SUBMITTING YOUR 2018 MIPS DATA: ADVICE FOR SOLO AND SMALL GROUP PRACTICES

Transcription

1 1 QUALITY PAYMENT PROGRAM SMALL UNDERSERVED RURAL SUPPORT (QPP SURS) WEBINAR OCTOBER 16, 3:30 PM ET AND OCTOBER 18, 11:00 AM ET SUBMITTING YOUR 2018 MIPS DATA: ADVICE FOR SOLO AND SMALL GROUP PRACTICES

2 2 HOUSEKEEPING ANNOUNCEMENTS If you are listening to this webinar through your phone, please remember to mute your computer speakers. For assistance, enter your issue in the chat box. To ask a question, enter your inquiry in the chat box.

3 3 POLLING QUESTION What is your role? A clinician working in a practice with 15 or fewer clinicians Non clinical staff from a practice with 15 or fewer clinicians A clinician working in a practice with more than 15 clinicians Non clinical staff in a practice with more than 15 clinicians Quality Payment Program (QPP) contractor Other person helping practices prepare for MIPS Other

4 4 POLLING QUESTION How are you planning to submit your 2018 MIPS data? I am submitting as an individual I am submitting as a group I am submitting as a virtual group

5 5 POLLING QUESTION What are your biggest expected challenges or concerns with using the QPP Portal to submit data?

6 6 CMS WELCOME Brenda Gentles, RN, BS, MS Division of ESRD, Population & Community Health Centers for Medicare & Medicaid Services QPP SURS Central Support Contractor COR

7 7 Michael Sacca, Managing Director, IMPAQ Health Division, QPP SURS Central Support Daniel Day, Hospital and Physician Office Quality Improvement Advisor for AQAF Bruce Spurlock, MD President & CEO, Cynosure Health

8 8 SETTING THE STAGE Focus: Understanding the methods by which you can submit your 2018 MIPS data Strategy: Discussion with panelists who are familiar with the range of data submission options available to small group practices and individual clinicians Topic Overview: Who is required to submit MIPS data? What you need to know before you get started Options for submitting in each of the four performance categories How best to prepare for the 2018 submission period Free resources! Using the Chat Box

9 9 POLLING QUESTION What are you most looking forward to learning about on today s webinar?

10 10 RESOURCES FOR FREE SUPPORT Technical Assistance Organizations General information about QPP for eligible clinicians participating in MIPS or Advanced APMs: Questions to CMS about Quality Payment Program: Sources of support for larger practices and APM participants described in: QPP_Technical_Assistanc e_resource_guide.pdf Free technical assistance and advice available for small practices from CMS-funded organizations. Contact information for each organization at:

11 11 QUESTION: Am I required to submit MIPS data and what do I need to know before I get started?

12 12 ELIGIBILITY REQUIREMENTS For 2018, you re required to participate in MIPS if you are an eligible clinician type, AND if you exceed the low-volume threshold. The low volume-threshold is applied at both the individual and at the group level. Review of exemption criteria

13 13 ELIGIBILITY REQUIREMENTS

14 14 WHERE CAN I CHECK MY ELIGIBILITY? Clinicians can use the CMS NPI lookup tool to check their eligibility: The tool contains eligibility information for ALL practices you are associated with The NPI lookup took can also be used to view special status information

15 15 MIPS REPORTING OPTIONS

16 16 MIPS YEAR 2 PERFORMANCE PERIOD AND TIMELINE Quality 12 months Cost 12 months IAs continuous 90 days PI continuous 90 days 2018 Data Submission Infographic

17 17 MONITORING YOUR DATA You can monitor your data all year long! Check and review your quality data codes for claims Verify and retain your Part B Remittance Advice/Explanation of Benefits transmittals. Use of MIPS calculator. Monitor vendors and regularly review reports.

18 18 QUESTION: How do I get started submitting my data through the QPP portal?

19 19 WHO NEEDS A CMS ENTERPRISE IDENTITY MANAGEMENT (EIDM) ACCOUNT Clinicians, groups, MIPS APMs, and certain Advanced APM participants that: Will be submitting data directly to qpp.cms.gov (QPP portal) Have secured an EHR/Health IT Vendor to submit their data to the QPP portal Want to view the data submitted on their behalf by a third party Qualified Clinical Data Registries, Qualified Registries, and EHR/Health IT Vendors that will be submitting data directly to the QPP portal on behalf of their clients CMS Enterprise Portal:

20 20 SETTING UP OR RENEWING YOUR ACCOUNT Your account will lock after 60 days of inactivity. Your password must be changed at least every 60 days and can only be changed once a day. Your account will deactivate if you have not logged in for more than 180 days. To reinstate your account, call the Quality Payment Program Service Center at TTY: or via at qpp@cms.hhs.gov Monday through Friday 8am-8pm ET. To set up a new account or for general information on EIDM access for QPP, please review: EIDM User Guide

21 21 QUESTION: What are my options for submitting my 2018 quality measures?

22 22 SUBMITTING YOUR QUALITY DATA Claims (individuals only) Qualified Clinical Data registry (QCDR) Qualified Registry (QR) Electronic Health Record (EHR)

23 23 SUBMITTING YOUR QUALITY DATA CLAIMS Clinicians pick from 73 available measures and report through their routine billing processes. Same claims forms you ve traditionally submitted to CMS for payment for the services you ve performed, but also add Quality Data Codes (QDCs) to denominator eligible claims as defined by the measure specification. For assistance in identifying denominator eligible cases based on the patients you see, and for more details on submitting QDCs, visit the 2018 Claims data submission fact sheet.

24 24 SUBMITTING YOUR QUALITY DATA QCDR AND QR QCDRs collect medical and/or clinical data to track patients and disease and submits to CMS on your behalf. Each QCDR usually gives customized instructions about how to submit data. You can find approved QCDRs in the 2018 QCDR qualified posting. A Qualified Registry collects clinical data and submits to CMS on your behalf. You can find approved Qualified Registries in the 2018 Qualified Registries qualified posting. Based on the terms of your agreements, both QCDRs and QRs will submit data on your behalf via the QPP portal. Quality data submitted by QRs and QCDRs is uploaded via QPP data format (JSON, XML) or Quality Reporting Document Architecture (QRDA III).

25 25 SUBMITTING YOUR QUALITY DATA EHR You can submit your quality data collected through your certified EHR technology (CEHRT) either the 2014 or the 2015 Edition CEHRT. You can submit yourself via the QPP portal or by working with a certified health IT vendor who will submit the data on your behalf. The data will be submitted via the QRDA III file format by you or your health IT vendor. Groups and Virtual Groups that collect data using multiple EHR systems will need to aggregate their data before it s submitted.

26 26 SUBMITTING YOUR QUALITY DATA PRACTICAL TIPS Review your data to make sure the percentages on the QPP portal dashboard are the same as in the file you are uploading. If you notice an error contact your vendor or Quality Payment Program Service Center at Some EHRs do not have the ability to report Quality data at the Group level. In this case you can either submit individually or hire a company to combine the individual QRDA III files. Engage your EHR vendor early and often!

27 27 QUESTION: What are my options for submitting my 2018 improvement activities?

28 28 IMPROVEMENT ACTIVITY REQUIREMENTS 15% of your final 2018 MIPS score. Choose from the 113 available Activities that best meet the need of your practice. Meet 90-day requirement (activities that you performed for at least 90 consecutive days). MIPS eligible clinicians in small practices can report on just 2 medium weighted or 1 high weighted IA activity to earn the maximum number of points. 1 high-weighted activity OR 2 medium-weighted activities Improvement Activities submitted by designated small practices receive double the points! 20 points for medium-weighted activities 40 points for high-weighted activities

29 29 IMPROVEMENT ACTIVITIES DATA SUBMISSION For 2018, you must chose one submission method. You can log onto the QPP portal and manually attest to the improvement activities that you completed. A third party vendor (QCDR, QR, or EHR) can submit your IA data on your behalf by uploading data via the QPP format (JSON, XML) or a QRDA III file. Keep documentation for 6 years.

30 30 IMPROVEMENT ACTIVITY PRACTICAL TIPS If your third-party vendor is able to create an IA QRDA III file and is submitting it on your behalf, there is no need for you to upload additional data for the activity/activities. When attesting in the portal, be sure to put in at least a 90-day continuous date range for the performance period as the QPP portal will give you an error message for any performance period inserted that is less than 90 days. Note: some activities performance period are longer than 90-days, so be sure to check the activity specifications.

31 31 QUESTION: What are my options for submitting data in the promoting interoperability performance category?

32 32 PI REQUIREMENTS Use certified EHR technology. Submit the performance period (a minimum of 90 consecutive days period in 2018). Submit a yes to the Prevention of Information Blocking Attestation. Submit a yes to the ONC Direct Review Attestation. Submit a yes for the security risk analysis measure, and at least a 1 in the numerator for the remaining base score measures or submit an exclusion for the base score measures.

33 33 PI DATA SUBMISSION You can log onto the QPP portal and manually attest to the PI measure that you completed or manually upload a file. A third party vendor (QCDR, QR, or EHR) can submit your PI measures on your behalf by uploading a file in the QPP Data Format (JSON, XML) or QRDA III format. You must use certified EHR technology to report or attest to PI. Review your EHRs dashboard to identify the PI data you are submitting for the last 90 days. Reweighting application is due December 31, To submit an application visit:

34 34 PI PRACTICAL TIPS No more PI measure performance thresholds! Submit PI measure data to build towards your score. The more measure data you submit, the more opportunity you have to increase your performance category score! Not seeing a score? Similar to IA, you first need to designate a performance period. Select one of the measure sets that are available (PI measures vs PI Transition measures). Your EHR plays a role in which measure set you choose. Submit the two required attestation statements. Finally, every single measure available within the Required Base Score selection must be attested with positive values (along with attesting that yes you completed the Security Risk Analysis measure) in order to begin populating a category score. OR if you meet the measure exclusion(s), choose the exclusion.

35 35 QUESTION: What about cost data submission?

36 36 COST Review your MIPS Cost performance category feedback in the QPP Portal. The Cost performance feedback shows how groups or solo practitioners performed on the two cost measures. Reference historical information from the Physician Value-Based Payment Modifier Program. Quality and Resource Use Reports (QRUR) showed how clinicians and groups performed on similar measures. You can access you QRUR here:

37 37 COST PERFORMANCE FEEDBACK You can access your performance feedback on cost measures via the QPP portal.

38 38 QUESTION: What should I be doing now to prepare for the data submission period?

39 39 PRACTICAL ADVICE Don t wait to get started. Make sure your EIDM account is set up and current. Understand your agreements with vendors. Work with your Technical Assistance Contractors sooner than later. Review and monitor all year long!

40 40 QUESTION: If I still need help, where can I go?

41 41 FREE RESOURCES FOR ASSISTANCE FROM CMS QPP website: information tailored for the needs of small practices MIPS-and-APMs/Quality-Payment-Program-Events.html Contact the Quality Payment Program at: or call Support and Available resources for Small, Underserved, and Rural Practices: Small Underserved Rural Support Technical Assistance Organizations (see list on slide 10) Contact information is available at: Available websites of each Technical Assistance Organization Types of help: needs assessments, webinars, technical support, links to peers you can talk with, assistance getting signed up to report through an approved channel that meets your practice s needs FREE Technical Assistance funded by CMS is also available for larger group practices and for clinicians interested in participating in an Alternative Payment Model. More information on those programs is available at:

42 42 FREE RESOURCES FOR ASSISTANCE FROM CMS CMS Data Submission instructional videos : Merit-based Incentive Payment System (MIPS) Data Submission Advancing Care Information (ACI) Data Submission for Alternative Payment Models (APMs) Data Submission via a Qualified Clinical Data Registry and Qualified Registry Data Submission fact sheet QPP Participation Status Lookup Tool 2017 Performance Review Fact Sheet 2017 Payment Adjustment Fact Sheet 2018 Quality Payment Program Participation Infographic 2018 Data Submission Infographic 2018 MIPS Scoring 101 Guide

43 43 WRAP-UP ACTIVITIES Links to Q&A documents, transcripts, and recordings of the event are available here: November: Overview of the 2019 Final Rule: Implications for Solo and Small Group Practices Please provide feedback on this event: Feedback Form

44 44 REFERENCES Slide decks created by event panelists also provided information reflected in this presentation. The input from project panelists is gratefully acknowledged. Other documents on the and website provide additional detail about the MIPS program. Disclaimer: This presentation was current at the time it was published or uploaded onto the web. Medicare policy changes periodically so links to the source documents have been provided within the document for your reference. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.

45 45 APPENDIX: FREQUENTLY ASKED QUESTIONS When is the 2018 performance period data submission period? The 2018 Performance Year data submission window is from January 2, 2019 April 2, You may submit and update your data any time while the submission window is open.

46 46 APPENDIX FREQUENTLY ASKED QUESTIONS: Where is the Submit button in the portal? There is no more submit button! The application for submissions around QPP was designed with real-time scoring and feedback built in to the functionality for that application. That said, any data that is submitted to the application, whether attested on the user interface (UI) or submitted through a file upload or data coming in through other sources, is actually stored and evaluated in real time.

47 47 APPENDIX: FREQUENTLY ASKED QUESTIONS Only the most favorable MIPS Final Score for a TIN-NPI is attributed to a TIN-NPI. But how does that play into submissions? Where there is a group and an individual submission, there is no combining of methods, so there would be a submission for an individual and a submission for a group. The only way that the TIN-NPI would actually be used as the submission would be if the overall submission score is higher than the group s. It takes into consideration the other two categories, as well. So, that individual would need to go in and submit as an individual for the PI and IA categories too. Otherwise, the group score, most likely by default if the group is reporting all three categories, is going to be higher.

48 48 APPENDIX: FREQUENTLY ASKED QUESTIONS Why is it that only one submission method is being scored despite having those multiple submission methods present? In the QPP portal during the submission period, you ll be able to see that data was submitted by you, or on your behalf by a third party, for EACH performance category. At the end of the data submission period, the single submission mechanism (QCDR, QR, attestation, EHR, etc.) that resulted in the highest performance category score will be your score for that performance category and will contribute towards your MIPS Final Score. NOTE: Data will not be aggregated across submission mechanisms to calculate your highest possible score for a performance category.

49 49 APPENDIX: FREQUENTLY ASKED QUESTIONS Why is my score no longer increasing although I am continuing to attest to Improvement Activities or Promoting Interoperability measures after seeing the 'Category Success' message (in the portal)? In the QPP portal during the submission period, if you are seeing that message that you've achieved category success, and you're seeing a category score that appears to be maxed out, you will, in the user interface or file upload, be allowed to continue uploading or attesting for additional measures and activities, and are encouraged to do so in order to submit additional relevant information. However, each of the various category scores does have a maximum score that can be achieved. So, once it has been achieved, additional measures submitted will not further impact the category score.

50 50 APPENDIX: ACRONYMS APM Alternative Payment Model ACO Accountable Care Organization ACI Advancing Care Information CERT Certified EHR Technology CMS Centers for Medicare & Medicaid Services ER Emergency Room EOB Explanation of Benefits EIDM Enterprise Identity Data Management MIPS Merit-based Incentives Payment System PCMH Patient Centered Medical Home PI Promoting Interoperability PQRS Physician Quality Reporting System IA Improvement Activities EHR Electronic Health Records QCDR Qualified Clinical Data Registry QPP Quality Payment Program QRDA Quality Reporting Data Architecture QRUR Quality and Resource Use Reports SURS - Small Underserved Rural Support TIN Tax Identification Number