MACRA’s Quality Payment Program Frequently Asked Questions1

CONTENTS MACRA ...................................................................................................................................................................... 2

Merit-Based Incentive Payment System (MIPS) ....................................................................................................... 2

Advanced Alternative Payment Models (APMS) ................................................................................................... 2-3

Joining an Advanced APM ........................................................................................................................................ 3

Incentive payment calculations for APMs ................................................................................................................ 4

MIPS eligibility .......................................................................................................................................................... 4

MIPS, psychologists/social workers and PQRS ......................................................................................................... 5

MIPS and Medicare/Medicaid .................................................................................................................................. 5

How does MIPS measure performance .................................................................................................................... 5

"Pick your pace” reporting .................................................................................................................................... 5-6

CMS determination of payment adjustments .......................................................................................................... 6

MIPS timeframe ........................................................................................................................................................ 7

MIPS vs. PQRS ........................................................................................................................................................... 7

MIPS in 2017 and psychologists/social workers .................................................................................................... 7-8

Individual MIPS reporting ...................................................................................................................................... 7-8

Group MIPS reporting .............................................................................................................................................. 8

Finding a qualified clinical registry ........................................................................................................................... 8

EHR certification ....................................................................................................................................................... 8

MIPS performance reporting ................................................................................................................................. 8-9

MIPS quality measures in 2017 ................................................................................................................................ 9

MIPS improvement measures in 2017 .............................................................................................................. 10-11

ACI measures in 2017 ........................................................................................................................................ 11-15

MIPS 2017 reporting deadline ................................................................................................................................ 15

Small/solo practice MIPS exemptions ............................................................................................................... 15-16

Quality Payment Program help .............................................................................................................................. 16

Additional questions ............................................................................................................................................... 16

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1. What is MACRA? The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is bipartisan legislation that was passed in 2015. The MACRA final rule, released on October 14, 2016, makes sweeping reforms to payments under Medicare Part B, which could increase or decrease the amount your agency is reimbursed by Medicare.

2. What is the Merit-Based Incentive Payment System (MIPS)? MIPS is one of two paths to payment under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program. MIPS consolidates three existing quality incentive payment programs:

• The Physician Quality Reporting System, or PQRS, which requires eligible professionals to report on clinical quality measures;

• The Electronic Health Records Incentive Program, otherwise known as “Meaningful Use,” which provides incentive payments for certain health care providers to use EHR technology to improve patient care

• The Value-based Payment Modifier (VBM), which uses claims and PQRS data to adjust Medicare payments based on quality and cost of care.

MIPS also includes a new performance category, “Improvement Activities,” which enables clinicians to choose from a list of more than 90 quality improvement activities and earn points for implementing those that best suit their practice.

If you decide to participate in traditional Medicare Part B, rather than an Advanced APM, then you will participate in MIPS where you earn a performance-based payment adjustment to your Medicare payment.

CMS anticipates that more than 90 percent of eligible clinicians who bill Medicare Part B will be subject to MIPS when it goes into effect on January 1, 2017.

3. What are Advanced Alternative Payment Models (APMS)?

Advanced APMs are the second path to payment under MACRA’s Quality Payment Program. An APM is a payment approach, developed in partnership with the clinician community, that provides added incentives to clinicians to provide high-quality and cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population. Advanced APMs are a subset of APMs and let practices earn more for taking on some risk related to patients’ outcomes. You may earn a 5% Medicare incentive payment during 2019 through 2024 and be exempt from MIPS reporting requirements and payment adjustments if you have sufficient participation in an Advanced APM. Earning an incentive payment in one year does not guarantee receiving the incentive payment in future years.

1 These FAQs are based on information provided in the final MACRA rule and are accurate as of October 18, 2016. Certain sections of the rule are still open to comment and have not been finalized.

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To be an Advanced APM, an APM must meet the following three criteria: Require participants to use certified EHR technology Provide payment for covered professional services based on quality measures

comparable to those used in the quality performance category of the Merit-based Incentive Payment System (MIPS), and

Either: (1) be a Medical Home Model expanded under CMS Innovation Center authority; or (2) require participating APM Entities to bear more than a nominal amount of financial risk for monetary losses.

The final rule defines the risk requirement for an Advanced APM to be in terms of either total Medicare expenditures or participating organizations’ Medicare revenue (which may vary significantly). This enhanced flexibility allows for the creation of more Advanced APMs tailored to physicians and other clinicians, such as advanced practice nurses, generally, and small practice participation in particular.

The final rule notes that although no Medical Home Models have been expanded under section CMS Innovation Center authority, CMS applies a different Advanced APM financial risk criterion to Medical Home Models, and MIPS eligible clinicians participating in Medical Home Models automatically receive the full score for the MIPS improvement activities performance category.

As defined by MACRA, APMs include:

• Comprehensive ESRD Care (CEC) - Two-Sided Risk

• Comprehensive Primary Care Plus (CPC+)

• Next Generation ACO Model

• Shared Savings Program - Track 2

• Shared Savings Program - Track 3

Note: The final rule states that this list may change; CMS will publish a final list before January 1, 2017.

Due to the requirements that advanced APM participants carry more than nominal risk and use CEHRT, this path to payment will NOT be an option for the vast majority of behavioral health providers. Read more about Advanced APMs in the Quality Payment Program here.

4. How do I join an advanced APM? CMS has established a website for clinicians to learn about specific Advanced APMs and how to apply. You can apply to an Advanced APM that fits your practice and is currently accepting applications. Note: this website will be updated as new information is available.

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5. How are incentive payments calculated for clinicians who participate in an advanced APM? If you receive 25% of Medicare payments or see 20% of your Medicare patients through an Advanced APM in 2017, then you earn a 5% incentive payment in 2019. Positive, neutral or negative payment adjustments will begin in 2019, beginning with adjustment of +/- 4.0%. Adjustments will increase every year, up to +/-9.0% in 2022. The timeline for advanced APM adjustments appears below. The size of your payment adjustment will depend both on how much data you submit and your quality results.

6. Who is eligible to participate in MIPS?

In 2017, MIPS eligible clinicians are those who bill Medicare Part B using the physician fee schedule, including:

• Physicians (including psychiatrists) • Physician assistants • Nurse practitioners • Clinical nurse specialists • Certified registered nurse anesthetists

In 2017, MIPS does NOT apply to:

• Clinical psychologists and licensed clinical social workers (although they may be added to the eligible list in 2019)

• First-year Medicare providers • Qualifying Advanced APM clinicians • Hospitals and facilities (i.e. skilled nursing facilities) • Providers who serve fewer than 100 Medicare recipients OR bill Medicare less than

$30,000 per year (“low-volume threshold”) • Clinicians and groups who are not paid under the Physician Fee Schedule (i.e. FQHCs and

partial hospitalization programs)

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7. Since MIPS may not apply to psychologists and social workers until 2019, does that mean they will have to participate in the Physician Quality Reporting System (PQRS) in 2017 and 2018? No, they will not have to participate in PQRS. PQRS, the Value-Based Modifier and Medicare’s Meaningful Use program are officially “sun setting” and will not apply to any clinicians as of January 1, 2017.

8. Does MIPS affect… • Medicare Advantage or managed care? • Medicaid reporting and reimbursement? • Medicare reimbursement for Rural Health Clinics or FQHCs? • Medicare reimbursement for hospitals or facilities?

No. MIPS only applies to clinicians who bill Medicare Part B using the physician fee schedule, and does NOT apply to hospitals or facilities.

9. How does MIPS measure performance? MIPS eligible clinicians can earn a payment adjustment based on evidence-based and practice-specific quality data. You show you provided high quality, efficient care supported by technology by sending in information in the following categories:

The cost category will be calculated in 2017, but will NOT be used to determine your payment adjustment. In 2018, we will start using the cost category to determine your payment adjustment.

10. What does it mean to “pick your pace” with MACRA reporting? Referring to 2017 as a “transition year,” the final rule states that clinicians and groups can “pick their pace” for the Quality Payment Program. If you're ready, you can begin January 1, 2017 and start collecting performance data. If you're not ready on January 1, you can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you'll need to

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send in your performance data by March 31, 2018. The first payment adjustments based on performance go into effect on January 1, 2019. If you choose the MIPS path of the Quality Payment Program, you have three options:

11. How will CMS determine payment adjustments? Depending on the data you submit by March 31, 2018, your 2019 Medicare payments will be adjusted up, down, or not at all. The information provided below is only relevant for the 2019 payment year.

CMS will provide additional information on payment adjustments for 2020 and beyond beginning next year.

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12. What is the timeframe for MIPS reporting, CMS feedback and payment adjustments? MIPS will go into effect on January 1, 2017. Feedback will be available in 2018. CMS will make positive, neutral or negative payment adjustments in 2019 based on 2017 participation and reporting (see #9).

13. Is MIPS a pay-for-reporting system, like the Physician Quality Reporting System (PQRS)?

No. Unlike PQRS, MIPS is not a pay-for-reporting program, and will not have a “satisfactory reporting” requirement. The data you submit for each quality measure will be compared to benchmarks in order to determine your Quality score. The baseline period for deriving benchmarks will be two years prior to the performance year, which will enable CMS to publish measure benchmarks prior to the start of the relevant performance year.

14. Our clinic has a mix of psychologists, social workers, nurse practitioners, and psychiatrists.

Since half of them are required to participate in MIPS in 2017, should the social workers and psychologists participate as well? LCSWs, clinical psychologists and other non-MIPS eligible clinicians can elect to participate in MIPS in 2017. The proposed rule states that if non-MIPS eligible individual clinicians and groups elect to participate, CMS would calculate administrative claims resource use measures and quality measures, if data are available.

15. How do I report to MIPS as an individual clinician?

If you choose to report as an individual, you’ll send your individual data for each of the MIPS categories through an electronic health record, registry, or a qualified clinical data registry. You may also send in quality data through your routine Medicare claims process (reporting via claims is not an option is not available for groups). If you decide to report to MIPS as an individual, your payment adjustment will be based on your individual performance across all categories. An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number.

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Note: you will be exempt from MIPS if you do not meet the low-volume threshold at the individual level.

16. How do I report to MIPS as part of a group?

If you send your MIPS data with a group, the group will get one payment adjustment based on the group’s performance. A group is defined as a set of clinicians (identified by their NPIs) sharing a common Tax Identification Number, no matter the specialty or practice site. Your group will send in group-level data for each of the MIPS categories through the CMS Web Interface or an electronic health record, registry, or a qualified clinical data registry. To submit data through our CMS web interface, you must register as a group by June 30, 2017. If they do not register as a group before June 30, 2017, eligible clinicians will need to report as individuals. Note: If clinicians decide to report as a group, the low-volume threshold will be applied at the group level.

17. How can I find a qualified clinical registry?

CMS has not yet released its list of QCDRs for 2017. A list of 2016 PQRS QCDRs can be found here.

18. How do I know if my EHR is certified? Check that your electronic health record is certified by the Office of the National Coordinator for Health Information Technology. CMS has included a link to this office on its Quality Payment Program website. If your electronic health record is certified, it should be ready to capture information for the MIPS advancing care information category and certain measures for the quality category.

19. What do I have to do to report in each MIPS performance category?

In 2017, CMS will only factor in quality (60%), advancing care information (25%) and improvement activities (15%) to determine MIPS eligible clinicians’ final score. Clinicians need to report in three categories only—the cost category does not require data submission, as this category is calculated using Medicare claims. CMS will start factoring the cost category into MIPS eligible clinicians’ final scores in 2018.

Quality Most participants: Report up to 6 quality measures, including an outcome

measure, for a minimum of 90 days.

Groups using the web interface: Report 15 quality measures for a full year

Advancing Care Information

Fulfill the required measures for a minimum of 90 days:

Security Risk Analysis e-Prescribing

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Provide Patient Access Send Summary of Care Request/Accept Summary of Care

Choose to submit up to 9 measures for a minimum of 90 days for additional credit. For bonus credit, you can: Report Public Health and Clinical Data Registry Reporting measures Use certified EHR technology to complete certain improvement

activities in the improvement activities performance category

OR

You may not need to submit advancing care information if these measures do not apply to you.

Improvement Activities

• Most participants: Attest that you completed up to 4 improvement activities for a minimum of 90 days.

• Groups with fewer than 15 participants or if you are in a rural or health professional shortage area: Attest that you completed up to 2 activities for a minimum of 90 days.

• Participants in certified patient-centered medical homes, comparable specialty practices, or an APM designated as a Medical Home Model: You will automatically earn full credit.

Cost Data submission is NOT required. CMS calculates this performance category from adjudicated claims.

20. What behavioral health-related MIPS quality measures are available in 2017?

Clinicians can review 2017 MIPS quality measures here. CMS’s new Quality Payment Program (QPP) website enables you to browse the measures and select the ones that you feel best align with your practice in a ‘shopping cart’ for further review. This tool also allows you to search quality measures by submission method, and according to whether it is a “high priority” measure or appears on a specialty measure list. CMS significantly expanded the list of quality measures available under the behavioral health specialty measure set in the final rule. (The proposed rule contained only 10 behavioral health-related measures, the majority of which pertained to dementia). The revised behavioral health quality measure specialty set includes measures such as depression utilization of the PHQ-9 tool, coordination of care for patients with major depressive disorder and specific comorbid conditions, preventive screening for alcohol and tobacco use, and documentation of current medications in the medical record. Please see the CMS QPP website for the full list of behavioral health specialty set quality measures. The site enables you to browse the quality measures and search for measures by specialty set, data submission method and high priority status.

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21. What behavioral health-related MIPS improvement measures are available in 2017? Clinicians can review 2017 improvement activity measures here. There are eight behavioral health-related improvement activity measures listed for 2017. Each improvement activity is weighted either “high” or “medium.” These include:

Measure Definition Weight Depression screening

Depression screening and follow-up plan: Regular engagement of MIPS eligible clinicians or groups in integrated prevention and treatment interventions, including depression screening and follow-up plan (refer to NQF #0418) for patients with co-occurring conditions of behavioral or mental health conditions.

Medium

Diabetes screening

Diabetes screening for people with schizophrenia or bipolar disease who are using antipsychotic medication.

Medium

EHR record enhancements for BH data capture

Enhancements to an electronic health record to capture additional data on behavioral health (BH) populations and use that data for additional decision-making purposes (e.g., capture of additional BH data results in additional depression screening for at-risk patient not previously identified).

Medium

Implementation of co-located PCP and MH services

Integration facilitation, and promotion of the colocation of mental health services in primary and/or non-primary clinical care settings

High

Implementation of integrated PCBH Model

Offer integrated behavioral health services to support patients with behavioral health needs, dementia, and poorly controlled chronic conditions that could include one or more of the following: Use evidence-based treatment protocols and treatment to goal where appropriate; Use evidence-based screening and case finding strategies to identify individuals at risk and in need of services; Ensure regular communication and coordinated workflows between eligible clinicians in primary care and behavioral health; Conduct regular case reviews for at-risk or unstable patients and those who are not responding to treatment; Use of a registry or certified health information technology functionality to support active care management and outreach to patients in treatment; and/or Integrate behavioral health and medical care plans and facilitate integration through co-location of services when feasible.

High

MDD prevention and treatment interventions

Major depressive disorder: Regular engagement of MIPS eligible clinicians or groups in integrated prevention and treatment interventions, including suicide risk assessment (refer to NQF #0104) for mental health patients with co-occurring conditions of behavioral or mental health conditions.

Medium

Tobacco Use Tobacco use: Regular engagement of MIPS eligible clinicians or groups in integrated prevention and treatment interventions, including tobacco use screening and cessation interventions (refer to NQF #0028) for patients with co-occurring conditions of behavioral or mental health and at risk factors for tobacco dependence.

Medium

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Unhealthy Alcohol Use

Unhealthy alcohol use: Regular engagement of MIPS eligible clinicians or groups in integrated prevention and treatment interventions, including screening and brief counseling (refer to NQF #2152) for patients with co-occurring conditions of behavioral or mental health conditions.

Medium

22. What Advancing Care Information measures are available in 2017?

In 2017, there are two measure set options for reporting. The option you use to submit your data is based on your electronic health record edition.

• Option 1: Advancing Care Information Objectives and Measures (15 measures)

• Option 2: 2017 Advancing Care Information Transition Objectives and Measures (11 measures)

These measures appear in the chart below. You may view them online here.

Advancing Care Information Objectives and Measures

Measure Definition Need for Base Score?

Score Weight

Clinical Data Registry Reporting

The MIPS eligible clinician is in active engagement to submit data to a clinical data registry. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

Clinical Information Reconciliation

For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician performs clinical information reconciliation. The MIPS eligible clinician must implement clinical information reconciliation for the following three clinical information sets: (1) Medication. Review of the patient's medication, including the name, dosage, frequency, and route of each medication. (2) Medication allergy. Review of the patient's known medication allergies. (3) Current Problem list. Review of the patient's current and active diagnoses.

No Up to 10%

Electronic Case Reporting

The MIPS eligible clinician is in active engagement with a public health agency to electronically submit case reporting of reportable conditions. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

e-Prescribing At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology.

Yes 0

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Immunization Registry Reporting

The MIPS eligible clinician is in active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS).

No 0 or 10%

Patient-Generated Health Data

Patient-generated health data or data from a non-clinical setting is incorporated into the certified EHR technology for at least one unique patient seen by the MIPS eligible clinician during the performance period.

No Up to 10%

Patient-Specific Education

The MIPS eligible clinician must use clinically relevant information from certified EHR technology to identify patient-specific educational resources and provide electronic access to those materials to at least one unique patient seen by the MIPS eligible clinician.

No Up to 10%

Provide Patient Access

For at least one unique patient seen by the MIPS eligible clinician: (1) The patient (or the patient authorized representative) is provided timely access to view online, download, and transmit his or her health information; and (2) The MIPS eligible clinician ensures the patient's health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programing Interface (API) in the MIPS eligible clinician's certified EHR technology.

Yes Up to 10%

Public Health Registry Reporting

The MIPS eligible clinician is in active engagement with a public health agency to submit data to public health registries. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

Secure Messaging

For at least one unique patient seen by the MIPS eligible clinician during the performance period, a secure message was sent using the electronic messaging function of certified EHR technology to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative).

No Up to 10%

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Security Risk Analysis

Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI data created or maintained by certified EHR technology in accordance with requirements in 45 CFR164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician's risk management process.

Yes 0

Send a Summary of Care Record

For at least one transition of care or referral, the MIPS eligible clinician that transitions or refers their patient to another setting of care or health care provider-(1) creates a summary of care record using certified EHR technology; and (2) electronically exchanges the summary of care record.

Yes Up to 10%

Summary of Care Measure

For at least one transition of care or referral received or patient encounter in which the MIPS eligible clinician has never before encountered the patient, the MIPS eligible clinician receives or retrieves and incorporates into the patient's record an electronic summary of care document.

Yes Up to 10%

Syndromic Surveillance Reporting

The MIPS eligible clinician is in active engagement with a public health agency to submit syndromic surveillance data from a urgent care ambulatory setting where the jurisdiction accepts syndromic data from such settings and the standards are clearly defined. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

View, Download and Transmit (VDT)

During the performance period, at least one unique patient (or patient-authorized representatives) seen by the MIPS eligible clinician actively engages with the EHR made accessible by the MIPS eligible clinician. An MIPS eligible clinician may meet the measure by either-(1) view, download or transmit to a third party their health information; or (2) access their health information through the use of an API that can be used by applications chosen by the patient and configured to the API in the MIPS eligible clinician's certified EHR technology; or (3) a combination of (1) and (2).

No Up to 10%

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2017 Advancing Care Information Transition Objectives and Measures

Measure Definition Need for Base Score?

Score Weight

e-Prescribing At least one permissible prescription written by the MIPS eligible clinician is queried for a drug formulary and transmitted electronically using certified EHR technology.

Yes 0

Health Information Exchange

The MIPS eligible clinician that transitions or refers their patient to another setting of care or health care clinician (1) uses CEHRT to create a summary of care record; and (2) electronically transmits such summary to a receiving health care clinician for at least one transition of care or referral.

Yes Up to 20%

Immunization Registry Reporting

The MIPS eligible clinician is in active engagement with a public health agency to submit immunization data.

No 0 or 10%

Medication Reconciliation

The MIPS eligible clinician performs medication reconciliation for at least one transition of care in which the patient is transitioned into the care of the MIPS eligible clinician.

No Up to 10%

Patient-Specific Education

The MIPS eligible clinician must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials to at least one unique patient seen by the MIPS eligible clinician.

No Up to 10%

Provide Patient Access

At least one patient seen by the MIPS eligible clinician during the performance period is provided timely access to view online, download, and transmit to a third party their health information subject to the MIPS eligible clinician's discretion to withhold certain information.

Yes Up to 20%

Secure Messaging

For at least one unique patient seen by the MIPS eligible clinician during the performance period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the performance period.

No Up to 10%

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Security Risk Analysis

Conduct or review a security risk analysis in accordance with the requirements in 45 CFR 164.308(a)(1), including addressing the security (to include encryption) of ePHI data created or maintained by certified EHR technology in accordance with requirements in 45 CFR164.312(a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the MIPS eligible clinician's risk management process.

Yes 0

Specialized Registry Reporting

The MIPS eligible clinician is in active engagement to submit data to specialized registry. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

Syndromic Surveillance Reporting

The MIPS eligible clinician is in active engagement with a public health agency to submit syndromic surveillance data. Earn a 5 % bonus in the advancing care information performance category score for submitting to one or more public health or clinical data registries.

No 0

View, Download, or Transmit (VDT)

At least one patient seen by the MIPS eligible clinician during the performance period (or patient-authorized representative) views, downloads or transmits their health information to a third party during the performance period.

No Up to 10%

23. When do MIPS data need to be reported for the 2017 performance year?

The MIPS data submission deadline is March 31 following the close of the performance period. CMS anticipates that the submission period would begin January 2 following the close of the performance period. For example, for the first MIPS performance period, the data submission period would occur from January 2, 2018, through March 31, 2018.

24. Are there any special MIPS provisions or exemptions for small or solo behavioral health practices? Yes. The final rule includes the following provisions for small practices (defined as 15 or fewer clinicians) and practices in rural or health professional shortage areas. For example:

• Low Volume Exclusions: Clinicians who serve fewer than 100 Medicare patients and bill Medicare less than $30,000 in 2017 do not need to participate in the Quality Payment Program (This is also known as the low-volume threshold).

• Flexibility in MIPS Scoring Based on Applicable Measures: The final rule stipulates that small and solo practices will have fewer reporting requirements. For example, small

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and solo practices only need to attest to two improvement activities to earn full credit compared to four activities for the majority of MIPS eligible clinicians.

• Group Reporting: Under MIPS, clinicians will have the option to be assessed as a group across all four MIPS performance categories. The law provides that solo and small practices may join “virtual groups” and combine their MIPS reporting, although this option will not be available in the 2017 performance year.

MACRA also provides $20 million each year for five years to fund training and education for Medicare clinicians in individual or small group practices of 15 clinicians or fewer and those working in underserved areas. Beginning December 2016, local, experienced organizations will use this funding to help small practices select appropriate quality measures and health IT to support their unique needs, train clinicians about the new improvement activities and assist practices in evaluating their options for joining an Advanced APM.

25. Where should I go for help with the Quality Payment Program? Transforming Clinical Practice Initiative (TCPI): TCPI is designed to support more than 140,000 clinician practices over the next 4 years in sharing, adapting, and further developing their comprehensive quality improvement strategies. Clinicians participating in TCPI will have the advantage of learning about MIPS and how to move toward participating in Advanced APMs. Click here to find help in your area. Quality Innovation Network (QIN)-Quality Improvement Organizations (QIOs): The QIO Program’s 14 QIN-QIOs bring Medicare beneficiaries, providers, and communities together in data-driven initiatives that increase patient safety, make communities healthier, better coordinate post-hospital care, and improve clinical quality. More information about QIN-QIOs can be found here. If you’re in an APM: The Innovation Center’s Learning Systems can help you find specialized information about what you need to do to be successful in the Advanced APM track. If you’re in an APM that is not an Advanced APM, then the Learning Systems can help you understand the special benefits you have through your APM that will help you be successful in MIPS. More information about the Learning Systems is available through your model’s support inbox.

26. If I have additional questions, who should I contact? Please contact Elizabeth Arend at ElizabethA@TheNationalCouncil.org. You can find additional resources at www.TheNationalCouncil.org/MACRA.

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MACRA Questions Policy Committee 11/16-11/17

Dual eligibility Q. If a provider bills and receives payment from Medicare but has Medicaid secondary, would these providers be eligible for MIPS?

A. The final rule indicates that the only beneficiaries that “count” when it comes to a clinician’s eligibility are Part B enrolled Medicare beneficiaries, and the only charges counted are those billed and allowed by Medicare Part B. So if you are an eligible clinician (i.e. an MD, NP or PA) and bill Medicare Part B when you treat patients, you may be eligible to participate in MIPS based on any payments made by Part B without regard to whatever secondary payments are made by Medicaid. (You would also need to fall above the low-volume threshold of serving 100+ Medicare Part B enrolled beneficiaries and billing Medicare Part B more than $30,000 per year using the physician fee schedule). Also, you would not be eligible if 2017 was your first year billing Medicare).

Q. Do dual eligible patients “count” in regard to the low-volume threshold?

A: The final rule states that CMS will “identify Medicare Part B allowed charges billed by the eligible clinician and the number of Part B-enrolled Medicare beneficiaries cared for by an eligible clinician during the first and second low-volume threshold determination periods.” There is no mention of dual eligible patients being factored in when CMS determines where you/your group falls in relation to the low-volume threshold, so they are counted just like other Part B-enrolled Medicare beneficiaries.

Q. Can eligible clinicians get credit under MIPS for serving Medicaid patients including dual eligibles?

A. Yes. Dual eligibles are considered Medicare patients, so clinicians are evaluated for treating them under all of the performance measures. Under the Improvement Activities category, eligible clinicians can also earn points by “Seeing new and follow-up Medicaid patients in a timely manner, including individuals dually eligible for Medicaid and Medicare.” This activity is weighted as “high” and is worth 20 points for most clinicians (eligible clinicians at small, rural and HPSA practices will need to report on fewer activities in this category and categories that are weighted as “high” will carry greater point value).

Non-eligible Providers Q. Will non-eligible providers be included in the overall group calculations and scores?

A. Non-MIPS eligible clinicians will NOT be subject to scoring or payment adjustments in 2017, but they can voluntarily report. They will still receive feedback on their performance, but their performance will not be factored into the group practice’s final score or payment adjustment.

The main motivator for non-eligible clinicians to participate is the feedback and the practice with the system, so when clinical psychologists and LCSWs are added to the list of eligible clinicians, they’re ready to go.

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Eligible clinicians can still shoot for a positive payment adjustment—and even a performance bonus—if they do well in the quality and ACI categories, where they can earn bonus points. Attached is the National Council’s updated MIPS Resource Guide, which provides more detail about scoring in each category.

Additional Resources: Quality Payment Program Website National Council MIPS Resource Guide National Council MACRA FAQs