In this column, I will return to the topic of the Quality Payment Program (QPP), Centers for Medicare & Medicaid Services’ new payment program, currently scheduled to go into effect January 2017. The QPP has two tracks, the Merit-Based Incentive Payment System (MIPS) and advanced Alternative Payment Models (APMs). Again, it is widely expected that for the first several years of the program, the vast majority of surgeons will participate in the QPP via the MIPS track.
Dr. Patrick V. Bailey
To briefly review from the July edition of this column, MIPS consists of four components:
1) Quality.
2) Resource Use.
3) Advancing Care Information (ACI).
4) Clinical Practice Improvement Activities (CPIA).
The Quality component replaces the Physician Quality Reporting System (PQRS), the Resource Use component replaces the Value-Based Modifier (VBM), the Advancing Care Information (ACI) component replaces the Electronic Health Record Meaningful Use (EHR-MU) program and is proposed to simplify the program by modifying requirements. The fourth component of MIPS, the Clinical Practice Improvement Activities (CPIA), is new.
MIPS participants will be assigned a Composite Performance Score based on their performance in all four components. As proposed for 2017, 50% of the MIPS Composite Performance Score will be based on performance in the Quality component, 25% will be based on the ACI component, 15% will be based on the CPIA, and 10% will be based on Resource Use. Thus, 75% of one’s score will be determined by performance in the Quality and ACI components. With that in mind, the remainder of this month’s column will be dedicated to the ACI with next month’s column focusing on the Quality component.
The Advancing Care Component (ACI)
As discussed above, the ACI component modifies and replaces the Electronic Health Record Meaningful Use (EHR-MU) program. As currently proposed, (and subject to change with release of the final rule in early November 2016), the score for ACI will be derived in two parts: a base score (50 points) and a performance score.
The threshold for achieving the base score remains an “all or nothing” proposition. Achieving the threshold is based upon reporting a yes/no statement OR the appropriate numerator and denominator for each measure, as required, for the following six objectives:
1) Protect Patient Health Information.
2) Electronic Prescribing.
3) Patient Electronic Access to Health Information.
4) Coordination of Care through Patient Engagement.
5) Health Information Exchange.
6) Public Health and Clinical Data Reporting.
Only after meeting the requirements for the base score is one eligible to receive additional performance score credit based on the level of performance on a subset of three of the objectives required to achieve the base score. Those three are:
1) Patient Electronic Access to Health Information.
2) Coordination of Care through Patient Engagement.
3) Health Information Exchange
There are a total of eight measures for these three objectives.
The two measures specific to the Patient Electronic Access objective are:
a) Patient Access Measure.
b) Patient-Specific Education Measure.
Coordination of Care through Patient Engagement is assessed based upon the following three measures:
a) View, Download, Transmit Measure.
b) Secure Messaging Measure.
c) Patient-Generated Health Data Measures.
For the Health Information Exchange objective, assessment is also based on three measures. They are:
a) Patient Record Exchange Measure.
b) Request/Accept Patient Care Record Measure.
c) Clinical Information Reconciliation Measure.
Scoring for each of these eight measures is based upon reporting both a numerator and denominator, thus facilitating the calculation of percentage score to which a point value is assigned. For example, a performance rate of 85 on one of the listed measures would earn 8.5 points toward the performance score. The sum of the points accumulated for these eight measures is added to Threshold Score to determine the final score for ACI. Again, 25% of one’s MIPS Composite Score is derived from performance in the ACI component.
It warrants repeating and re-emphasis that the above information is subject to modification pending the release of the MIPS Final Rule, expected in early November.
As mentioned above, the Quality component of MIPS replaces the PQRS. Quality assessment will comprise 50% of the MIPS Composite Score. In next month’s column, I will provide an outline of the changes CMS is proposing for the Quality assessment. As a preview, some good news can be found in the fact that the current MIPS Quality component proposal will require providers to report on a total of six measures as opposed to the previous PQRS requirement to report on nine.
Until next month …