QPP SURS Newsletter August 2019

QPP SURS Quality Payment Program


Upcoming Events

Doctor Talking to Patient


August 2019 LAN Webinar: Maximizing Your Quality Score: Beyond the Basics for Solo and Small Group Practices

September 2019 LAN Webinar: Considerations for Joining an Alternative Payment Model for Solo and Small Group Practices

Additional Upcoming Events and Links to Past Events

Small Practice Spotlight: Westside Internal Medicine, LLC

Kavita Patel is the practice administrator for Westside Internal Medicine, a small primary care practice in Spartanburg, South Carolina. In 2017, this practice received a MIPS score of 92; she credits their success to exception performance in the quality performance category with the help of a huddle worksheet. This worksheet helps ensure that the clinician is providing all the necessary exams to keep patients healthy, while simultaneously fulfilling MIPS quality measure requirements.

What is a huddle worksheet?

The huddle worksheet is a one-page document that nurses prepare ahead of patient appointments to help the clinician remember to conduct necessary screenings. These exams and screenings align with the practice’s selected MIPS quality measures related to vaccinations and screenings for diabetes, breast cancer, colon cancer, depression, and alcohol/substance use.

How is the huddle worksheet used?

Nurses prepare the huddle sheet a day before each patient visit by reviewing the patient’s electronic medical record and identifying services for which the patient is due. The clinician then reviews the huddle sheet and orders tests and services for the nurses to perform. With orders already in place, nurses can provide needed services as soon as the patient arrives.

Kavita’s practice began using this huddle worksheet 6 years ago. Since that time, the practice has continued to update and enhance the tool. At first, the practice found the worksheet to be time consuming, and filling out the document slowed everyone down. Now, the practice believes the document is key to their MIPS success because it ensures that patients receive necessary services and supports documentation of care.

Kavita’s advice to others who want to develop their own huddle sheet is to take it slow. It can take several months to fine-tune the worksheet and to address communication challenges such as transitions from administrative staff to clinical staff. Kavita advises keeping the huddle sheet to a single page. Take a look at Kavita’s huddle worksheet below and think about how your practice could adapt this tool to improve your clinical workflow, as well as your practice’s MIPS documentation and data collection.

Image of a huddle worksheet

June 2019 LAN Notable Q&As

The following questions were asked by the audience during the June 2019 LAN webinar titled “How to Succeed in the Promoting Interoperability (PI) Category 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. We are surrounded by providers who do not use the same Electronic Medical Record (EMR) as our small office. Continuity of Care Document (CCD) exchange is difficult.  What is an option for small providers to communicate with larger health systems?

A. One alternative is to leverage your local health information exchange (HIE). HIEs are available in many states and allow for the secure transmission of health care data across health systems and different EMR vendors. Your office may be able to conduct CCD exchange through the HIE, even with clinicians who use different EMR systems. Alternatively, you may be eligible for an exclusion from this requirement if you transfer a patient to another setting or refer a patient fewer than 100 times during the performance period. For more information on these measure exclusions, please see the Support Electronic Referral Loops by Receiving and Incorporating Health Information” and “Support Electronic Referral Loops By Sending Health Information” measure specification files in the 2019 PI Measures Specifications. If you have questions about identifying a local HIE, or understanding the exclusion requirements, please contact your local Technical Assistance Contractor. You can locate your region’s Technical Assistance Contractor at https://qpp.cms.gov/about/small-underserved-rural-practices.

Q. How can I report PI measures if I don’t have an EMR system in place?
A. You can still participate in MIPS, but you will not be able to report data in the PI performance category. CMS offers a Hardship Exception application for small practices who are unable to report on the PI performance category. If approved, the Hardship Exception would reweight the PI performance category to 0% of your final score and the 25% weighting of the PI performance category will be reallocated to the Quality performance category. Although small practices (fewer than 15 clinicians) are eligible to apply for the exception, they are not automatically exempt from the PI performance category and must still submit an application for CMS approval. Additional information regarding the Hardship Exception is available here.

Q. Are the PI measures the same as the Advancing Care Information Measures?

A. Beginning with the 2018 Performance Year, CMS renamed the Advancing Care Information (ACI) performance category to Promoting Interoperability (PI). The PI performance category contains some of the same measures with ACI, but you should review the annual updates to ensure you are using the most current information. You can find more information on PI measures in the CMS resource library. The 2019 PI measure specifications are here.

CMS Releases 2020 Proposed Rule for the Quality Payment Program

On July 29th, 2019, CMS released the proposed policies for the 2020 performance year of the Quality Payment Program via the Medicare Physician Fee Schedule (PFS) Notice of Proposed Rulemaking (NPRM). Some proposed key changes 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
  • Updating requirements for Qualified Clinical Data Registry (QCDR) measures and the services that third-party intermediaries must provide (beginning with the 2021 performance period)
  • Revising the specifications for the Total Per Capita Cost (TPCC) and Medicare Spending Per Beneficiary Clinician (MSPB Clinician) measures

For an overview of the QPP proposed policies for 2020 (year 4) and comparison of these policies to the current 2019 (year 3) requirements, please review the 2020 Proposed Rule Overview Factsheet. You can also read the entire Proposed Rule here.

CMS welcomes your feedback on the 2020 performance period of the Quality Payment Program, comments are due by September 27, 2019.

For information on how to submit your comments, please review the notice in the Federal Register.

2019 Promoting Interoperability (PI) Requirements: What Changed in Year 3?

CMS updated the PI performance category for the 2019 performance year to include several new requirements, as well as modifications to certain other requirements. Here are the top reminders and changes to be aware of in the 2019 performance year:

You must use EHR technology certified to the 2015 Certified Electronic Health Record Technology (CEHRT) Edition.

The 2015 CEHRT Edition functionality must be in place by the first day of the PI performance period, and certified by the last day of the performance period. The performance period for PI is a minimum of a continuous 90-day period. The timing of this 90-day period is up to you. For example, if your 90-day PI performance period begins October 1, 2019, then your 2015 Edition CEHRT functionality must be in place by October 1, 2019 and the product certified to the 2015 Edition criteria by the last day of the performance period, December 31, 2019. If you are not sure which edition your EHR is certified to, then we recommend that you search for your EHR product(s) using the Certified Health IT Product List (CHPL) website (please note that this website is not supported by Internet Explorer).  

New Measures and Bonus Points!

In 2019, CMS has moved away from classifying PI measures as base, performance or bonus score measures. Additionally, the following four measures are no longer eligible to report: 1) Patient-Specific Education, 2) View, Download, or Transmit (VTD), 3) Secure Messaging, and 4) Patient-Generated Data (PGH). In 2019, there is only one set of PI objectives and measures, based on the 2015 Edition CEHRT. The new measure set includes eleven measures spread across four objectives: 1) e-Prescribing, 2) Health Information Exchange, 3) Provider to Patient Exchange, and 4) Public Health and Clinical Data Exchange. Clinicians must report measures from each of the four objectives, unless they qualify for an exclusion.

Clinicians, groups, and virtual groups can earn five bonus points each for the submission of these two new optional measures:

  • Query of Prescription Drug Monitoring Program (PDMP)
  • Verify Opioid Treatment Agreement

To get full credit in the PI category, SURS practices must do the following:

  • Collect your data in EHR technology with 2015 Edition functionality (certified by the last day of the performance period) for a minimum of any continuous 90-day period in 2019, up to the full calendar year;
  • Submit a “yes” to the Prevention of Information Blocking Attestations;
  • Submit a “yes” to the ONC Direct Review Attestation;
  • Submit a “yes” that you have completed the Security Risk Analysis measure in 2019; and
  • Report the required measures from each of the four objectives or claim their exclusion(s).

You can still submit an application for the PI hardship exception.

  • The PI hardship exception will continue to be available for small practices. This means that if your practice has 15 or fewer eligible clinicians, you can request that the PI category be reweighted to zero and reallocated to the Quality performance category. The PI hardship exception is also available to practices of all sizes who have decertified EHR technology, insufficient internet connectivity, lack of control over the availability of CEHRT, and practices that face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues. The Promoting Interoperability Hardship Exception Application for Performance Year 2019 will open early summer 2019 and close December 31, 2019. For more information on Hardship Exceptions, click here.

You can find more details outlining each element of the PI measures in the Promoting Interoperability Measure Specifications and information on the ways to submit data to CMS on the 2019 Promoting Interoperability Measures Requirements website. In addition, CMS has published a fact sheet on the Promoting Interoperability Performance Category.

2019 MIPS Quality Measure Spotlight: Colorectal Cancer Screening (Quality ID: 113)

Clinicians providing colorectal cancer screenings can choose to report the Colorectal Cancer Screeningquality measure (Quality ID: 113) to MIPS. Practices who choose to report this MIPS measure may find compliance to be a challenge due to patient anxiety about colonoscopies. While a colonoscopy is still considered the gold standard for diagnosing colon cancer, there may be an alternative screening method to meet and achieve high performance on this MIPS measure.

Practices can prescribe fecal immunochemical DNA test in-home kits, such as Cologuard®, to their low and average risk patients as an effective way to screen those who may not be willing to undergo a colonoscopy. These kits allow patients to screen themselves in the privacy of their own homes instead of scheduling a colonoscopy in the office. Moreover, the test is non-invasive and does not require the patient preparation that colonoscopies necessitate, making this alternative more appealing to many patients.

If you are searching for quality measures to improve at your practice, you may consider prescribing your low-risk and average risk patients in-home testing kits. These kits can be shipped directly to the patient’s home, and can be used to help meet the requirements of the Colorectal Cancer Screening quality measure. Screenings such as these can help detect cancer for early treatment and ultimately improve the health of your patients over the long term.

2019 CMS Resources for Specialists and Facility-Based Clinicians

CMS frequently adds new information and resources to the QPP Resource Library on the QPP website (qpp.cms.gov). If you have not visited the Resource Library recently, you may have missed some helpful information for your practice! For example, if you are a newly eligible clinician type in 2019, CMS has published Specialty Guides describing the relevant MIPS measures and activities for:

In addition to the Specialty Guides, CMS has also published:

  • 2019 QP Methodology Fact Sheet – This fact sheet provides an overview of the 2019 Qualifying APM Participants (QPs) and Partial QPs determinations, including how CMS will identify eligible clinicians participating in Advanced APMs and how the QP payment and patient count threshold scores are calculated.

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