IN THIS ISSUE
- Upcoming Events
- SURS Practice Spotlight: Pulmonary & Internal Medicine Associates
- Review Your 2019 MIPS Measures
- Are You or Your Practice Newly-Eligible for MIPS in 2019?
- Value of Transitioning to an Alternative Payment Model
- March 2019 LAN Q&A
- Monthly Observance: Mental Health Month
INFORMATION REGARDING UPCOMING EVENTS, ALONG WITH REGISTRATION INFORMATION, CAN BE FOUND BELOW:
June 2019 LAN Webinar: How to Succeed in the Promoting Interoperability Category for Solo and Small Group Practices
Additional Upcoming Events and Links to Past Events
Upcoming and past CMS events related to MACRA, MIPS, and APMS will be listed here starting in the new year: https://qpp.cms.gov/.
Past QPP SURS events are listed here: https://qppsurs.com/webinar-resources/
SURS Practice Spotlight: Pulmonary & Internal Medicine
Leah Brady is a practice manager at Pulmonary & Internal Medicine Associates, a small practice in Trumbull, Connecticut. The clinicians in Leah’s practice reported as a group and received a perfect score of 100 in 2017!
What is the secret to this practice’s success in MIPS? Leah explained that her practice’s electronic health record (EHR) was crucial to helping her track, document, and submit MIPS measures. If your practice has an EHR, or are planning to invest in an EHR, you may be able to replicate Leah’s MIPS success using the following tips:
Streamline your documentation practices
To excel in MIPS, Leah created a new template in her EHR to centralize MIPS documentation for her clinicians. It’s a single page with tabs, which enables providers to locate information quickly and not have to open different pages in the EHR. Prior to this template, clinicians were entering free-text throughout the patient’s health record, making it hard to quickly ascertain a patient’s status. Leah admitted it was challenging to create this template and it required close collaboration with her EHR vendor on a number of occasions, but after a few weeks, the template was fully mapped and greatly facilitated MIPS reporting for her providers.
Frequently generate MIPS measure reports using your EHR
Leah ran reports in her EHR frequently to see how providers were progressing on their MIPS measures. She noted, “Getting everyone to do it was hard; I ran reports constantly to see that everyone was doing what they should be. I had to pull doctors aside to say: ‘I know you’re documenting it, but here’s how you need to do it to have it count for MIPS.’” Leah noted that this extra monitoring paid off in the end to ensure her clinicians were getting full credit for their measures.
Do what you can to address the cost of care
To reduce the cost of care for her practice’s Medicare patients, Leah worked with her clinicians to refer to non-hospital facilities, such as stand-alone advanced radiology facilities, whenever possible and clinically appropriate. While the cost performance category is challenging for her practice because some of their pulmonary patients tend to require more comprehensive services and supports and even direct referrals to the hospital, her practice makes an effort to reduce Medicare costs by limiting referrals to hospitals, when possible.
Sometimes success in MIPS comes down to patience, persistence, and a focus on what you can control. Keep Leah’s tips in mind as you continue reporting for the 2019 performance year. Interested in learning more tips directly from clinicians and practice managers? The CMS QPP SURS Central Support Team held a webinar in April entitled: “Lessons Learned: How to Succeed in MIPS for Solo and Small Group Practices.” For access to the webinar recording, slides, Q&A, and transcript, see the QPP SURS website here: https://qppsurs.com/webinar-resources/.
Review Your 2019 MIPS Measures
CMS has updated the “Explore Measures” tool on the QPP website with the 2019 MIPS measures and activities for the four performance categories. Click here to ensure that your selected MIPS measures are active for 2019, and check out the following resources on the QPP Resource Library:
- 2019 Clinical Quality Measure Specifications and Supporting Documents
- 2019 Quality Measure Benchmarks
- 2019 Improvement Activities
- 2019 Promoting Interoperability Measure Specifications
- 2019 Cost Measure Information
- 2019 Cost Measure Code Lists
Are You or Your Practice Newly-Eligible for MIPS in 2019?
Unsure if you or your practice are eligible for MIPS in 2019? To find out, enter your National Provider Identifier (NPI) into the CMS QPP Participation Status Tool. This valuable tool will display your eligibility status for the 2019 QPP Performance Year and will let you know whether you are required to participate in MIPS at each of your associated practices.
If you are required to participate, it can be overwhelming to know where to begin. The best place to start is with the CMS Quality Payment Program (QPP) website. Check out the Resource Library for guides, tip sheets, and other resources on how to prepare your practice for MIPS. Some helpful resources include:
- 2019 MIPS Quick Start Guide
- 2019 MIPS Participation and Eligibility Fact Sheet
- Promoting Interoperability Hardship Exception
- How to Create a QPP Account (video)
You can also receive free, tailored, one-on-one support from the Technical Assistance Contractor in your region. To locate your local Technical Assistance Contractor, see the following webpage: https://qpp.cms.gov/about/small-underserved-rural-practices. In addition to providing one-on-one support, the Technical Assistance Contractors create and share MIPS resources and tip sheets, including the following resources for newly eligible clinicians:
- Speech Language Pathologists
- Occupational and Physical Therapists
- Dietitians and Nutrition Professionals
- Clinical Psychologists
- Quality Insights’ 2019 MIPS Specialty Guides:
- TMF’s Q&A on MIPS for Newly-Eligible Clinician Types
Another resource is your specialty society or professional association. Many specialty societies operate their own Qualified Registries or Qualified Clinical Data Registries, which many members can use for free or reduced cost to track relevant MIPS measures and submit their data to CMS. Specialty societies also disseminate MIPS guidance and resources throughout the year to support their members. MIPS-specific resources for the six new clinician types are listed below. These resources can help you to successfully participate in MIPS in 2019.
- American Physical Therapy Association (APTA) Guidance for Physical Therapists
- American Occupational Therapy Association (AOTA) Occupational Therapist Measures for 2019 MIPS (member log-in required).
- American Psychological Association (APA) Guidance for Eligible Psychologists
- American Speech-Language-Hearing Association (ASHA) 2019 MIPS Fact Sheet for Speech Pathologists and Audiology
- Academy of Doctors of Audiology’s (ADA) 2019 Guidance for Audiologists
- Academy of Nutrition and Dietetics guidance on MIPS
Value of Transitioning to an Alternative Payment Model
Can participating in an Alternative Payment Model (APM) help you achieve a high MIPS score? According to the 2017 MIPS performance results, providers who participated in MIPS through an APM received a mean score of 87 points, more than 20 points higher than providers who participated in MIPS as individuals or groups. While joining an APM might not be appropriate for every practice, it may be worthwhile to consider the advantages of joining an APM.
What is an APM?
An Alternative Payment Model is a value-based approach to paying for care for Medicare beneficiaries that incentivizes quality and value. Providers who participate in the same APM work together to coordinate care for a group of patients and receive payments based on the quality and cost of care delivered. Medicare rewards APM providers financially if quality care is provided at lower cost.
MIPS-eligible providers can participate in an Advanced APM or a MIPS APM. If you participate in an Advanced APM and achieve threshold levels of payments or patients seen through that Advanced APM, you will be considered a Qualifying APM Participant (QP). QPs are excluded from MIPS reporting requirements altogether and have the opportunity to earn a 5% bonus for meeting those thresholds. If you do not meet the required thresholds to be considered a QP, you may still be considered a partial Qualifying APM Participant (Partial QP) if you receive at least 40 percent of your Medicare Part B payments or see at least 25 percent of Medicare patients through an Advanced APM entity during one of the determination periods. If you are a partial QP, you can decide whether or not to participate in MIPS.
If you participate in an Advanced APM and do not meet the thresholds to become a QP or partial QP, you may still benefit because most Advanced APMs are also MIPS APMs. Providers who participate in MIPS APMs are eligible for special scoring under the APM Scoring Standard. In addition, if you are struggling with MIPS, an APM may give you support with reporting and help you to achieve a higher score.
What are the potential advantages of joining an APM?
- Greater financial reward – Advanced APM entities can receive a 5% bonus. There are higher rewards for taking on additional risk and generating more savings!
- Reduced reporting burden – Providers in APMs do not have to report individual quality and improvement activity measures since the APM entity reports these measures on behalf of their providers. This frees up practices to focus on the goals of the APM.
- Increased support – APM entities, which help to manage the reporting for the providers in the APM, can provide several benefits to their practices, including access to advanced health IT, data analytics, and quality reporting.
Where do I start?
To determine if an APM is best for you, consider your volume of patients and how they are attributed, as well as the readiness of your practice for implementation. For free advice on whether you should join an APM, you can reach out to your local Technical Assistance Contractor to discuss the pros and cons for your practice. To see what APMs are in your area, check out the APM lookup tool here: https://qpp.cms.gov/participation-lookup.
The CMS QPP SURS Central Support Team held a webinar in September 2018, entitled: “Understanding Advanced Alternative Payment Models (APMs): Advice for Solo and Small Group Practices.” For access to the webinar recording, slides, Q&A, and transcript, see the QPP SURS website here: https://qppsurs.com/webinar-resources/. Another great resource is the Health Care Payment Learning & Action Network, which is dedicated to increasing APM adoption and providing resources to help practices move towards APMs. For more information, click here: https://hcp-lan.org/.
March 2019 LAN Q&A
The following questions were asked by the audience during the March 2019 LAN webinar titled “MIPS Question and Answer Town Hall Event for Solo and Small Group Practices.” For access to the full Q&A document and previous LAN webinar presentations, see the QPP SURS WordPress website: https://qppsurs.com/webinar-resources/.
Q: Our EMR vendor doesn’t seem to know what category II scores are. If that’s the case, how do we capture them?
A: The category II codes are typically Quality Data Codes (QDCs) appended to applicable Part B claim line item submissions for applicable quality measures to indicate whether a numerator service was performed, not performed, or not applicable/excluded. To collect and submit quality data through Medicare Part B Claims, you will attach QDCs to your Medicare Part B claims throughout the 2019 performance year. Please note that the last day for submitting 2019 Medicare Part B claims with QDCs for the 2019 performance year is determined by your Medicare Administrative Contractor (MAC) but must be processed no later than 60 days after the close of the performance year. Please see the 2019 Claims Data Submission Fact Sheet for more information.
Q: Are any Quality Measures topped out for 2019? I know they might not be eligible for total points, but how do I find out which, if any, are finished?
A: The Quality Measure Benchmarks include information on whether the benchmark is topped out, meaning the measure is not showing much variability and may have different scoring in future years. There are several Quality Measures that are topped out for 2019. You can find the topped out measures in the 2019 MIPS Quality Historic Benchmarks file.
Q: Our problem is with interoperability. Our EHR can send information to other providers, but none of the doctors we refer to are able to accept the information our system sends. How is this going to affect our score? We do send information to our state’s Medicaid registry.
A: This is an issue that many providers struggle with in their regions. One Technical Assistance Contractor offered the advice that you could call your most frequently referred to practices or facilities and see if they would work with you on the bilateral exchange of information because they may have the same measures that you are trying to meet. You could also become part of your state’s Health Information Exchange (HIE) to potentially improve the transfer of information between your practice and other providers. Keep in mind that the HIE measure’s exclusion can be claimed by any MIPS eligible clinician who transfers patients to another setting or refers patients fewer than 100 times during the performance year. For other ideas on how to address this issue in your region, you can reach out to your Technical Assistance Contractor for additional free support. You can locate your local Technical Assistance Contractor at https://qpp.cms.gov/about/small-underserved-rural-practices.
Q: When will our 2018 Cost Scores be available to review?
A: Feedback on 2018 MIPS performance year cost measure performance will be available in the summer of 2019 through the QPP Portal.
Monthly Observance — Mental Health Month
May is National Mental Health Month, and an opportunity to ensure your practice is addressing the mental health needs, as well as the physical needs, of your patients. According to the National Institute of Mental Health, one in five adults in the U.S. live with a mental illness. There are dozens of MIPS measures that practices can report to help monitor and support the mental health of their patients. Whether you are reporting on depression screenings, dementia assessments and counseling, or adherence to medications, tracking MIPS mental and behavioral health measures can help improve diagnoses and access to treatments for your patients.
Relevant MIPS measures include, but are not limited to:
- Adherence to Antipsychotic Medications For Individuals with Schizophrenia (Quality ID: 383)
- Dementia: Cognitive Assessment (Quality ID: 281)
- Depression Utilization of the PHQ-9 Tool (Quality ID: 371)
- Preventive Care and Screening: Screening for Depression and Follow-Up Plan (Quality ID: 134)
- Follow-Up After Hospitalization for Mental Illness (FUH) (Quality ID: 391)
For more information on Mental Health Month, click here. Additionally, Mental Health America created a toolkit with outreach ideas, fact sheets, and additional tools and resources to help address patient’s mental health.