The Centers for Medicare & Medicaid Services is reviewing claims and letting practices know which clinicians need to take part in MIPS, the Merit-based Incentive Payment System. MIPS is an important part of the new Quality Payment Program. In late April through May, practices will get a letter from the Medicare Administrative Contractor that processes Medicare Part B claims. This letter will tell the participation status of each MIPS clinician associated with the Taxpayer Identification Number or TIN in a practice.
Clinicians should participate in MIPS for the 2017 transition year if they bill more than $30,000 in Medicare Part B allowed charges a year AND provide care for more than 100 Part B-enrolled Medicare beneficiaries a year.
The Quality Payment Program intends to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for their overall work in delivering the best care for patients. It replaces the Sustainable Growth Rate formula and streamlines the “Legacy Programs” Physician Quality Reporting System (PQRS), the Value-based Payment Modifier (VM), and the Medicare Electronic Health Records (EHR) Incentive Program. During this first year of the program CMS is committed to diligently working with you to streamline the process as much as possible. Our goal is to further reduce burdensome requirements so that you can deliver the best possible care to patients. Learn more about the Quality Payment Program.
Contact the Kentucky REC with your questions. Our advisors are here to help you navigate healthcare IT, regulatory issues and more. 859-323-3090
The Center for Children’s Digestive Health (CCDH) has paid the U.S. Department of Health and Human Services (HHS) $31,000 to settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule and agreed to implement a corrective action plan. CCDH is a small, for-profit health care provider with a pediatric subspecialty practice that operates its practice in seven clinic locations in Illinois.
In August 2015, the HHS Office for Civil Rights (OCR) initiated a compliance review of the Center for Children’s Digestive Health (CCDH) following an initiation of an investigation of a business associate, FileFax, Inc., which stored records containing protected health information (PHI) for CCDH. While CCDH began disclosing PHI to Filefax in 2003, neither party could produce a signed Business Associate Agreement (BAA) prior to Oct. 12, 2015.
The Resolution Agreement and Corrective Action Plan may be found on the OCR website at http://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/agreements/CCDH
For more information on Business Associate Agreements, please visit https://www.hhs.gov/hipaa/for-professionals/covered-entities/sample-business-associate-agreement-provisions/index.html
To learn more about non-discrimination and health information privacy laws, your civil rights, and privacy rights in health care and human service settings, and to find information on filing a complaint, visit http://www.hhs.gov/hipaa/index.html
Don’t let this happen to you! Contact the Kentucky REC with your questions. Our security advisors are here to help you. 859-323-3090
In case you missed our informational PCSP webinar last week, we are having a repeat webinar on April 18th, 2017 at 12pm.
The Patient-Centered Specialty Practice is a National Committee for Quality Assurance (NCQA) recognition program that extends the Patient-Centered Medical Home (PCMH) concepts to specialists. Specialty practices committed to access, communication and care coordination can earn accolades as the “neighbors” that surround and inform the medical home and colleagues in primary care.
Our cohort framework is designed to accelerate your journey to NCQA PCSP Recognition within a 14-16 month period. Through our expert training, coaching, and resources, your staff will be well-prepared to carry out the practice transformation process.
Now is the perfect time! By receiving recognition as a PCSP, your organization will receive full points in the Improvement Activities category of the Merit-Based Incentive Payment System under the Medicare Access and CHIP Reauthorization Act (MACRA).
Don’t miss the opportunity to be a part of something special as we work to transform healthcare in Kentucky!
Groups participating in the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program are not required to register, except for groups that intend to utilize the CMS Web Interface and/or administer the Consumer Assessment of Health Providers and Systems (CAHPS) for MIPS survey. To register, please visit the Quality Payment Program website. The registration period is from April 1, 2017 through June 30, 2017.
Under MIPS, a group is defined as a single Taxpayer Identification Number (TIN) with two or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their National Provider Identifiers (NPI), who have reassigned their billing rights to the TIN. Eligible clinicians who participate as a group will be assessed a at a group level across all four MIPS performance categories. The group will receive one payment adjustment for the group’s performance.
Note: Groups that participate in a Shared Savings Program ACO are not required to register or report; the Shared Savings Program ACO is required to report quality measures on behalf of participating eligible clinicians for purposes of MIPS.
For 2017, only groups of 25 or more eligible clinicians that have registered can report via the CMS Web Interface. Groups that participate in MIPS through qualified registry, qualified clinical data registry, or electronic health record data submission mechanisms do not need to register. For 2017, only groups of 2 or more eligible clinicians that have registered can participate in the CAHPS for MIPS survey.
As a courtesy, CMS automatically registered groups for the CMS Web Interface for the 2017 performance period that previously registered for group reporting under the Physician Quality Reporting System (PQRS) Group Practice Reporting Option (GPRO) Web Interface. If you need to remove your registration for Web Interface submission because your group now has fewer than 25 eligible clinicians, you should “cancel” your registration. If your group wants to administer the CAHPS for MIPS survey, your group will need to make an election via the registration system.
The registration period for groups who choose Web Interface or CAHPS for MIPS Survey as their data submission method is April 1 – June 30, 2017.
Note: For individual or group participation, registration is not required for any other submission method.
How to Register
To register, visit Quality Payment Program website.You will need a valid Enterprise Identity Management (EIDM) account with a Physician Value – Physician Quality Reporting System (PV-PQRS) role in order to register.
EIDM Account Information
• Open a New Account: To create or modify an EIDM account, review the Guide for Obtaining a New EIDM Account.
• Reactivate an Account: To reactivate or confirm the status of an account, contact the Quality Payment Program at 1-866-288-8292 (TTY:1-877-715-6222) or firstname.lastname@example.org, Monday – Friday 8:00am – 8:00pm Eastern Time and provide the group name and TIN.
• Use a Current Account: To request a role to access the ‘Physician Quality and Value Programs’ application in the CMS Enterprise Portal, review the Guide for Obtaining a ‘Physician Quality and Value Programs’ Role for an Existing EIDM User.
For More Information: visit the Quality Payment Program website and review the following materials:
Contact the Kentucky REC with your questions. Our advisors are here to help you. 859-323-3090
Kentucky REC presented a MACRA Overview webinar to help organization’s understand how this will impact the way they deliver care.
To listen to the webinar, please click here.
The following questions were asked on the webinar. We have answered the Frequently Asked Questions below.
Please note: If you asked a question and do not see an answer here, please contact us directly and we will be more than happy to speak with you.
1. Are anesthesiologist excluded from MIPS?
Anesthesiologist may be exempt from participating in the MIPS program or certain categories of the program dependent on the place of service codes billed. Once CMS has the NPI lookup feature available you will be able to use this tool to find out for sure. However, until that time, it would be important to evaluate the percentage of “patient facing” encounters the provider has during 2016 to determine eligibility outside of the standard low volume threshold.
2. If we have a high percentage of Medicaid patients, do we need to worry about MACRA?
MACRA exclusions are based on volume, not percent of revenue, so we would suggest you check the dollar amount. An Eligible Clinician (EC) is excluded if he/she bills less than $30,000 or sees less than 100 Medicare patients.
3. How are providers identified as working in an FQHC so they won’t get a penalty for not reporting?
CMS will look at three snapshots of time from 2016 to determine eligibility. If the provider meets the low volume threshold of less than $30,000 Medicare Part B and/or less than 100 Medicare patients then they would be excluded. Traditionally, FQHC providers would not bill Part B outside of ancillary services. However, it is critical that you verify each provider to ensure avoidance of penalty.
4. We are an RHC, are we excluded from participating in MACRA/MIPS?
While RHC payments billed under the all-inclusive payment methodology are excluded, any Medicare Part B payments are included. This would typically include anything billed under ancillary testing (Lab, Radiology, etc). We would encourage you to look at your Medicare Part B billings and determine if your providers have billed less than $30,000 or seen less than 100 patients to be excluded. This would be per provider, if reporting on an individual provider level, or at the group level, if group reporting.
5. We are in an ACO (that is not considered an advanced Alternative Payment Model). Do we still have to participate in MACRA?
Yes, ACO participants are required to report under MACRA. There is not a separate reporting option for the Quality Performance category, as that is reported through your ACO. You would still report on the ACI and IA categories.
6. We are part of an ACO and attesting to PCMH this year, are we under MIPS or APM?
Unless your ACO is considered an advanced Alternative Payment Model, ACO participants are MIPS eligible.
7. We treat nursing home residents and patient engagement is our biggest challenge. The 5% for ACI will be tough. Any advice?
One suggestion is to partner with those nursing homes and see if they will assist in talking about the benefits of the patient portal. Use fliers/brochures to help keep the message in front of patients and families. Have your care team members, most importantly the physicians, talk about the portal. Studies have shown that patients are more responsive if their physician asks them to use the portal versus other staff members.
8. Any guidance on successful strategies to improve patient utilization of portals? Can you provide more information on the “opt-out” option? Is this a viable solution to meeting this requirement?
One of the best strategies to improve use of patient portals is to have the physician engage the patient in discussing portal benefits. Many physicians are encouraging patients to use the portal to request/cancel appointments, request prescriptions on medications when refills expire, and to send private messages to care team members. All these options depend upon the functionality of your particular portal vendor. One caveat to the “opt out” option-you must have a way to show a list of patients who “opt-out” and most systems do not yet have this ability automated. Therefore, you would need a manual process to provide documentation if ever audited.
9. Are psychologists considered Eligible Clinicians?
Under MIPS, psychologists are not considered Eligible Clinicians (ECs) in performance years 2017 and 2018. They should plan on reporting in 2019 (for payment year 2021). While it is not required, it might be beneficial to begin reporting prior to 2019 as a way for the provider to receive feedback and begin implementing strategies that would strengthen their score by 2019.
10. We cannot report using the public health reporting (KHIE) due to the costs constraints. How can you help?
For Advancing Care Information, there is no longer an “all or nothing” approach. Therefore, not having connectivity to KHIE or a public health organization will not prevent you from successful participation.
11. Is full year reporting required to be eligible for part of the $500 million pool for scoring greater than 70 points?
No, a full year is not required. However, a full year reporting period could increase your chance to achieve a score of greater than 70. It is important that you evaluate your reports prior to submission to determine the best submission methods and performance periods.
12. Is the low volume threshold only for one year?
The low volume threshold is based on a “look back” of your previous year’s activity.
13. Is the low volume threshold per provider or per organization?
It depends on how you plan to report. If you do individual reporting, then it is per provider. However, if you plan to do group reporting, then it would be collective for your group.
14. Does MACRA only apply if we are applying for the Medicare EHR Incentive Program? If we are applying for the Medicaid EHR Incentive Program can we also participate in the Medicare EHR Incentive Program?
MACRA is the legislation that created the Quality Payment Program which encompasses the PQRS program, the Medicare EHR Incentive Program and the Value Modifier. If a provider is an Eligible Clinician then the provider would need to participate in one of the two tracks: MIPS or Advanced APM. In addition, if the provider participates in the Medicaid EHR Incentive Program, then the provider can continue to participate in that program through 2021. However, this would require the provider to attest to both one track of the QPP program as well as the Medicaid EHR Incentive Program to avoid penalty and potentially qualify for the Medicaid EHR Incentive program monies.
15. I currently participate in the Medicaid EHR Incentive Program. Do I also have to participate in MACRA?
Medicaid EHR Incentive Program will continue through 2021. If you would like to continue to participate in the Medicaid EHR Incentive Program, you can do so, but it will require dual attestation (MU requirements for Medicaid Program and ACI requirements for QPP Program).
16. Is ACI reporting at the organization level?
ACI reporting can be done at the TIN level or individual NPI level. Depending on the size of your practice and the vendor you use for data capturing, you may have a group level report that can be pulled to determine the group’s performance.
17. How will we attest for MACRA?
Currently there are several different methods to use to submit data for the MIPS program. Check out the QPP.CMS.GOV website to learn more.