Welcome The AAMC, UHC and FPSC Web Conference on 2014 PQRS Proposed Changes will begin shortly.

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1 Welcome The AAMC, UHC and FPSC Web Conference on 2014 PQRS Proposed Changes will begin shortly. Please do not place your phones on hold. If you need to leave the event, hang up and dial back into the conference. We ask that you mute your own phones to prevent background noise. Today s event is being recorded. Your cooperation is greatly appreciated. Dial-in number: Meeting ID number: Attendee ID number: Don t Forget to Enter! Located on the Info Tab in WebEx For help: WebEx Technical Support , AAMC-UHC-FPSC Page 1

2 Proposed Changes to 2014 PQRS in Medicare PFS Proposed Rule August 14, , AAMC-UHC-FPSC Page 2

3 When you called in, did you enter your attendee ID number? Dial-in number: Meeting ID number: Attendee ID number: Located on the Info Tab in WebEx Housekeeping Phone lines are muted; we will be un-muting phone lines throughout the call Please do not place your phones on hold If you need to leave the event, hang up and dial back into the conference Mute your own phones to prevent background noise To ask a question, use right-side of the WebEx Viewer Raise hand Send question to the host using the Q&A section 2013, AAMC-UHC-FPSC Page 3

4 Today s Objectives Provide an overview of the proposed changes to PQRS and the value modifier programs Help you choose the right PQRS option for your group Outline pathway for groups to consider reporting options Leave you with a checklist for next steps Gather feedback about proposals for comment to CMS 2013, AAMC-UHC-FPSC Page 4

5 Checklist for Next Steps Before October 15 th 1. Get IACS account and establish PV-PQRS role for all TINs If you have any unresolved issues or need help with establishing this account, let us know 2. Default: Select administrative claims for groups Can change the option through October 15, but this will protect the group from 2015 PQRS and VM penalties 3. Download the Quality Resource Use Reports Available September 15 from QualityNet PV-PQRS role can do this Learn about results from quality tiering Next Steps 1. Evaluate PQRS options for , AAMC-UHC-FPSC Page 5

6 Payments Rates Will be Significantly Affected by Reporting/ Performance 2014 erx Penalty (-2%) 2% at risk for 2014 (erx Incentive Program) Up to 6% at risk in 2016 (based on 2014 data) Additional increases for future years 2014 PQRS Incentive (0.5%) 2014 EHR Incentive 2014 Calendar Year 2016 PQRS Penalty 2016 EHR Incentive Penalty 2.0% reduction if not successful reporting PQRS measures 2.0% reduction Attest for MU in 2014* * If first year of MU, EPs can attest up until October Value Modifier Automatic 2% reduction if not reporting PQRS data; OR Up to 2% at risk based on quality/cost performance for large group practices 2013, AAMC-UHC-FPSC Page 6

7 PQRS and VM Programs are Linked VM implementation in 2015 is based on PQRS participation in 2013 Groups of physicians with > 100 eligible professionals PQRS Participation Groups that register for PQRS GPRO (via web interface, registry or CMS- calculated admin claims ) and meet the minimum reporting requirement Non-PQRS Participation Groups that do not register for PQRS GPRO and do not meet the minimum reporting requirement. Elect quality-tiering calculation Source: CMS Upward, downward, or no adjustment based on performance 0.0% (no adjustment) -1% (downward adjustment) VM adjustment in addition to -1.5% PQRS penalty for not reporting.

8 Outputs Calculation Inputs Another View of the Value Modifier Groups decide which PQRS/quality reporting to choose. Automatic penalty for not submitting PQRS data. PQRS Data + Non-PQRS Outcome Measures (from claims) Cost Measures (from claims) CMS Calculates Quality and Cost Composite Scores Quality Composite Score Cost Composite Score CMS releases report with benchmark data to groups. Medicare Part B payments adjusted based on scores. Private Feedback Report Quality & Resource Use Reports (QRUR) Pay-for- Performance Payment Adjustment based on scores (Quality Tiering) 8 Gray - Data supplied by physician groups Green Data supplied by CMS 2013, AAMC-UHC-FPSC Page 8

9 Quality-Tiering Approach for 2015 Each group receives two composite scores (quality of care; cost of care), based on the group s standardized performance (e.g., how far away from the national mean). This approach identifies statistically significant outliers and assigns them to their respective cost and quality tiers. Low cost Average cost High cost High quality +2.0x* +1.0x* +0.0% Average quality +1.0x* +0.0% -0.5% Low quality +0.0% -0.5% -1.0% * *Eligible for an additional +1.0x if : Reporting quality measures via the web based interface or registries AND Average beneficiary risk score in the top 25% of all beneficiary risk scores Source: CMS 2013, AAMC-UHC-FPSC Page 9 9

10 Value Modifier 2015 Policies & 2016 Proposals Value Modifier Components 2015 Finalized Policies 2016 Proposed Policies Performance Year Group Size Available Quality Reporting Mechanisms Outcome Measures Patient Experience of Care Measures GPRO-Web Interface, CMS Qualified Registries, Administrative Claims All Cause Readmission Composite of Acute Prevention Quality Indicators: (bacterial pneumonia, urinary tract infection, dehydration) Composite of Chronic Prevention Quality Indicators: (chronic obstructive pulmonary disease (COPD), heart failure, diabetes) N/A GPRO-Web Interface, CMS Qualified Registries, EHRs, and 70% of EPs reporting individually Same as 2015 PQRS CAHPS: Option for groups of 25+ EPs Source: CMS 10

11 Value Modifier 2015 Policies & 2016 Proposals (continued) Value Modifier Components Cost Measures 2015 Finalized Policies Total per capita costs measure (annual payment standardized and riskadjusted Part A and Part B costs) Total per capita costs for beneficiaries with four chronic conditions: COPD, Heart Failure, Coronary Artery Disease, Diabetes Same as 2015 and 2016 Proposed Policies Medicare Spending Per Beneficiary measure (includes Part A and B costs during the 3 days before and 30 days after an inpatient hospitalization) Benchmarks Group Comparison Specialty Adjusted Group Cost Quality Tiering Optional Mandatory Groups of EPs receive only the upward adjustment, no downward adjustment Payment at Risk -1.0% -2.0% Source: CMS 11

12 Timeline for VM that Applies to Payment Starting January 1, 2016 October Registration closes 1 st Quarter Complete submission of 2013 information for PQRS January 1 VM applied to physicians in groups of > 100 EPs 1 st Quarter Complete submission of 2014 information for PQRS January 1 VM applied to physicians in groups of > 100 EPs and to physicians in groups of rd Quarter Retrieve 2012 Physician Feedback reports (Groups of 25+) May 1- September Registration period 3 rd Quarter Retrieve 2013 Physician Feedback reports (All Groups and Solo Practitioners) 3 rd Quarter Retrieve 2014 reports (All Groups and Solo Practitoners) Source: CMS 12

13 A Closer Look at the 2013 Group Reporting Options for Large Groups Item GPRO Web Registry Administrative Claims Effective Date 2013 forward 2013 forward 2013 only Measure selection Pre-determined (18 measures) Practice selects from available PQRS measures (at least 3 measures) Pre-determined (14 process measures and 3 outcomes) Submission Process XML Web Tool Registry submits data on groups behalf Groups register but do not need to submit data Reporting requirements Populate data fields for the first 411 consecutively ranked and assigned beneficiaries in the order in which they appear in the group's sample Report each measure for at least 80 percent of the group practice's Medicare Part B FFS patients seen during the reporting period to which the measure applies. Claims data is used to evaluate performance on 14 quality measures and 3 outcome measures Individual PQRS can also be reported Public Reporting of 2013 Performance Data 2013 performance data and patient experience (CG-CAHPS) publicly reported on Physician Compare No public reporting No public reporting Assignment of Patients/Beneficiaries CMS assigns using 2-step primary care attribution Registry/groups identify the patients based on measure specifications CMS assigns using 2-step primary care attribution Qualifies for EHR Clinical Quality Measures (CQM) Yes (starting in 2014) if using CEHRT No No Effect on Incentives and Penalties (Incentives require successful reporting) - Avoids the 2015 PQRS and VM penalty - Qualifies for 2013 and 2014 PQRS incentive - Avoids the 2015 PQRS and VM penalty - Qualifies for 2013 and 2014 PQRS incentive - Avoid the 2015 PQRS and VM penalty - No PQRS incentives 2013, AAMC-UHC-FPSC Page 13

14 What PQRS Reporting Option to Choose? Strategic questions to consider: Individual or group reporting Reporting mechanism Alignment with Medicare EHR Program Number and variety of TINs Available resources (staff, etc.) Will performance data be publically reported? 2013, AAMC-UHC-FPSC Page 14

15 2014 PQRS/Physician Compare Proposals Group reporting Restrict GPRO Web for groups of 100+ EPs CG-CAHPS submission option for groups 25+ EPs CG-CAHPS must be in conjunction with EHR or Registry reporting Individual reporting Increased the number of required measures 9 measures/3 domains New reporting mechanism: Qualified Clinical Data Registry Different from previous PQRS registry reporting Proposal for hospital-based EPs to report Inpatient Quality Reporting (IQR) measures Physician Compare Plan to publish in 2015 a select number of measures for all groups and individuals reporting those measures in 2014 reporting period 2013, AAMC-UHC-FPSC Page 15

16 Group v. Individual Reporting Pros Cons Group Reporting Simpler to track single set of measures Protects everyone in group from 4% automatic penalties for not reporting PQRS data Measures may not resonate with all eligible professionals (EPs) in the group Measure denominators could include patients from practice for whom the measure the is not relevant. (ex. Patient, with comorbid diabetes, is referred to specialist for another reason, may be included in diabetes measure.) Individual Reporting EPs select measures that resonate with them Complex to identify and track measures for variety of EPs Need to track payment adjustments for individual EPs Individuals EPs that do not have measures are vulnerable to PQRS adjustment 2013, AAMC-UHC-FPSC Page 16

17 2014 PQRS Proposed Reporting Mechanisms Reporting Mechanism Group Individual Reporting Requirements Timing / Commitment Other Comments GPRO Web + (CG-CAHPS) X 18 predetermined measures for a sample of patient Registry X X 9 measures/3 domains for 50% of applicable patients EHR X X 9 measures/3 domains EHR must be certified for measures. Annual submission Approximately two month window to report Registry submits annually. Annual submission from institutions EHR. Available to groups with 100 or more EPs CMS will pay for CG-CAHPS in mo reporting option for individuals reporting measures groups. Measures groups available for individuals only. EHR/Registry + CG-CAHPS X CG-CAHPS required measures AND 6 measures/2 domains from EHR/Registry Claims X 9 measures/3 domains unless fewer than 9 measures apply for 50% of Medicare Part B Pts. Qualified Clinical Data Registry Hospital-based Physicians Administrative Claims X 9 measures/3 domains for 50% of applicable patients X X OPTIONAL: Use IQR measures CMS to identify patients to be surveyed. Annual submission. Report concurrently with claims submission. Registry submits data annually. Available to groups with 25 or more EPs. Groups must use a certified survey vendor. Only option for EPs with fewer than 9 measures. Cannot correct quality measures. New reporting option for individuals only. Reporting option might align with EHR Incentive Program. See slide 23 for more details n/a n/a n/a n/a Available for 2013 only 2013, AAMC-UHC-FPSC Page 17

18 Reasons to align EHR Alignment One submission for the clinical quality measures (CQM) for EHR and PQRS Aligns resources for meaningful use and PQRS reporting Reasons to defer alignment Concerns about EHR data validity, especially for data that will be used for VM EHR submission may not cover all EPs Medicaid EPs and first-time attesters may not be included in attestation Timing of EHR implementation/stage 2 upgrades Remaining questions about how EHR Incentive Program and PQRS will interface 2013, AAMC-UHC-FPSC Page 18

19 More about EHR Reporting Not much in 2014 PFS Proposed Rule about how PQRS and EHR align for group reporting Conversations with CMS indicate: For GPRO Web, ACOs: Rules for EHR submission will be based on PQRS reporting requirements. Need to attest to using CEHRT.. For Group CQM Submission: CMS will get a list of NPIs for the groups that did CQM submission. All Medicare EPs will get credit for CQM. States need to determine whether Medicaid EPs are covered. First time attesters (reporting 1 quarter of data by October 1) will not be covered 2013, AAMC-UHC-FPSC Page 19

20 More about EHR Reporting Questions still outstanding: Does it matter if you do not upgrade until to Stage 2 until midyear? Does the entire groups report on the same set of 9 measures/3 domains? Does it matter if an individual EPs have zero denominator within group submission? Other questions? 2013, AAMC-UHC-FPSC Page 20

21 CG-CAHPS Certified Survey Vendor Optional: groups with 25 or more EPs can report CG- CAHPS along with an EHR/Registry submission CG-CAHPS must be reported with another reporting option Administration CMS identifies patient population based on E/M visits Group contracts with certified vendor CMS will pay for administration in 2014 for ACOs, GPRO Web Required Questions Getting timely care appointments, and info* How well providers communicate* Patient s rating of provider* Access to specialists Health promotion & education* Shared decision making Health status/functional status Courteous and helpful office staff Care coordination Between visit communication Helping you to take your medication as directed Stewardship of patient resources * Performance reported on Physician Compare 2013, AAMC-UHC-FPSC Page 21

22 Qualified Clinical Data Registries Proposed Definition for Qualified Clinical Data Registry A CMS-approved entity (such as a registry, certification board, collaborative, etc.) that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care furnished to patients Must be able to: Submit quality measures data or results to CMS; Must have at least 9 measures/3 domains, including one outcome measure Submit quality measures data on multiple payers; Provide timely feedback at least quarterly; AND Possess a method to benchmark the quality of care measures provided by an EP with that of other EPs performing the same or similar functions QCDR must nominate themselves Option only available to individuals May be able to get credit for EHR Incentive Program , AAMC-UHC-FPSC Page 22

23 Reporting for Hospital-Based EPs Proposal for hospital-based physicians Proposed: report retooled Inpatient Quality Reporting (IQR) measures via registry Alternative: Attribute hospital IQR performance to individual or group practice Need mechanism to determine which hospital should be attributed performance 2013, AAMC-UHC-FPSC Page 23

24 Physician Compare CMS is proposing to publicly display the following measures that are submitted by groups or individuals through GPRO Web, EHR, or Registry Diabetes: Hemoglobin A1c Poor Control Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD) Medication Reconciliation Preventive Care and Screening: Influenza Immunization Pneumococcal Vaccination Status for Older Adults Preventive Care and Screening: Breast Cancer Screening. Colorectal Cancer Screening Coronary Artery Disease (CAD): Angiotensinconverting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy Diabetes or Left Ventricular Systolic Dysfunction (LVEF < 40%) Adult Weight Screening and Follow-Up Preventive Care and Screening: Screening for Clinical Depression Coronary Artery Disease (CAD): Lipid Control Ischemic Vascular Disease (IVD): Use of Aspirin or Another Antithrombotic. Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention. Hypertension (HTN): Controlling High Blood Pressure Ischemic Vascular Disease (IVD): Complete Lipid Panel and LDL Control Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented PLUS: Selected CG-CAHPS Measures 2013, AAMC-UHC-FPSC Page 24

25 Reminder: Checklist for Next Steps Before October 15 th 1. Get IACS account and establish PV-PQRS role for all TINs If you have any unresolved issues or need help with establishing this account, let us know 2. Default: Select administrative claims for groups Can change the option through October 15, but this will protect the group from 2015 PQRS and VM penalties 3. Download the Quality Resource Use Reports Available September 15 from QualityNet PV-PQRS role can do this Learn about results from quality tiering Next Steps 1. Evaluate PQRS options for , AAMC-UHC-FPSC Page 25

26 Why Download QRUR? First look at cost and quality performance for value modifier Gauge performance for electing quality tiering in 2013 Data file will include: Drill down table including beneficiaries attributed to the group, their resource use, specific chronic diseases Drill down table including all hospitalizations for attributed beneficiaries Drill down table of individual EP PQRS reporting (December 2013) Assess areas that affect your performance related to costs and utilization Findings from Academic GPRO QRUR Benchmarking Project 2013, AAMC-UHC-FPSC Page 26

27 Total Per Capita Costs 2013, AAMC-UHC-FPSC Page $20,000 $18,000 $16,000 Academic GPRO QRUR Benchmarking Project Highlights Overall Per Capita Costs Higher Among Academic Cohort $14,000 $12,000 $10,000 $8,000 $6,000 $4,000 $2,000 $ Organization Before Risk Adjustment After Risk Adjustment National Mean Academic Mean Downward risk adjustment for almost all academic groups confirms that this cohort has higher than average proportion of patients with serious medical conditions or other high cost risk factors.

28 Member s Cost Minus National Mean Member s Cost Minus National Mean Not One Service Drives the Difference in Costs Among Inpatient Hospital Academic Cohort $1,400 $1,200 1 $1,000 $ $ $ $ $- $(200) 4 16 $(400) 12 $(600) $(800) 11 $2,500 $2,000 Outpatient Hospital 7 9 $1,500 $1,000 $500 $ $(500) 2 11 National Mean for Hospital Inpatient Per Capita Costs = $3,036 National Mean for Hospital Outpatient Per Capita Costs = $3, , AAMC-UHC-FPSC Page 28

29 Per Capita Costs by Disease Type Show Trends by Organization <25th Percentile 25th - 50th Percentile 50th - 75th Percentile >75th Percentile 2013, AAMC-UHC-FPSC Page 29

30 2014 Physician Fee Schedule Webinar Series Materials and Recordings 1) Registering for Group Reporting and Proposed Policies for the Value Based Modifier CME/CEU available for this session 2) Payment Policies in 2014 Physician Fee Schedule Proposed Rule 3) Proposed Changes to the 2014 PQRS Reporting Materials posted to , AAMC-UHC-FPSC Page 30

31 Questions What comments/feedback do you have about current 2014 PQRS & VM proposals? Option for individual reporting for value modifier & 70% threshold Preferences for hospitalist reporting Removal of administrative claims Increase in value modifier & mandatory quality tiering Feedback on EHR option Feedback on CG-CAHPS option What else do you need to know to make an informed decision about which PQRS option to pursue in 2014? How can we help you navigate your options? Consider: Educational materials Networking Interpretation of options and data 2013, AAMC-UHC-FPSC Page 31

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