QPP SURS Newsletter November 2019

QPP SURS Quality Payment Program


Upcoming Events

Doctor Talking to Patient


December 2019 LAN Webinar: Implications of the Year 4 Final Rule for Solo and Small Group Practices

Additional Upcoming Events and Links to Past Events

Past QPP SURS events: https://qppsurs.com/webinar-resources/

Small Practice Spotlight: Sumter Internal Medicine Associates

Practice Manager Jacqui Hawkey

Sumter Internal Medicine Associates is a solo provider practice in Sumter, South Carolina that achieved a perfect MIPS score of 100 in both the 2017 and 2018 performance years. The practice manager, Jacqui Hawkey, shared how the practice’s Electronic Health Record (EHR) was instrumental to their success in MIPS and offered the following tips for how to improve your score.

Consider purchasing a MIPS Dashboard from your EHR vendor (if available): Jacqui purchased the MIPS package from their EHR vendor (Allscripts). While the MIPS dashboard was an additional $1250.00 and the CEHRT implementation was $2000.00 with monthly fees of $50, Jacqui believes it was worth the investment since it allowed her to easily track the practice’s progress on MIPS measures and identify areas that needed improvement.

I’ve been running my reports all year to find out where I’m not doing so well. There are certain things outside of our control, but for the things we can control, we can figure out what can be improved or done to get credit. A lot of the time the providers are already doing those activities, but just need to figure out what to do in the EHR to get credit.” – Jacqui

Customize your EHR to remind clinicians to document care: Jacqui customized her EHR so that pop-up boxes appear for the clinician to complete when documenting care. These shortcuts remind the clinician where to document care in the EHR to ensure he receives full credit for the health education he is providing on weight and diet for his diabetic patients.

Find a network or community forum: Jacqui participates in a community forum organized by Allscripts to share MIPS challenges and solutions with other practices. She learned that many practices like hers were struggling to figure out how to get credit for the health education they were providing to patients. After hearing suggestions from other offices, she was able to create a flag in the EHR to remind her clinician where to document health education services.

Keep these tips in mind as you prepare for the last quarter of 2019!

How to Address and Report on Opioid Use Disorder

In 2018 and 2019, CMS added new opioid-related MIPS measures across the Quality, Promoting Interoperability and Improvement Activities performance categories to enable clinicians to receive credit for providing clinically appropriate treatment for patients with an opioid use disorder. Below are the 2019 opioid-related MIPS measures that clinicians can elect to report. If you prescribe opioids at your practice, consider reporting on one or more of the following measures to receive credit for promoting safe and effective pain management for your patients.

2019 Quality Measures:

  • Opioid Therapy Follow-up Evaluation (Quality ID: 408)
  • Documentation of Signed Opioid Treatment Agreement (Quality ID: 412)
  • Evaluation or Interview for Risk of Opioid Misuse (Quality ID: 414)
  • Continuity of Pharmacotherapy for Opioid Use Disorder (OUD) (Quality ID: 468)

2019 Promoting Interoperability[1] :

  • Query of the Prescription Drug Monitoring Program (PDMP) (PI_EP_2)
  • Verify Opioid Treatment Agreement (PI_EP_3)

2019 Improvement Activities:

  • CDC Training on CDC’s Guideline for Prescribing Opioids for Chronic Pain (IA_PSPA_22)
  • Completion of training and receipt of approved waiver for provision opioid medication-assisted treatments (IA_PSPA_10)
  • Consultation of the Prescription Drug Monitoring Program (IA_PSPA_6)
  • Patient Medication Risk Education (IA_PSPA_31)
  • Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support (IA_PSPA_32)

For details on these opioid-related MIPS measures, consult the following 2019 MIPS measure specification packages:

Questions and Answers from the September 2019 QPP SURS LAN Webinar

The following questions were among those asked by the attendees of the September 2019 LAN webinar, entitled “Considerations for Joining an Alternative Payment Model (APM) for Solo or Small Group Practices.” The answers have been edited here for length and context. For access to the full Q&A document and previous LAN webinar presentations, see the QPP SURS website.

What is an APM?

An Alternative Payment Model (APM) is a payment approach that gives added incentive payments to provide high-quality and cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population.

Under the Quality Payment Program, there are two main types of APMs: MIPS APMs and Advanced APMs. MIPS APMs must include at least one MIPS eligible clinician on its participation list and base payment incentives on cost and quality performance. Advanced APMs are a track of the Quality Payment Program that offer a 5 percent incentive payment for meeting specific payment or patient thresholds through an Advanced APM. If you meet one or both of these thresholds, you will designated as a Qualifying APM Participant (QP) and are exempt from the MIPS reporting requirements and payment adjustment. Advanced APMs let practices earn more rewards in exchange for taking on higher financial risk. Most Advanced APMs are also MIPS APMs. In the event that a MIPS eligible clinician does not achieve QP status, they will be scored under the APM Scoring Standard, if the Advanced APM is also a MIPS APM.

The most well-known APM entity is an Accountable Care Organization (ACO). An ACO is an entity comprised of doctors, hospitals, and other health care providers who come together voluntarily to give coordinated high-quality care to their patients. For more information on APMs, please visit https://qpp.cms.gov/apms/overview.

What is the benefit of participating in a MIPS APM as opposed to reporting in the MIPS track only?

Although participating in a MIPS APM does not exclude an eligible clinician from MIPS, clinicians will be scored using the APM scoring standard. The MIPS APM scoring standard accounts for activities already required by the APM, including Quality measure reporting and Improvement Activities, to reduce duplication of reporting and allow clinicians to focus on the goals of the APM. Therefore, the MIPS performance category weighting and reporting requirements are different than the general MIPS scoring standard.

APMs provide several benefits including: care coordination, shared incentives and savings, population management capabilities, opportunities and support such as health IT, data analytics and quality reporting, greater rewards for taking on some financial risk, and an ability to focus more on outcomes. In 2019, if you participate in a combination of Advanced APMs with Medicare and Other-Payer Advanced APMs, you are eligible to become a Qualifying APM Participant (QP), and will be exempt from MIPS entirely. For more information, see the 2019 QPP Multi-Payer Other Payer Advanced APMs.

We really need to understand how a provider becomes a Qualifying APM Participant (QP). What happens if we join an Advanced APM but do not get the QP status?

In order for a clinician to become a Qualifying APM Participant (QP), they must participate in an Advanced APM. Advanced APMs must meet the following criteria:

  • At least 75% of the clinicians in each APM entity use Certified EHR Technology (CEHRT) to document and communicate clinical care information with patients and other health care professionals
  • The APM provides payment for covered professional services based on quality measures comparable to those used in the MIPS quality performance category; and
  • The APM must either be a Medical Home Model expanded under CMS Innovation Center authority OR must require participants to bear a more than nominal amount of financial risk.

To learn more about specific Advanced APMs and how to join one that fits your practice and is currently accepting applications, please visit https://innovation.cms.gov/initiatives/#views=models&stg=accepting%20letters%20of%20intent,accepting%20applications,ongoing.

Participating in an Advanced APM does not guarantee that a clinician will achieve QP status. In order to achieve QP status for Performance Year 2019, clinicians must receive at least 50 percent of their Medicare Part B payments or see at least 35 percent of their Medicare patients through an Advanced APM at one of the determination periods (“snapshots”).

To determine QP status, CMS will take three “snapshots” of all participants on each Advanced APM entity’s Participation List or Affiliated Practitioner List on March 31, June 30, and August 31 to determine which eligible clinicians are participating in an Advanced APM and whether they meet the threshold to become QPs. CMS will make determinations at both the individual and APM entity levels. If the Threshold Score calculated during a QP determination period for the APM Entity meets or exceeds the QP payment amount or patient count threshold, CMS will consider all eligible clinicians in the APM Entity to be QPs or Partial QPs (as described below) for that performance year.

An eligible clinician can still participate in an Advanced APM if he or she does not achieve QP status. Clinicians who participate in Advanced APMs, but do not meet the QP threshold, may become “Partial” Qualifying APM Participants. If approved, Partial QPs can choose whether to participate in MIPS. If you do not qualify as a QP or partial QP, you are required to report MIPS data. If the Advanced APM is also a MIPS APM, then eligible clinicians will be scored using the MIPS APM scoring standard.

You can use the QPP NPI Lookup Tool to check your APM participation, including your QP status. Be careful to select the correct performance year, since your eligibility status can change year over year. The QP Methodology Fact Sheet can help you understand how CMS makes QP and partial QP status determinations. You can check the 2019 Determination Periods and Snapshots which includes information on APMS here.

UPDATE: On September 27, 2019, CMS posted a new fact sheet specific to APM Incentive Payments for 2017 Performance. The fact sheet can be found at the following location: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/0/2019%20APM%20Incentive%20Payment%20Fact%20Sheet.pdf

For more information about the 2019 Cost performance category, check out the 2019 Cost Performance Category Fact Sheet. For QPP-SURS specific guidance, see the recent webinar on “How to Maximize Your Score in the Cost Category: Practical Advice for Solo and Small Group Practices.” If you have more specific questions, reach out to your Technical Assistance Contractor. To find the right person to talk in your region, check https://qpp.cms.gov/about/small-underserved-rural-practices.

Utilizing a Health Information Exchange (HIE) for Promoting Interoperability Reporting

The Promoting Interoperability (PI) performance category is designed to encourage electronic access and exchange of health information between providers and patients. Interoperability is a key goal of MIPS and is designed to make communicating patient information less burdensome for providers while improving health outcomes.  This category can be challenging to small practices who do not have an Electronic Health Record (EHR) or do not have access to a state Health Information Exchange (HIE). The electronic exchange of health information continues to evolve, and for that reason, CMS gives small practices the option to apply for an exception to the PI performance category for the 2019 performance period and have these points transferred over to the Quality performance category.

However, if your practice has Certified EHR Technology (CEHRT), you are eligible to receive points in the PI category[2]. In 2019, MIPS-eligible clinicians must report on six required measures in this category. Two of the required measures which can be particularly difficult for small practices to report independently are:

1. Support Electronic Referral Loops by Sending Health Information (previously “Send a Summary of Care”).

2. Support Electronic Referral Loops by Receiving and Incorporating Health Information (This measure is a combination of two measures from 2018: “Request/Accept Summary of Care and Clinical Information Reconciliation”).

Keep in mind that you can claim an exclusion from the Sending Health Information measure if you transfer a patient to another setting or refer a patient fewer than 100 times during the performance period. Additionally, an exclusion is available for the Receiving and Incorporating Health Information measure if you receive fewer than 100 transitions of care or referrals or have fewer than 100 encounters with patients never before encountered during the performance period. An exclusion is also available to any MIPS eligible clinician who is unable to implement this measure in 2019, as CMS recognizes that not all EHR vendors will be able to fully develop this measure in time to be implemented for the 2019 PI performance period.

One way to align your resources with the HIE objective is by providing your direct address to local health systems and providers. A clinician’s direct address is a secure email address that connects one Electronic Health Record to another. For the HIE objective, a clinician could connect to other providers to which they refer patients or receive patient referrals from. To find your Direct Address, reach out to your EHR vendor or State Health Information Exchange entities, regional and local Health Information Exchange entities, or private service providers offering Direct exchange capabilities called Health Information Service Providers (HISPs).

Text Box: Health Information Exchange (HIE)
An HIE is a statewide repository that enables providers and patients to access and share patient health information. HIEs offer many advantages, including the ability for providers in multiple settings to have real-time access to a patient’s health record, which facilitates care coordination, reduces duplicative testing and medical errors, and reduces time spent on paperwork.

Another way to complete these measures is to connect with your state Health Information Exchange (HIE). For information on how to connect to your state’s HIE, see the following resources:

  • Your State Department of Health or Regional Extension Center may have resources or training guides on how to connect to your state’s HIE.
  • The National Rural Health Resource Center has published HIE resources to assist rural providers in understanding and engaging in an HIE. Visit the HIE Toolkit Webpage for more information.

If you would like further information about how to connect with your state HIE, please reach out to your region’s Technical Assistance Contractor for SURS practices. Information for your region’s support organization can be found at https://qpp.cms.gov/about/help-and-support.

How to Find Relevant MIPS Measures for your Specialty

The Quality performance category makes up 45% of your total MIPS score in 2019, and will make up 45% in 2020. To participate, you must choose and report on 6 quality measures (or a complete specialty measures set) from among the over 260 specified by CMS, including at least one outcome measure. If you are unsure which measures are applicable to your practice, consider the following tools and strategies to find the right measures for you.

  • Search the Explore Measures and Activities Tool: The CMS QPP website has an Explore Measures & Activities Tool that will allow you to search key words relating to your practice, as well as filter by measure type, specialty measure set, and collection type.
  • Check the Specialty Measures Sets: In 2019, there are 26 Specialty Measures Sets, each containing a number of measures that may be applicable to a specific specialty type, including some cross-cutting measures that specialists can choose to report. You can view all of the available Specialty Measures sets by using the Explore Measures & Activities Tool, and filtering by specialty measure set. If you choose a set with 6 or more possible measures, the measure requirements are the same as if you were not using a set. If your set has fewer than 6 measures, you must submit all measures in the set, but do not need to submit additional measures.
  • Review 2019 Quality measure specification documents: The 2019 MIPS Quality Measure Specification documents, in particular the Single Source documents, allow clinicians to filter MIPS quality measures by the CPT, HCPCS or ICD-10 codes they normally bill to see what relevant MIPS measures are relevant for their practice. For more information on how to use Single Source documents, refer to TMF’s Q&A on Single Source Documents available here. Additionally, check out the 2019 measure specifications and supporting documents listed below:
  • Review your specialty association’s website: Many national specialty societies have MIPS resource pages that can help identify relevant MIPS measures and activities for your specialty.
  • Consider reporting through a Qualified Clinical Data Registry (QCDR): A QCDR is a CMS-approved entity that collects clinical data on behalf of clinicians for MIPS data submission. Unlike Qualified Registries (QRs), QCDRs are not limited to standard measures within the Quality Payment Program, and can offer additional measures relevant to some specialties that count toward MIPS scores. For more information, please review the list of 2019 MIPS QCDRs.
  • Talk to your Technical Assistance Contractor (TAC). Technical Assistance Contractors are trained to help you meet MIPS requirements and are available to give individualized guidance on what measures are appropriate for your specialty free of cost. You can find the name and contact information for your TAC at https://qpp.cms.gov/about/small-underserved-rural-practices.

Monthly Observance: Diabetes Month

November is National Diabetes Awareness Month, and November 14th is World Diabetes Day. According to the CDC, over 30 million people living in the United States have diabetes, and over 84 million are living with prediabetes, making the disease one of the most pressing health concerns in the country.

The Centers for Medicare & Medicaid Services (CMS) has launched a number of initiatives aimed at diabetes management, treatment, and prevention, including implementing Everyone with Diabetes Counts (EDC), a diabetes self-management education program. In addition, MIPS offers quality measures related to diabetes prevention and care. Below are a number of diabetes quality measures that you can select to improve care and strengthen your MIPS score:

  • Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological Evaluation (Quality ID 117): Percentage of patients aged 18 years and older with a diagnosis of diabetes mellitus who had a neurological examination of their lower extremities within 12 months.
  • Diabetes: Eye Exam (Quality ID 262): Percentage of patients 18 – 75 years of age with diabetes who had a retinal or dilated eye exam by an eye care professional during the measurement period or a negative retinal or dilated eye exam (no evidence of retinopathy) in the 12 months prior to the measurement period.
  • Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%) (Quality ID 001): Percentage of patients 18-75 years of age with diabetes who had hemoglobin A1c > 9.0% during the measurement period.

1. PDMP and Verify Opioid Treatment Agreement are bonus measures. If available for your practice, this is a great way to earn extra points and increase your MIPS score.

2. To check if your EHR is certified, search for your EHR product(s) on the Certified Health IT Product List (CHPL) website https://chpl.healthit.gov/#/search.

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