patient reported outcomes

In our previous post, we introduced the framework for the new Quality Payment Program (QPP) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Here we look deeper at the Merit-based Incentive Payment System (MIPS) pathway, which the Centers for Medicare & Medicaid Services (CMS) estimates will achieve an 80 to 90 percent participation rate in the 2017 transition year.

Participation in MIPS can start on January 1, 2017 or by October 2, 2017 and the first payment adjustments are effective January 1, 2019.  Eligible clinicians (ECs) will have three options in 2017 for MIPS based on submission of data for three performance categories – quality, improvement activities, and advancing care information (ACI). The cost category is based on administrative claims data, it does not require submission, and it is not weighted for the first year.

Transition year options

Clinicians seeking to participate in the first year of the Quality Payment Program have a few options to choose from, which Andy Slavitt, CMS acting administrator, outlined in this recently published blog.

  • Submit Something: Submit a minimum amount of 2017 data for at least one quality measure, one improvement activity, or all required ACI measures to avoid a negative payment adjustment. This first option gives participating physicians and hospitals an opportunity to ensure their submission systems are working to help them gain confidence that they will be ready for broader participation in 2018 and 2019.
  • Submit Some Measures: The second option allows participants to submit ≥ 90 days of data for more than one quality measure, more than one improvement activity, or more than the required ACI measures and earn a neutral or small positive payment adjustment.  For example, a participant could submit information for part of the calendar year for quality measures, how their practice uses technology, and what improvement activities they are undertaking.
  • Submit All Measures: Practices that are ready to comply on January 1, 2017, can submit data on all required MIPS measures — including quality measures, ACI measures, and improvement activities — for the full calendar year, and qualify for a moderate positive adjustment as well as a possible additional positive adjustment. CMS is confident that many practices will be ready to comply with this option.

The size of payment adjustments for any of these options will depend on how much data is submitted and the quality results. It is also important to note that if no data is submitted in 2017, eligible clinicians will receive a negative four percent payment adjustment.

HIT, measures and activities supporting MIPS requirements

Health information technology (HIT) is a key component of MACRA as it enables participation in the QPP. Under MIPS, CMS encourages reporting from Certified EHR Technology (CEHRT) or Qualified Clinical Data Registries (QCDRs). Bonus points are also available for end-to-end reporting, which uses automated software to aggregate measure data, calculate measures, perform filtering of measurement data, and submitting data electronically.

Through MIPS, CMS will collect and evaluate data related to four performance categories: Quality, ACI, improvement activities, and cost. Each category has a variety of measures that will be considered and weighted according to their value. This combination of measures will determine the clinician’s final score.

  • Under Quality, there are 271 quality measures, and 53 are electronic clinical quality measures. Quality comprises 60 percent of the eligible clinician’s final score in payment year 2019, 50 percent in 2020, and 30 percent thereafter. 
  • Under ACI, there are 15 measures correlated to Meaningful Use Stage 3, and 11 correlated to Modified Stage 2 of the CMS EP incentive program.  Eligible clinicians are also required to demonstrate cooperation with provisions concerning blocking the sharing of information, and engagement with activities that support performance of CEHRT. ACI comprises 25 percent of the final score.
  • Under Improvement Activities, there are 93 activities with two high-weighted or four medium-weighted activities required for a full score. At least one improvement activity is sufficient in the transition year.  This category comprises 15 percent of the final score.
  • Under Cost, CMS will calculate measures of total per capita costs for all attributed beneficiaries, a Medicare Spending per Beneficiary measure, and 10 episode-based measures. Cost comprises zero percent of the final score in payment year 2019, 10 percent in 2020, and 30 percent thereafter.

With so many measures and variable weighting structures, getting ready for MIPS may feel overwhelming. Organizations that don’t feel prepared to take on MIPS, should seek out help from experts in the field to create an implementation plan, and look for opportunities to engage with CMS about the performance metrics and how to best position themselves for a pay-for-value driven future.