SLIDE 2
The performance of MIPS participants, referred to as Eligible Clinicians or ECs, is measured across the four weighted performance categories on a 100 point scale, called the Final Score, which is then compared against an annual performance threshold, with Medicare Part B reimbursement rates adjusted based on program performance. In 2018, the Quality performance category is worth 50% of the Final Score, Cost is worth 10% of the Final Score, the Improvement Activities performance category is worth 15% of the Final Score, and the Advancing Care Information performance category is worth 25% of the Final Score.
SLIDE 3
The Advancing Care Information, or ACI, MIPS performance category replaces the Medicare Meaningful Use program and focusses on key measures of health IT interoperability, promoting patient engagement and electronic information exchange. It uses many of the same measures clinicians have been working on for years under Meaningful Use with the exception of the Computerized Provider Order Entry or CPOE measure and the Clinical Decision Support or CDS measure. Additionally, ACI eliminates the all or nothing thresholds for measurement, as well as most of the measure exclusions. In this new version of what was previously Meaningful Use, whatever the numerators and denominators are for a measure, they translate into points. From 2017 to 2018, there was a change in the way engagement with Public Health Agencies is scored with performance category points earned for active engagement with any valid agency or registry and bonus points earned for engagement with any additional valid registries. Along with bonus points, there are two scores which are calculated as part of the ACI category, the base score and the performance score.
SLIDE 5
Although all clinicians in the ACI performance category must use Certified EHR Technology or CEHRT to participate, the ACI measures you report on are dependent on which version of technology you use. There are 2 sets of ACI measures available to participants in 2018, the Advancing Care Information Objectives and Measures, which align with the Meaningful Use Stage 3 requirements, and the 2018 Advancing Care Information Transition Objectives and Measures, which align with the Meaningful Use Modified Stage 2 requirements. For those who have upgraded to the 2015 certified version of their EHR, they can choose to report using the regular ACI objectives and measures, the 2018 transition objectives and measures, or a combination of the 2 measure sets. For those who are still utilizing the 2014 certified version of their EHR, they will report either exclusively using the 2018 transition objectives and measures or can choose to report on a combination of the 2 measure sets, reporting on the regular objectives and measures for which their technology is capable.
SLIDE 6
Looking more closely at the Base Score of the ACI performance category, this is the only place where there is still an all-or-nothing component, similar to the prior legacy Meaningful Use program. In order to receive the 50 points available, a clinician must meet ALL of the base score measure objectives. Failing to meet any of the base score measure objectives will result in a total ACI category score of zero. To meet base score measure objectives, the clinician needs to have a numerator of at least one for an applicable measure, or in the case of the security risk assessment, the clinician must be able to attest Yes to having completed it in 2018. So in terms of the electronic prescribing measure, when the clinician has submitted one prescription electronically, she has met the base score requirements. Do the same for the other base score measures, achieving a numerator of one or attesting Yes to the requirements of a yes/no measure, and the clinician has met the requirements for the Base ACI score and will be awarded the corresponding 50 points.
SLIDE 7
In calculating the Performance Score, clinicians can pick and choose which measures they would like to focus on, allowing program flexibility that did not exist under Meaningful Use. Here, whatever the measure’s numerator and denominator is, it converts into points that add up to a performance score of up to 90 points total or 10 points each. Here again the measures reported on are dependent on the version of EHR is in use, with the 2018 transition objectives having 2 less measures on which to report versus the regular objectives which align with Meaningful Use Stage 3. To compensate, two of the 2018 transition objectives, Provide Patient Access and Health Information Exchange are worth double, earning clinicians as many as 20 performance points each for those measures. When scoring a Yes/No measure, a clinician gets the full 10 points for attesting Yes to meeting the measure objective or zero points for not meeting the objective.
SLIDE 8
There are 2 ways that clinicians can earn bonus points in the ACI performance category. In terms of public health measures, clinicians earn 10 performance score points for actively engaging with any applicable Public Health Agency. Meeting the measure requirements for active engagement with any additional public health organizations earns a clinician up to an additional 5% in bonus points. Additional bonus points can also be earned by using Certified EHR Technology to report certain Improvement Activities. Here CMS has linked 2 of the MIPS performance categories, ACI and Improvement Activities. 18 of the 112 Improvement Activities can potentially earn a clinician up to 10% in ACI bonus points by utilizing CEHRT to implement the activity.
SLIDE 10
Summarizing it all and bringing all of the ACI score components back into a rough scoring example, we have the base score worth either 0 or 50 points. Remember, if the base score requirements are not met, the clinician will receive an overall ACI composite score of zero as no ACI score can be achieved without meeting the base score requirements. Then we have the performance score, worth up to 90 points, which converts measure numerators and denominators into points using a decile system where a performance rate of 8% earns 1 point, a performance rate of 20% earns 2 points and so on up to 10 or 20 possible points depending on the measure. Clinicians can earn up to 15 bonus points for actively engaging with additional public health registries and for leveraging certified EHR technology in the implementation of certain Improvement Activities. Those 3 scoring components then add up to the overall ACI composite score which is maximized when 100 total points are earned. And in a rough scoring example, if a MIPS eligible clinician receives the 50 point base score, earns a 40% performance score and no bonus points, she would earn a 90% ACI performance category score. When weighted by 25% as it is in 2018, this would contribute 22.5 points to the clinician’s overall MIPS Final Score. For most clinicians, meeting the legacy Meaningful Use program requirements and continuing those successful workflows typically translates into a high ACI score.
Learn about the latest fee schedule changes moving from Fee for Service to Value or Quality based payment methodologies, via MACRA/ MIPS/ QPP.
To help clarify some of the terms surrounding Medicare Access and CHIP Reauthorization Act (MACRA), the AMA has compiled a list of acronyms, terms and definitions.
ABC™ - Achievable Benchmark of Care
ACO - accountable care organization
AHRQ - Agency for HealthCare Research and Quality
APM - alternative payment model
APRN - advanced practice registered nurse
ASPE - HHS’ Office of the Assistant Secretary for Planning and Evaluation
AUC - appropriate use criteria
BPCI - bundled payments for care improvement
CAH - critical access hospital
CAHPS - Consumer Assessment of Healthcare Providers and Systems
CBSA - non-core based statistical area
CDS - clinical decision support
CEHRT - certified EHR technology
CFR - Code of Federal Regulations
CHIP - Children’s Health Insurance Program
CJR - comprehensive care for joint replacement
CMMI - Center for Medicare & Medicaid Innovation (CMS Innovation Center)
CMS - Centers for Medicare and Medicaid Services
COI - collection of information
CPIA - clinical practice improvement activity
CPOE - computerized provider order entry
CPR - customary, prevailing and reasonable
CPS - composite performance score
CPT - Current Procedural Terminology
CQM - clinical quality measure
CY - calendar year
DPP - diabetes prevention program
eCQM - Electronic Clinician Quality Measure
ED - Emergency Department
EHR - electronic health record
EP - eligible professional
ESRD - End-stage Renal Disease
FFS - fee for service
FQHC - federally qualified health center
FR - Federal Register
GAO - Government Accountability Office
GPCI - Geographic Practice Cost Index
HAC - hospital-acquired condition
HCAHPS - Hospice Consumer Assessment of Healthcare Providers and Systems
HHS - Department of Health & Human Services
HIE - Health Information Exchange
HIPAA - Health Insurance Portability and Accountability Act of 1996
HITECH - Health Information Technology for Economic and Clinical Health
HOPD - Hospital Outpatient Department
HPSA - health professional shortage area
HRSA - Health Resources and Services Administration
IHS - Indian Health Service
IPAB - Independent Payment Advisory Board
IT - information technology
LDO - large dialysis organization
MA - medical assistant
MAC - Medicare Administrative Contractor
MACRA - Medicare Access and CHIP Reauthorization Act of 2015
MedPAC - Medicare Payment Advisory Commission
MEI - Medicare Economic Index
MIPAA - Medicare Improvements for Patients and Providers Act of 2008
MIPS - Merit-based Incentive Payment System
MLR - minimum loss rate
MSPB - Medicare spending per beneficiary
MSR - minimum savings rate
MU - Meaningful Use
MUA - medically underserved area
NCQA - National Committee for Quality Assurance
NPI - National Provider Identifier
NQF - National Quality Forum
OCM - Oncology Care Model
OIG - Office of the Inspector General
ONC - Office of the National Coordinator for Health Information Technology
PCMH - patient-centered medical home
PCORI - Patient-centered Outcomes Research Institute
PECOS - Medicare Provider Enrollment, Chain and Ownership System
PFPMs - physician-focused payment models
PFS - physician fee schedule
PHS - public health service
PPS - prospective payment system
PQRS - Physician Quality Reporting System
PTAC - Physician-focused Payment Model Technical Advisory Committee
QCDR - qualified clinical data registry
QIO - quality improvement organization
QP - qualifying APM participant
QPP - Quality Payment Program
QRDA - quality reporting document architecture
QRUR - quality and resource use reports
RAC - recovery audit contractor
RBRVS - Resource-based Relative Value Scale
RFI - request for information
RHC - rural health clinic
RIA - regulatory impact analysis
RVU - relative value unit
SGR - sustainable growth rate
TCPI - Transforming Clinical Practice Initiative
TIN - tax identification number
VBM - value-based payment modifier
VPS - volume performance standard