CMS released the final rule on the Quality Payment Program (QPP), which combines the Merit-based Payment Program (MIPS) and Advanced Alternative Payment Models (APMs) in October 2016. This final rule establishes regulations on the way Medicare incorporates quality measurement into payments and develops incentives for participation in alternative payment models. The QPP is designed to reform Medicare Part B payments for more than 600,000 clinicians and improve healthcare by setting standards to improve patient care nationwide in all healthcare fields. Providers may choose to take the MIPS track or the Advanced APM track.
CMS encourages participation in Advanced APMs by promising providers a 5% bonus for each year of participation, from 2019-2024, if the participants meet revenue and patient thresholds set by CMS. Advanced APMs are defined as models that include a quality measure component, has majority of participants using certified EHRs and involves risk of financial loss. Advanced APM entities must meet either predefined patient or payment percentages. These percentages rise annually finally topping out in 2024 at 75% for payment percentages and 50% for percentage of patients.
The MIPS scoring can be achieved by reporting individually or as a group under the same TIN. Through MIPS, providers may earn a performance-based payment adjustment. CMS will award the same final MIPS score to all the participants in a MIPS APM entity. Participants in the APM entities are assessed for meeting certain quality and cost metrics. The scoring for the Advancing Care Information and Improvement Activities will be scored collectively as well.
Improvement Activities are a new performance category for 2017 where clinicians are rewarded for providing care focused on care coordination, beneficiary engagement and patient safety. Most participants are required to attest that they have completed 4 improvement activities for a minimum of 90 days. A listing of Improvement Activities can be found at https://qpp.cms.gov/measures/ia.
The MIPS performance categories consist of quality, cost, improvement activities and advancing care information. Each category is assigned a weight. The quality category weighs in at 60% of the final score and replaces PQRS and the quality portion of the value modifier. Providers must choose 6 of approximately 300 quality measures and report on these for a minimum of 90 days to be eligible for the maximum payment adjustment. One of these measures must be an outcome measure or a high-priority measure which could consist of patient experience, patient safety, efficiency or care coordination. Many of these measures are specialty-specific making it easier for providers to choose and meet measure requirements.
The cost category has no reporting requirement during this transition year therefore offers a weight of 0%. CMS intends to provide feedback on your performance on this category for 2017 but this will not affect your 2019 payments. This data will be pulled from Medicare claims data.
Providers must attest to participating in performance activities that improve clinical practice. Providers may choose from over 90 activities under 9 subcategories. Only 4 activities need to be attested to. This is a new category which carries a weight of 15% of the possible 100 points. This category may prove to be the most cumbersome of all requirements. In addition to being a new requirement, CMS has not released a clear definition of how these activities must be reported.
Hospital-based MIPS eligible providers may choose to report under the advancing care information performance category. Other providers who are MIPS eligible and using a certified EHR may apply to have their performance category weighed to zero if the objectives and measures are found not to be applicable to those providers. CMS will then reassign the 25% weight of this category to the other performance categories.
The consensus in the healthcare community, in regards to MACRA, seems to be that of bewilderment in a sense. Providers are being forced to purchase EHR systems which require constant updates to remain in compliance with the ever-changing rules and regulations imposed on us by CMS. Many of which are mediocre at best. In addition, we hire IT companies to make sure we are HIPAA compliant, more staff is needed to monitor the EHR system, generate reports, input data and keep track of the latest CMS updates. This has created an enormous expense for providers and still we barely scrape through it at the end of each year only to start the next year with new laws and regulations. It is nearly impossible to keep this all straight.
But is it all bad?
I admit that we are being held to a higher standard as providers. We are now accountable and more transparent than ever. Has the implementation of MACRA forced us to refocus on the quality of care we give to our patients or are we now more preoccupied than ever? Is this forcing us to rethink the care we give our patients? The way we communicate to our patients and other physicians to improve continuity of care? Are we improving our processes to provide a better patient experience? How do you feel this has impacted the care we provide to our patients? Can technology help?
Technology is coming a long way to improve patient safety and communication at the bedside. One of those solutions is MEDI+SIGN. MEDI+SIGN is designed as a replacement for the standard dry-erase whiteboard in the patient room but it is much more. It automatically communicates the patient’s information in a clear and concise way to the patient, the patient’s family and to the staff, becoming a central hub in the continuum of care. With value-based care being such a large part of MACRA and MIPS, tools like MEDI+SIGN are invaluable to make these programs a success in your organization.
To learn more about how our Medi+Sign digital whiteboard system can help your organization, please visit us at www.medisigndisplays.com.
CMS Center for Medicare and Medicaid Services
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