Your Guide to Understanding MACRA – MIPS – APMs - QPP

 

What is MACRA, MIPS, APMs, QPP?

  • MACRA

    Medicare Access and SHIP Reauthorization Act of 2015

  • MIPS

    Merit Based Incentive Payment System

  • APMs

    Advanced Alternative Payment Models

  • QPP

    Quality Payment Program

 

 

Helpful links

 

 

A Summary of what you need to know about the new mandates

The Centers for Medicare & Medicaid Services (CMS) released the final rule that will implement Quality Payment Program (QPP) as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Although QPP begins January 1, 2017, the first 2 years of the program there will be less financial risk. Allowing for providers time to navigate the requirements.

The Program has two paths for participation:

  • The Merit-based Incentive Payment System (MIPS)
  • Advanced Alternative Payment Models (APMs)

Best way to get ready for QPP, MACRA, MIPS (Merit Based Incentive Payment System) is to satisfy Meaningful Use Stage 2 (MU2) requirements and continue to work on meeting Clinical Quality Measures (CQM). CMS states providers already attesting to MU2 + PQRS will likely not have any new requirements.

 

 

Eligible clinicians can choose their pace of participation

Although the QPP will still begin January 1 2017, there will be a ramp-up period with less financial risk for eligible clinicians in at least the first two years of the program. Given the wide diversity of clinical practices, the initial development period of the QPP implementation would allow clinicians to pick their pace of participation for the QPP’s first performance period that begins January 1, 2017. As described by CMS in the final rule.

 

 

Reporting options

  • Clinicians can choose to report under the Merit-based Incentive Payment System (MIPS) for a full 90-day period or, ideally, the full year, and maximize the MIPS eligible clinician’s chances to qualify for a positive adjustment. In addition, MIPS eligible clinicians who are exceptional performers in MIPS, as shown by the practice information that they submit, are eligible for an additional positive adjustment for each year of the first 6 years of the program.
  • Clinicians can choose to report to MIPS for a period of time less than the full year performance period 2017 but for a full 90-day period at a minimum and report more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category in order to avoid a negative MIPS payment adjustment and to possibly receive a positive MIPS payment adjustment.
  • Clinicians can choose to report one measure in the quality performance category; one activity in the improvement activities performance category; or report the required measures of the advancing care information performance category and avoid a negative MIPS payment adjustment. Alternatively, if MIPS eligible clinicians choose to not report even one measure or activity, they will receive the full negative 4 percent adjustment.
  • MIPS eligible clinicians can participate in Advanced APMs, and if they receive a sufficient portion of their Medicare payments or see a sufficient portion of their Medicare patients through the Advanced APM, they will qualify for a 5 percent bonus incentive payment in 2019.

 

There are 2 exclusions: $30,000 Medicare per year OR 100 Medicare patients

 

 

Registry reporting and sign up requirements

Providers who have not signed up with a registry should do so now because they will need to report data to the registry. There are registries that are specialty specific, so check with your medical association for more information, specific to you and the state you are located in.

 

 

What will you be reporting?

Continue to follow MU2 and CQM guidelines. You will have to report at least 3 of 6 NQS areas. The 6 NQS areas are:

  1. Communication and Care Coordination
  2. Community/Population Health
  3. Effective Clinical Care
  4. Efficiency and Cost Reduction
  5. Patient Safety
  6. Person and Caregiver Centered Experience and outcomes

A list of all measures can be found here.

 

 

CMS estimates that over 90% of eligible clinicians will not be subject to a negative payment adjustment in the transition year

CMS estimates that over 90% of MIPS eligible clinicians will receive a positive or neutral MIPS payment adjustment in the transition year, and that at least 80% of clinicians in small and solo practices with 1-9 clinicians will receive a positive or neutral MIPS payment adjustment.

 

 

The MIPS score

After calculating a MIPS score, eligible professionals (EPs) may receive a payment bonus, a payment penalty or no payment adjustment. Unlike previous payment programs, scoring is no longer all-or-nothing but rather proportional to performance.

The proposed MIPS score will be based on four performance categories as follows:

  • Quality. Replaces the VM quality component and PQRS. 50% of total score in Year 1. These are measures related to patient outcomes, appropriate use of medical resources, patient safety, efficiency, patient experience and care coordination.
  • Cost. Also known as Resource Use. Replaces the VM cost component. 10% of total score in Year 1. These are specialty-based measures focused on efficient resource use. Cost measures would be solely based on Medicare claims, with no additional reporting requirements.
  • Clinical Practice Improvement Activities. 15% of total score in Year 1. These measures would focus on care coordination, beneficiary engagement and patient safety.
  • Advancing Care Information. Replaces Meaningful Use. 25% of total score in Year 1. These are measures that reflect on how well clinicians use EHR technology, especially when it comes to interoperability and information exchange.

The weight of each category will shift over time so that cost measures are a higher percentage of the MIPS score.

 

 

Summary of MIPS Performance Categories *

Performance Category Points Needed to Get a Full Score per Performance Category Category Percentage of MIPS Total Score
Quality Clinicians choose six measures to report to CMS that best reflect their practice. One of these measures must be an outcome measure or a high quality measure and one must be a crosscutting measure. Clinicians also can choose to report a specialty measure set. 80 to 90 points depending on group size 50%
Advancing Care Information Clinicians will report key measures of interoperability and information exchange. Clinicians are rewarded for their performance on measures that matter most to them. 100 Points 25%
Clinical Practice Improvement Activities Clinicians can choose the activities best suited for their practice; the rule proposes over 90 activities from which to choose. Clinicians participating in medical homes earn full credit in this category, and those participating in Advanced APMs will earn at least half credit. 60 Points 15%
Cost CMS will calculate these measures based on claims and availability of sufficient volume. Clinicians do not need to report anything. Average score of all resource measures that can be attributed. 10%

*These total percentages generally apply, but possible exemptions or adjustments may apply depending on a clinician or groups’ circumstances which would cause the total score for the category to be different.

Source: CMS Quality Payment Program

 

 

What is the timeline?

Year
QPP, MACRA, MIPS and APM Timeline
2015

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation passed and RFI public comments submitted to CMS.

2016

QPP Proposed and Final Rule released.

2017

MIPS first performance year begins. Multiple reporting options for providers allow them to pick an option that works best for their practices. Options to avoid a negative payment adjustment include reporting some data, a 90 day reporting period, and a full year reporting period. MIPS payment adjustments in 2019 will be based on performance in 2017.

01/01/2017

Providers who are ready to begin participating in the programs can start collecting performance data on Jan. 1, 2017 and could result in a positive payment adjustment. MIPS payment adjustments in 2019 will be based on performance in 2017.

10/02/2017

Providers who are not yet prepared to participate have until Oct. 2, 2017, to begin collecting performance data and still could qualify for a small positive payment adjustment. MIPS payment adjustments in 2019 will be based on performance in 2017.

01/01/2018

The performance period for MIPS is the full calendar year (Jan. 1 through Dec. 31) two years prior to the payment adjustment year. As such, MIPS payment adjustments in 2020 will be based on performance in 2019. 2018 reporting requirements are subject to change, and CMS will release more information in 2017.

03/31/2018

Participating providers must submit all data, regardless of when collection began in 2017, to CMS by March 31, 2018.

12/31/2018

MU, PQRS and VBM payment adjustments sunset for Medicare providers at the end of 2018.

2019

MIPS Payment Adjustment (+/-) 4% plus up to a 12% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.

2020

MIPS Payment Adjustment (+/-) 5% plus up to a 15% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.

2021

MIPS Payment Adjustment (+/-) 7% plus up to a 21% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.

2022

MIPS Payment Adjustment (+/-) 9% plus up to a 27% bonus for achieving 25th percentile or Qualifying APM 5% Participant Incentive Payment.

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