. 1717 What Can You Do? First Base: Understand MACRA Confirm MIPS/APM eligibility status for your customers Ask if they understand the requirements Take advantage of resources available to you Second Base: Take Action Create a team: include clinicians, staff and billers Refine your team’s knowledge on MIPS Select measures and submission options • Claims, registry, manual attestation Set goals and expectations and meet regularly • Find ways to incentivize team members for their good work. Create contests. Make it fun! Track your progress. Run reports twice per month
- 18. 1818 What Can You Do? Third Base: Attest Run your final reports in January 2020: Full Year for the Quality category 90 days up to a full year for the Promoting Interoperability Category Gather and save any supporting documentation for your selected improvement activities Submit your data prior to March 31, 2020 Score or Strike out? # of Clinicians Total Paid in Part B Claims per Year Assuming the National Maximum Payment adjustment is 2.3% Negative 7% 1 150,000 $ 3,450.00 $ (10,500.00) 2 260,000 $ 5,980.00 $ (18,200.00)
- 19. 1919 What’s Your Strategy? Calculate your possible financial gains or losses and ask yourself: Can I afford to leave money on the table? Am I willing to modify my workflow to improve my scores? Create a customized MIPS plan Can this be a new business opportunity for you? Recommendations: Partner up with clinicians to help them earn a positive payment adjustment Should you setup recurring meetings? Should you be involved in the attestation process? Offer small incentives: Lunch, bottle of wine, a gift card, etc.
- 20. 2020 Claims Submission Process • Go to the Quality section in the QPP website: Quality Measures • Use the Specialty Measure Set filter to select your specialty • Select Medicare Part B Claims Measures from the CollectionType filter • Review the measure descriptions carefully, then select six measures (include at least one outcome or high-priority measure) • Under Documentation, click on Claims Specifications to open its PDF file • Review and find the required codes then include them on Medicare claims as applicable • Claims submission must be done for the entire calendar year
- 21. 2121 The Benefits of Submitting Quality Measures via Claims include: • Save money: clinicians do not have to pay a registry to submit measures to CMS • Help clinicians avoid a negative payment adjustment Claims Submission
- 23. 2323 Payments Adjustments for 2017 0 - 2 4 - 74 75 - 100 Group Size Positive Payment Adjustment Count # Neutral Payment Adjustment Count # Negative Payment Adjustment Count # Individual (1) 55,240 20,137 2,225 Small Group (2 - 15) 23,539 670 20,014 Total 78,779 20,807 22,239 According to the CMS’s 2017 QPP Experience Report: 3 More than 22,000 clinicians could have avoided the 4% negative payment adjustment by submitting only…
- 24. 2424 Payment Adjustments Starting January 2019, Medicare Administrative Contractors (MAC) will use the three code types listed below to identify payment adjustments for the 2017 reporting year: • Claim Adjustment Reason Code (CARC): 144 for a positive payment adjustment and 237 for a regulatory penalty • Remittance Advice Remark Codes (RARCs): N807 –MIPS based payment adjustment • Group Code: CO for a regulatory requirement that resulted in an adjustment Clinicians will also receive a Medicare Summary Notice (MSN) every three months. If a payment adjustment was made, the MSN will indicate the following message: “This claim shows a quality reporting program adjustment”
- 25. 2525 Payment Adjustments Important facts about payment adjustments for 2017: • 93% of clinicians received a positive payment adjustment. Code used is CARC 144 • 5% received a negative payment adjustment. Code used is CARC 237 • ONLY 2% of clinicians received a neutral status • The national mean MIPS score was 74.01 • Clinicians in small practices received an average score of 43.46 points • The national mean APM score was 87.64 93% 5% 2% 2017 PAYMENT ADJUSTMENTS Positive Payment Adjustment Negative Payment Adjustment Neutral
- 26. 2626 Payment Adjustments • The minimum positive payment adjustment is 0.28% • The maximum positive payment adjustment for clinicians who submitted 70 to 100 points is • The negative 4% payment adjustment taken away from providers who ignored MIPS or submitted less than 3 points in 2017, is being used to pay the winners 1.88%
- 27. What’s in the Forecast?
- 28. 2828 Key proposals for 2020 performance year of the Quality Payment Program include: • Increasing the performance threshold from 30 points to 45 points • Revising category weights for Quality (decreases from 45% to 40%) and Cost (increases from 15% to 20%) • Increasing the data completeness threshold for the quality data that clinicians submit • Increasing the threshold for clinicians who complete or participate in the Improvement Activity for group reporting • Revising the specifications for the Total Per Capita Cost (TPCC) and Medicare Spending Per Beneficiary Clinician (MSPB Clinician) measures Proposed Rule for 2020
- 29. 2929 • Improve Beneficiary Outcomes • Reduce Burden on Clinicians • Maximize participation • Improve data and information sharing • Deliver IT System Capabilities that meet the needs of users What’s the Goal?
- 30. Resources
- 31. 3131 https://qpp.cms.gov/ Free Resources 1. Provider Name 2. NPI 3. Practice Name 4. Security Questions Kareo Support 888-775-2736 Helpme.Kareo.com
- 32. 3232 • Kareo Clinical • Platform Co-branding • Kareo Engage Success summit promotions Available Now through August 30th • Data Services • Discounted Reporting Package • Custom Note Types and EHR Template Development • Custom Online MACRA/MIPS Training Consult • Custom Onsite Training Available August 13 and 14 only: Refer a friend to Kareo and receive $500! Visit the Kareo Account Review table to learn more!
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Editor's Notes
- Click on #2 Click again on #3
- -Go over steps to find codes to submit measures via claims -ePrescribing: mention formularies -SRA: not scored, but it is mandatory -IA: Easy 15 points. Show them how to select IAs
- Ok, so based on what we’ve covered…
- MIPS “History” dates back to 2017