As of January 1, 2017, the Quality Payment Program is in effect. So long fee-for-service, welcome to value-based reimbursement! On January 19, DataFile Technologies hosted a complimentary webinar featuring Kathryn Ayers Wickenhauser, Regulatory Compliance Advisor, to explain this latest healthcare reform and the impact to providers as they transition to value-based payments.
The audience was very engaged and we received a number of great questions that we weren’t able to address on the webinar. Here are the frequently asked questions that you asked our experts about MACRA. As MACRA and the Quality Payment Program seem to be “moving targets” and continue to evolve, please note that the questions and answers that appear here are not intended to be legal advice and DataFile Technologies is not liable for the content here within.
Q: Where can we listen to the webinar?
A: If you missed the webinar, or you’d like to share it with a colleague, please listen to the webinar in its entirety here.
Q: Where can we find more information on the Quality Payment Program?
A: Certainly visit the Quality Payment Program website. We also recommend utilizing any professional societies you are part of to find more information relevant to your specialty. DataFile will continue to be your healthcare data experts as we post content and updates to our blog. We also invite you to subscribe to DataFile Digest, our monthly newsletter here.
Q: What is the certified EHR requirement for performance year 2017? Is there a schedule available?
A: For 2017 performance and reporting, 2014 or 2015 CEHRT (Certified Electronic Health Record Technology) will be accepted. For the ACI category, choose your version of your CEHRT to determine what your 2017 reporting measures could be. For 2018 reporting, eligible clinicians will be required to use 2015 CEHRT.
Q: We are probably going to change out EHRs mid-way through 2017. Will we still be able to meet the threshold?
A: Great question! I would recommend reaching out directly to CMS and clarifying this question with them for your particular situation. MIPS does not require a set period of time to report. To avoid the negative payment adjustment, a provider must report at least one measure. My advice would be to try and gather data for at least 90 days in both places and submit whichever one is higher. This aligns with CMS advice that if an eligible clinician switches practices in 2017, to use the data from whichever data set is higher. Of course, you will want to clarify your individual situation with CMS!
Q: Is there any information on how this change is going to affect pediatrics and non-Medicare providers?
A: One of my favorite phrases (and is now deemed a Kathryn-ism!) is “when CMS institutes, commercial payers follow suit.” Even if the specific CMS Quality Payment Program does not apply to you because you meet the exclusion criteria, commercial payers are already paying more to clinicians who demonstrate quality care through quality measure reporting. I would check in with your professional organizations on their advice for you as well. Quality care is not limited to Medicare, it will certainly transcend boundaries into the commercial sector — in fact, it already is!
Q: Why would a group want to report as individuals instead of reporting as a group?
A: There are a multitude of reasons an organization may want to report individually or as a group. First of all, it’s an all or nothing decision based on Tax ID number (TIN). You cannot have some clinicians in a TIN report individually and some as part of the group. If you have a clinician that will have difficulty meeting MIPS (like a subspecialist) it may be in your best interest to report as part of the group. Ultimately MIPS payment adjustment will follow the NPI number, so reporting as group could help that clinical receive a possible positive payment adjustment. If a clinician reports through multiple organizations, it may be best to do individual reporting. Again, the payment adjustment follows the delivery of care associated with a specific NPI. Additionally, many more organizations are basing clinician compensation off of attaining quality metrics, so your organization may want to have clinicians report and be incentivized for the quality care they provide. There are many factors that impact if you can report as a group, but if eligible, it is certainly up to the organization to weigh the benefits of reporting either way.
Q: During the webinar, you mentioned something about points. Can you explain what you mean?
A: Sure! MIPS is broken down into four categories adding up to a composite score out of 100. Three categories, ACI, Quality, and Clinical Practice Improvement Activities, are counted in 2017. Cost will become the fourth category in 2018. Within each category, there are various measures that add up to an overall category score. Each measure has a top score that can be achieved. Unlike other Pay-for-Performance programs like Meaningful Use, there is no threshold that is required to be met within the MIPS program. Rather, the higher your overall performance on each measure, the higher the score you achieve, which leads to an increased overall composite score. Many of the measures use a decile system, where the percentage directly translates to the number of points you achieve for that measure. For instance, if you achieve a 73% on a given measure, you may fall in the designated Decile 8, which uses a benchmark of 69%-78.9% in this example. Decile 8 then translates to 8-8.9 points out of a possible 10 points. Conversely, if you achieved a 25% on a measure, you could fall in Decile 4 with a range of 23%-35.9%, translating to somewhere between 4-4.9 points. The higher the clinician’s performance on a measure, the higher their percentage, translating to achieving more of the points possible of the measure, resulting in an increased category score and therefore better composite score. This is certainly one of the most confusing parts of the Quality Payment Program! Check out qpp.cms.gov for more information on how these points for measures will occur.