Agenda MACRA. MIPS Impact to providers Impact to AC. Questions & Comments. APM vs MIPS. AC User Survey AC Certification

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1 MACRA Overview

2 Agenda MACRA APM vs MIPS MIPS Impact to providers Impact to AC AC User Survey AC Certification Questions & Comments 2

3 APMs vs MIPS Alternate Payment Models vs Merit Based Incentive Payment System 3

4 Alternate Payment Models Clinicians that participate in an approved APM will be exempt from MIPS reporting. APM ACOs: Next Generation PCMH(?) CPC+ (5K?) CMS Innovation Center Models Largely for Enterprise practice models Based on Quality measures comparable to MIPS Must use certified EHR technology Practice bears financial risk for non-compliance 4

5 MIPS Consolidates Existing Programs Physician Quality Reporting (PQRS) Meaningful Use Value Based Modifier MIPS

6 MIPS Impact to Providers 6

7 Composite Scoring Quality 0-50 Advanced Care Information (ACI) 0-25 Clinical practice improvement activities (CPI) 0-15 Resource Use Points, < 25 points is penalty threshold MIPS Composite Performance Score 0-100

8 MIPS Impact to Reimbursement Based on the MIPS composite score the clinician achieves, reimbursement in future years will be increased or reduced. 8

9 MACRA Timeline 9

10 Quality Data Submission = 50% of MIPS Score Performance Period Measure Type Submission Submission Mechanism Submission Criteria Data Completeness Jan 1 Dec 31 Individual MIPS eligible Clinicians Part B Claims Report at least six measures including one cross-cutting measure and at least one outcome measure, or if an outcome measure is not available report another high priority measure; if less than six measures apply then report on each measure that is applicable. MIPS eligible clinicians and groups will have to select their measures from either the list of all MIPS Measures in Table A or a set of specialty specific measures in Table E. 80 percent of MIPS eligible clinician s patients Jan 1 Dec 31 Individual MIPS eligible clinicians or Groups QCDR Qualified Registry EHR Report at least six measures including one cross-cutting measure and at least one outcome measure, or if an outcome measure is not available report another high priority measure; if less than six measures apply then report on each measure that is applicable. MIPS eligible clinicians and groups will have to select their measures from either the list of all MIPS Measures in Table A or a set of specialty specific measures in Table E. 90 percent of MIPS eligible clinician s or groups patients 10

11 Reporting Mechanisms The rule proposes to allow third parties to act as intermediaries on behalf of clinicians and submit data for the performance categories as applicable. Registries Qualified Clinical Data Registries Health information technology developers Certified survey vendors Note that all clinical measures must be captured within an ONC certified EHR module 11

12 Advancing Care Information (ACI) 25% of total score in 1 st year Includes a base score and a performance Score Replaces Medicare EHR Incentive Program (Meaningful Use) for Medicare Part B submitters Report customizable measures that reflect how they use electronic health record (EHR) technology in their day-to-day practice Emphasis on interoperability and information exchange Would not require all-or-nothing EHR measurement or quarterly reporting No longer require reporting Clinical Decision Support Computerized Provider Order Entry 12

13 ACI Base Score ONC 2015 Certified Technology (up to 50 points of the 100 points for this category ) Protect Patient Health Information (yes/no) Electronic Prescribing (numerator/denominator) Patient Electronic Access (numerator/denominator) Health Information Exchange (numerator/denominator) Coordination of Care Through Patient Engagement (numerator/denominator) Public Health and Clinical Data Registry Reporting (yes/no) 13

14 Advancing Care Information Performance Score Accounts for up to 80 points Score can exceed 100 points, but anyone who score 100 points or above will receive the maximum 25 points towards the MIPS score. Clinicians select the measures that best fit their practice Patient Electronic Access Coordination of Care Through Patient Engagement Health Information Exchange Immunization Registry is required May report on more than one public health registry Receive one additional point for reporting beyond the immunization category. 14

15 Base Score : ACI Objective Measure Total Base Score 1 Protect Patient Health Information Security Risk Analysis 50% 2 Electronic Prescribing eprescribing 3 Patient Electronic Access Patient Access Patient-Specific Education 4 Coordination of Care Through Patient Engagement View, Download or Transmit (VDT) Secure Messaging Patient-Generated Health Data 5 Health Information Exchange Patient Patient Care Record Exchange Request/Accept Record Exchange Clinical Information Reconciliation 6 Public Health and Clinical Data Registry Reporting Immunization Registry Reporting (Optional) Syndromic Surveillance Reporting (Optional) Electronic Case Reporting (Optional) Public Health Registry Reporting (Optional) Clinical Data Registry Reporting 15

16 Clinical Practice Improvement 15% of total score in 1 st year Activities focused on care coordination, beneficiary engagement, and patient safety Select activities that match their practices goals from a list of more than 90 options Clinicians would receive credit in this category for participating in Alternative Payment Models and in Patient-Centered Medical Homes. 16

17 Clinical Practice Improvement Maximum - 60 points Highly weighted activities 20 points Other activities 10 points 17

18 Resource Use = Cost 10% of total score in the first year Based on Medicare claims Uses more than 40 episode-specific measures to account for differences among specialties. MIPS calculates scores based on Medicare claims No additional reporting requirements for clinicians under the cost category Each cost measure would be worth up to 10 points 18

19 Addenda : MIPS Program Specifics (as of August, 2016) 19

20 Objective and Measures detail Objective Measure Measure Description Attestation 1 Protect Patient Health Information Protect electronic protected health information (ephi) created or maintained by the certified EHR technology through the implementation of appropriate technical, administrative, and physical safeguards Security Risk Analysis Conduct or review a security risk analysis in accordance with the requirements in 45 CFR (a)(1), including addressing the security (to include encryption) of ephi data created or maintained by certified EHR technology in accordance with requirements in 45 CFR (a)(2)(iv) and 45 CFR (d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician s risk management process. Yes/No 2 Electronic Prescribing MIPS eligible clinicians must generate and transmit permissible prescriptions electronically. eprescribing At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology. Denominator: Number of prescriptions written for drugs requiring a prescription in order to be dispensed other than controlled substances during the performance period; or number of prescriptions written for drugs requiring a prescription in order to be dispensed during the performance period. Numerator: The number of prescriptions in the denominator generated, queried for a drug formulary, and transmitted electronically using certified EHR technology. 20

21 Objective and Measures- detail Objective Measure Measure Description Attestation 3 Clinical Decision Support (CDS) - Alternate Only Implement clinical decision support (CDS) interventions focused on improving performance on high-priority health conditions Clinical Decision Support (CDS) Interventions Implement three clinical decision support interventions related to three CQMs at a relevant point in patient care for the entire performance period. Absent three CQMs related to a MIPS eligible clinician s scope of practice or patient population, the clinical decision support interventions must be related to high priority health conditions. Yes/No Drug Interaction and Drug- Allergy Checks The MIPS eligible clinician has enabled and implemented the functionality for drug-drug and drug-allergy interaction checks for the entire performance period. 21

22 Objective and Measures Objective Measure Measure Description Attestation 4 Computerized Provider Order Entry (CPOE) - Alternate Only Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant, who can enter orders into the medical record per state, local, and professional guidelines. Medication Orders Laboratory Orders Diagnostic Imaging Orders At least one medication order created by the MIPS eligible clinician during the performance period is recorded using CPOE. At least one laboratory order created by the MIPS eligible clinician during the performance period is recorded using CPOE At least one diagnostic imaging order created by the MIPS eligible clinician during the performance period is recorded using CPOE Denominator: Number of medication orders created by the MIPS eligible clinician during the performance period. Numerator: The number of orders in the denominator recorded using CPOE. Denominator: Number of laboratory orders created by the MIPS eligible clinician during the performance period. Numerator: The number of orders in the denominator recorded using CPOE. Denominator: Number of diagnostic imaging orders created by the MIPS eligible clinician during the performance period. Numerator: The number of orders in the denominator recorded using CPOE. 22

23 Objective and Measures detail Objective Measure Measure Description Attestation 5 Patient Electronic Access The MIPS eligible clinician provides patients (or patient authorized representative) with timely electronic access to their health information and patient-specific education. Patient Access View, Download or Transmit (VDT) For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient s health information is available for the patient (or patient authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programing Interface (API) in the MIPS eligible clinician s certified EHR technology. Denominator: The number of unique patients seen by the MIPS eligible clinician during the performance period. Numerator: The number of patients in the denominator (or patient authorized representative) who are provided timely access to health information to view online, download, and transmit to a third party and to access using an application of their choice that is configured meet the technical specifications of the API in the MIPS eligible clinician s certified EHR technology. 6 Patient-Specific Education Patient-Specific Education The MIPS eligible clinician must use clinically relevant information from certified EHR technology to identify patient-specific educational resources and provide electronic access to those materials to at least one unique patient seen by the MIPS eligible clinician. Denominator: The number of unique patients seen by the MIPS eligible clinician during the performance period. The number of patients in the denominator who were provided electronic access to patient-specific educational resources using clinically relevant information identified from certified EHR technology during the performance period. 23

24 Objective and Measures- detail Objective Measure Measure Description Attestation Coordination of Care Through Patient Engagement Use certified EHR technology to engage with patients or their authorized representatives about the patient s care. View, Download, Transmit (VDT) During the performance period, at least one unique patient (or patient-authorized representatives) seen by the MIPS eligible clinician actively engages with the EHR made accessible by the MIPS eligible clinician. An MIPS eligible clinician may meet the measure by either (1) view, download or transmit to a third party their health information; or (2) access their health information through the use of an API that can be used by applications chosen by the patient and configured to the API in the MIPS eligible clinician s certified EHR technology; or (3) a combination of (1) and (2). Denominator: Number of unique patients seen by the MIPS eligible clinician during the performance period. Numerator: The number of unique patients (or their authorized representatives) in the denominator who have viewed online, downloaded, or transmitted to a third party the patient s health information during the performance period and the number of unique patients (or their authorized representatives) in the denominator who have accessed their health information through the use of an API during the performance period. 7 Secure Messaging Secure Messaging For at least one unique patient seen by the MIPS eligible clinician during the performance period, a secure message was sent using the electronic messaging function of certified EHR technology to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative). Denominator: Number of unique patients seen by the MIPS eligible clinician during the performance period. Numerator: The number of patients in the denominator for whom a secure electronic message is sent to the patient (or patient-authorized representative) or in response to a secure message sent by the patient (or patient-authorized representative), during the performance period. 24

25 Objective and Measures - detail Objective Measure Measure Description Attestation Coordination of Care Through Patient Engagement Use certified EHR technology to engage with patients or their authorized representatives about the patient s care. Patient-Generated Health Data Measure Patient-generated health data or data from a nonclinical setting is incorporated into the certified EHR technology for at least one unique patient seen by the MIPS eligible clinician during the performance period. Denominator: Number of unique patients seen by the MIPS eligible clinician during the performance period. Numerator: The number of patients in the denominator for whom data from nonclinical settings, which may include patient-generated health data, is captured through the certified EHR technology into the patient record during the performance period. 25

26 Objective and Measures Objective Measure Measure Description Attestation 8 Health Information Exchange The MIPS eligible clinician provides a summary of care record when transitioning or referring their patient to another setting of care, receives or retrieves a summary of care record upon the receipt of a transition or referral or upon the first patient encounter with a new patient, and incorporates summary of care information from other health care providers into their EHR using the functions of certified EHR technology. Patient Care Record Exchange Request/Accept Patient Care Record Clinical Information Reconciliation For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider (1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record. For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or retrieves and incorporates into the patient s record an electronic summary of care document. For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician performs clinical information reconciliation. The clinician must implement clinical information reconciliation for the following three clinical information sets: (1) Medication. Review of the patient s medication, including the name, dosage, frequency, and route of each medication. (2) Medication allergy. Review of the patient s known medication allergies. (3) Current Problem list. Review of the patient s current and active diagnoses. Denominator: Number of transitions of care and referrals during the performance period for which the MIPS eligible clinician was the transferring or referring clinician. Numerator: The number of transitions of care and referrals in the denominator where a summary of care record was created using certified EHR technology and exchanged electronically. Denominator: Number of patient encounters during the performance period for which a MIPS eligible clinician was the receiving party of a transition or referral or has never before encountered the patient and for which an electronic summary of care record is available. Numerator: Number of patient encounters in the denominator where an electronic summary of care record received is incorporated by the clinician into the certified EHR technology. Denominator: Number of transitions of care or referrals during the performance period for which the MIPS eligible clinician was the recipient of the transition or referral or has never before encountered the patient. Numerator: The number of transitions of care or referrals in the denominator where the following three clinical information reconciliations were performed: Medication list, medication allergy list, and current problem list. 26

27 Objective and Measures Objective Measure Measure Description Attestation 9 Public Health and Clinical Data Registry Reporting The MIPS eligible clinician is in active engagement with a public health agency or clinical data registry to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice. Immunization Registry Reporting (Optional) Syndromic Surveillance Reporting The MIPS eligible clinician is in active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS). The MIPS eligible clinician is in active engagement with a public health agency to submit syndromic surveillance data from a non-urgent care ambulatory setting where the jurisdiction accepts syndromic data from such settings and the standards are clearly defined. Yes/No (Optional) Electronic Case Reporting The MIPS eligible clinician is in active engagement with a public health agency to electronically submit case reporting of reportable conditions. (Optional) Public Health Registry Reporting The MIPS eligible clinician is in active engagement with a public health agency to submit data to public health registries. (Optional) Clinical Data Registry Reporting The MIPS eligible clinician is in active engagement to submit data to a clinical data registry. 27