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MACRA: The Implications for Health Care IT Vendors Health Care Industry Committee Health Care IT Advisor Ye Hoffman Senior Analyst June 22, 2016

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Page 1: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

MACRA The Implications for

Health Care IT Vendors

Health Care Industry Committee

Health Care IT Advisor

Ye Hoffman

Senior Analyst

June 22 2016

2

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

3

MACRA Details to Be Finalized in Coming Months

Sources CMS The Advisory Board Company research and analysis

1) Centers for Medicare amp Medicaid Services

2) Merit-Based Incentive Payment System

3) Alternative Payment Model

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Implementation Timeline

MACRA-in-Brief

bull Legislation passed in April 2015 that repealed the Sustainable Growth Rate (SGR)

bull Locks Medicare Part B payment rates at near zero growth 05 increase from

2015ndash2019 00 increase from 2020ndash2025 025 increase from 2026 and on

bull Extra $500M for exceptional performers under MIPS APM bonuses range from

$146M to $429M

Fall 2016

CMS expects to release

final rule by November 1

2016

April 27 2016

CMS1 released proposed rule with

details for MIPS2 and APM3 tracks

and call for comments

January 2017

Performance period begins that

will determine applicable MIPS

or APM track Today

June 27 2016

Comment period on proposed

rule closes

January 2019

First Year of physician

payment adjustment

under MIPS or APM

April 16 2015

MACRA signed into law

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

4

From Standalone Programs to an Integrated Initiative

Source Advisory Board research and analysis

MACRA Reduced Total Maximum Penalties for Near-Term

-4

Prior to MACRA maximum penalty rate among separate quality programs1

-9

Under MACRA 2019 maximum penalty rate based on 2017 MIPS performance

MACRA Consolidates Previous Quality Reporting Programs

for Medicare Clinicians

1) Based on -2 PQRS -4 VBPM -3 MU

2015 2024 2019

Physician Quality Reporting System

(PQRS)

MIPSAPM

Future Years 2011 2007

EHR Incentive Programs

(aka Meaningful Use)

Value-Based Payment Modifier

(VBPM)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

5

MACRA Creates CMS Quality Payment Program

Alternative Payment

Models (APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives 5 annual bonus

in 2019ndash2024 and 075 annual payment

increase from 2026 on

Payment adjustments reach

-9 +27 by 2022

Performance based on 4 categories

Quality Resource use ACI1 CPIA2

MU Under MACRA Does Not Impact Hospitals Medicaid-Eligible Professionals (EPs)

bull 2016 not impacted for any provider in MU including Medicare EPs

bull MU as defined by Modified Stage 2 and Stage 3 regulation continues on as is for eligible hospitals (EHs)

and Medicaid EPs

bull CMS indicates in a recent blog post that they are planning to work with EHs and Medicaid EPs to

determine whether they could align ACI with existing MU requirementsmdashtimeline not clear

1) Advancing Care Information (ie EHR use)

2) Clinical Practice Improvement Activities

CMS Quality Payment Program

Sources HR 2 Medicare Access and CHIP Reauthorization Act of

2015 CMS blog ldquoMoving toward improved care through informationrdquo

April 2016 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 2: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

2

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

3

MACRA Details to Be Finalized in Coming Months

Sources CMS The Advisory Board Company research and analysis

1) Centers for Medicare amp Medicaid Services

2) Merit-Based Incentive Payment System

3) Alternative Payment Model

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Implementation Timeline

MACRA-in-Brief

bull Legislation passed in April 2015 that repealed the Sustainable Growth Rate (SGR)

bull Locks Medicare Part B payment rates at near zero growth 05 increase from

2015ndash2019 00 increase from 2020ndash2025 025 increase from 2026 and on

bull Extra $500M for exceptional performers under MIPS APM bonuses range from

$146M to $429M

Fall 2016

CMS expects to release

final rule by November 1

2016

April 27 2016

CMS1 released proposed rule with

details for MIPS2 and APM3 tracks

and call for comments

January 2017

Performance period begins that

will determine applicable MIPS

or APM track Today

June 27 2016

Comment period on proposed

rule closes

January 2019

First Year of physician

payment adjustment

under MIPS or APM

April 16 2015

MACRA signed into law

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

4

From Standalone Programs to an Integrated Initiative

Source Advisory Board research and analysis

MACRA Reduced Total Maximum Penalties for Near-Term

-4

Prior to MACRA maximum penalty rate among separate quality programs1

-9

Under MACRA 2019 maximum penalty rate based on 2017 MIPS performance

MACRA Consolidates Previous Quality Reporting Programs

for Medicare Clinicians

1) Based on -2 PQRS -4 VBPM -3 MU

2015 2024 2019

Physician Quality Reporting System

(PQRS)

MIPSAPM

Future Years 2011 2007

EHR Incentive Programs

(aka Meaningful Use)

Value-Based Payment Modifier

(VBPM)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

5

MACRA Creates CMS Quality Payment Program

Alternative Payment

Models (APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives 5 annual bonus

in 2019ndash2024 and 075 annual payment

increase from 2026 on

Payment adjustments reach

-9 +27 by 2022

Performance based on 4 categories

Quality Resource use ACI1 CPIA2

MU Under MACRA Does Not Impact Hospitals Medicaid-Eligible Professionals (EPs)

bull 2016 not impacted for any provider in MU including Medicare EPs

bull MU as defined by Modified Stage 2 and Stage 3 regulation continues on as is for eligible hospitals (EHs)

and Medicaid EPs

bull CMS indicates in a recent blog post that they are planning to work with EHs and Medicaid EPs to

determine whether they could align ACI with existing MU requirementsmdashtimeline not clear

1) Advancing Care Information (ie EHR use)

2) Clinical Practice Improvement Activities

CMS Quality Payment Program

Sources HR 2 Medicare Access and CHIP Reauthorization Act of

2015 CMS blog ldquoMoving toward improved care through informationrdquo

April 2016 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 3: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

3

MACRA Details to Be Finalized in Coming Months

Sources CMS The Advisory Board Company research and analysis

1) Centers for Medicare amp Medicaid Services

2) Merit-Based Incentive Payment System

3) Alternative Payment Model

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Implementation Timeline

MACRA-in-Brief

bull Legislation passed in April 2015 that repealed the Sustainable Growth Rate (SGR)

bull Locks Medicare Part B payment rates at near zero growth 05 increase from

2015ndash2019 00 increase from 2020ndash2025 025 increase from 2026 and on

bull Extra $500M for exceptional performers under MIPS APM bonuses range from

$146M to $429M

Fall 2016

CMS expects to release

final rule by November 1

2016

April 27 2016

CMS1 released proposed rule with

details for MIPS2 and APM3 tracks

and call for comments

January 2017

Performance period begins that

will determine applicable MIPS

or APM track Today

June 27 2016

Comment period on proposed

rule closes

January 2019

First Year of physician

payment adjustment

under MIPS or APM

April 16 2015

MACRA signed into law

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

4

From Standalone Programs to an Integrated Initiative

Source Advisory Board research and analysis

MACRA Reduced Total Maximum Penalties for Near-Term

-4

Prior to MACRA maximum penalty rate among separate quality programs1

-9

Under MACRA 2019 maximum penalty rate based on 2017 MIPS performance

MACRA Consolidates Previous Quality Reporting Programs

for Medicare Clinicians

1) Based on -2 PQRS -4 VBPM -3 MU

2015 2024 2019

Physician Quality Reporting System

(PQRS)

MIPSAPM

Future Years 2011 2007

EHR Incentive Programs

(aka Meaningful Use)

Value-Based Payment Modifier

(VBPM)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

5

MACRA Creates CMS Quality Payment Program

Alternative Payment

Models (APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives 5 annual bonus

in 2019ndash2024 and 075 annual payment

increase from 2026 on

Payment adjustments reach

-9 +27 by 2022

Performance based on 4 categories

Quality Resource use ACI1 CPIA2

MU Under MACRA Does Not Impact Hospitals Medicaid-Eligible Professionals (EPs)

bull 2016 not impacted for any provider in MU including Medicare EPs

bull MU as defined by Modified Stage 2 and Stage 3 regulation continues on as is for eligible hospitals (EHs)

and Medicaid EPs

bull CMS indicates in a recent blog post that they are planning to work with EHs and Medicaid EPs to

determine whether they could align ACI with existing MU requirementsmdashtimeline not clear

1) Advancing Care Information (ie EHR use)

2) Clinical Practice Improvement Activities

CMS Quality Payment Program

Sources HR 2 Medicare Access and CHIP Reauthorization Act of

2015 CMS blog ldquoMoving toward improved care through informationrdquo

April 2016 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 4: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

4

From Standalone Programs to an Integrated Initiative

Source Advisory Board research and analysis

MACRA Reduced Total Maximum Penalties for Near-Term

-4

Prior to MACRA maximum penalty rate among separate quality programs1

-9

Under MACRA 2019 maximum penalty rate based on 2017 MIPS performance

MACRA Consolidates Previous Quality Reporting Programs

for Medicare Clinicians

1) Based on -2 PQRS -4 VBPM -3 MU

2015 2024 2019

Physician Quality Reporting System

(PQRS)

MIPSAPM

Future Years 2011 2007

EHR Incentive Programs

(aka Meaningful Use)

Value-Based Payment Modifier

(VBPM)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

5

MACRA Creates CMS Quality Payment Program

Alternative Payment

Models (APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives 5 annual bonus

in 2019ndash2024 and 075 annual payment

increase from 2026 on

Payment adjustments reach

-9 +27 by 2022

Performance based on 4 categories

Quality Resource use ACI1 CPIA2

MU Under MACRA Does Not Impact Hospitals Medicaid-Eligible Professionals (EPs)

bull 2016 not impacted for any provider in MU including Medicare EPs

bull MU as defined by Modified Stage 2 and Stage 3 regulation continues on as is for eligible hospitals (EHs)

and Medicaid EPs

bull CMS indicates in a recent blog post that they are planning to work with EHs and Medicaid EPs to

determine whether they could align ACI with existing MU requirementsmdashtimeline not clear

1) Advancing Care Information (ie EHR use)

2) Clinical Practice Improvement Activities

CMS Quality Payment Program

Sources HR 2 Medicare Access and CHIP Reauthorization Act of

2015 CMS blog ldquoMoving toward improved care through informationrdquo

April 2016 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 5: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

5

MACRA Creates CMS Quality Payment Program

Alternative Payment

Models (APM)

Merit-Based Incentive

Payment System (MIPS)

Exempt from MIPS payment

adjustments

Financial incentives 5 annual bonus

in 2019ndash2024 and 075 annual payment

increase from 2026 on

Payment adjustments reach

-9 +27 by 2022

Performance based on 4 categories

Quality Resource use ACI1 CPIA2

MU Under MACRA Does Not Impact Hospitals Medicaid-Eligible Professionals (EPs)

bull 2016 not impacted for any provider in MU including Medicare EPs

bull MU as defined by Modified Stage 2 and Stage 3 regulation continues on as is for eligible hospitals (EHs)

and Medicaid EPs

bull CMS indicates in a recent blog post that they are planning to work with EHs and Medicaid EPs to

determine whether they could align ACI with existing MU requirementsmdashtimeline not clear

1) Advancing Care Information (ie EHR use)

2) Clinical Practice Improvement Activities

CMS Quality Payment Program

Sources HR 2 Medicare Access and CHIP Reauthorization Act of

2015 CMS blog ldquoMoving toward improved care through informationrdquo

April 2016 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 6: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

6

A Sweeping Impact Across Providers

Whorsquos Included and Who Is Exempt

Sources CMS Advisory Board research and analysis

1) Physician assistants

2) Nurse practitioners

3) Affordable Care Act

Included

Medicare Part B payments

(ie clinician professional

payments)

Clinicians groups that fall under

low volume threshold

bull $10000 or less in Medicare

charges AND

bull 100 or fewer Medicare patients

Providers in their first year

billing Medicare

Physicians PAs1 NPs2

Clinical Nurse Specialists

Certified Registered Nurse

Anesthetists

Groups that include any of

the above clinicians

MACRA is to care delivery

reform what the ACA3 was

to coverage reformrdquo

Andy Slavitt CMS Acting Administrator

Excluded

Estimated number of clinicians affected by

MACRA changes in first performance year

836000

Medicare Part A (ie inpatient

outpatient technical hospital

payments)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 7: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

7

APM Payment Track Looks Enticing

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

0

1

2

3

4

5

6

2015 2020 2025

2015ndash2019

05 annual

update

2020ndash2025

Frozen

payment rates Alternative Payment Model

Track 2026 and on 075

annual update

The Merit-Based Incentive

System 2026 and on 025

annual update

Baseline Payment Adjustments Under Each Track

2019ndash2024

APM track participants

receive 5 annual bonus

Annual Bonus for APM

Participation

Bonus awarded each

year from 2019ndash2024

to clinicians who qualify

for the APM track

5

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 8: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

8

APM Track Qualification Requirements

Not Just Any APM Must Be an Advanced APM

bull More than nominal financial risk (ie threshold to trigger losses no greater than 4

loss sharing at least 30 and maximum possible loss at least 4 of spending target)

bull Certified EHR use

bull Quality requirements comparable to MIPS

Minimum QP Threshold Minimum Partial QP Threshold

20

40 50

25

50

75

2019ndash2020 2021ndash2022 2023 and on

Payment Patient Count Requirements for Qualifying Participants (QPs) Partial QPs

Year

Pe

rce

nt o

f p

aym

en

t

un

de

r A

dva

nce

d A

PM

10

25

35 20

35

50

2019ndash2020 2021ndash2022 2023 and on

Year

Pe

rce

nt o

f p

atie

nt co

un

t

un

de

r A

dva

nce

d A

PM

Payment Patient Count

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 9: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

9

MIPS A Zero-Sum Game for Clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032

Advisory Board research and analysis

1) Eligible clinicians

2) The mean or median (as selected by CMS) of the composite performance scores for all

MIPS-eligible professionals with respect to a prior period specified by the Secretary

3) Payment adjustment size corresponds with how far the score deviates from the PT

4) Additional pool of $500M available for high performers to receive additional incentive of up

to 10 for MIPS-eligible providers that exceed the 25th percentile above the PT

-10

0

10

20

30

Maximum Penalties and Bonuses

2019 2020 2021 2022+

4

-4

5

-5

7

-7

9

-9

12

15

21

27

Budget

neutrality

adjustment

Scaling

factor up to

3x may be

applied to

upward

adjustment

to ensure

payout pool

equals

penalty pool Pa

ym

en

t a

dju

stm

ent

Payment Adjustment Determination

1

2

3

Highest performers

eligible for up to 10

additional incentive4

MIPS ECs1 assigned score of

0ndash100 based on performance

across four categories

Score compared to CMS-set

performance threshold2 (PT)

non-reporting groups given

lowest score

A score above PT results in

upward payment adjustment a

score below PT results in a

downward adjustment3

Year

Stronger Performers Benefit at Expense of Those with Low ScoresNo Data

Non-reporting

participants given

lowest score Basis for Performance Threshold

In 2019 PT based on 2014 and 2015

performance data from PQRS VBPM MU

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 10: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

10

Preferential Scoring for MIPS APMs

Potential Advantage to Achieve ldquoExceptional Performancerdquo Incentives

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive

under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9

2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Medicare Shared Savings Program

2) Accountable care organization

Comparison between MIPS Weighting

and Scoring for MIPS APMs in 2017

25 30 30

75 15

20 20

25

10

50 50 50

MIPS MSSP Next Gen Other APMs

Quality

Resource Use

Clinical Practice Improvement Activities (CPIA)

Advancing Care Information (ACI)

MIPS APM Scoring Standard

Extra pool of incentives for

MIPS ECs whose performance

exceptionally exceeds a

specified threshold

$500M

Reporting

bull Quality measures submitted through CMS Web

Interface by MSSP1Next Gen ACO2 on behalf of

MIPS participants Quality category is not reported

for other MIPS APMs

bull ACI CPIAmdashsubmit data per MIPS requirements

Scoring

bull Performance evaluated collectively at the APM

Entity level

bull Scoring Standard CPS stays at 100 with

readjusted weights for the remaining performance

categories

bull Automatic 30 points for CPIA Resource Use

is not scored

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 11: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

11

MIPS Performance Categories Executive Summary

Category Key Components ECrsquos Relative

Difficulty

bull Fewer measures to report than PQRS lots of

measures to choose from

bull No longer pay for reporting performance matters

bull Bonus points for electronic reporting

bull No separate reporting requirement based on claims

bull Many new cost measures assess which conditions

you treat not just whom you treat

bull Part D drug costs may be included in future years

bull Over 90 activities to choose from offers flexibility for

many provider types

bull Preferential scoring for PCMH1 and MIPS APM

participants

bull Applies to all clinicians2 unlike previous Medicare

Eligible Professional MU requirements (which only

applied to physicians)

bull No longer requires ldquoall-or-nothingrdquo measure threshold

reporting clinicians scored on participation and

performance

1) Patient-centered medical homes are recognized if they are accredited by the Accreditation Association for Ambulatory

Health Care (AAAHC) the National Committee for Quality Assurance (NCQA) PCMH recognition The Joint

Commission Designation or the Utilization Review Accreditation Commission (URAC)

2) Eligible clinicians include physicians physician assistants nurse practitioners clinical nurse specialists certified

registered nurse anesthetists and groups that include such clinicians In 2017 ACI category may be reweighted to zero

for non-physician clinicians

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-

Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

Score based

on peer

performance

benchmarks

Score based

on ECsrsquo own

performance

Quality

(Previously

PQRS)

Resource Use

(Previously VBPM

cost component)

Clinical Practice

Improvement

Activities

(New category)

Advancing Care

Information

(Previously MU)

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 12: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

12

MIPS Quality Performance Category

Significant Flexibility with Almost 300 Measures Generous Bonus Points

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for

Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

PQRS MIPS Quality

Qu

ali

ty

Measu

res

bull Report 9 measures

across 3 National Quality

Strategy Domains

bull Groups of 100+ EPs

reporting via GPRO1 are

required to also report all

Consumer Assessment of

Healthcare Providers amp

Systems (CAHPS) survey

measures

bull Report 6 measures2

including at least 1 outcome

measure and 1 cross-cutting3

measure

bull CAHPS measure is an

optional quality measure for

groups of 2 or more ECs

bull 3 additional population-based

measures4 based on claims

data

Data

S

ub

mis

sio

n

bull Use 1 of the allowed

reporting mechanisms

bull Use 1 of the allowed reporting

mechanisms (more details on

Slide 32)

bull MSSPNext Gen ACO entities

do not separately report

Data

C

om

ple

ten

ess

bull Varies by type of reporting

mechanism (eg 50 of

the EPrsquos Medicare Part B

fee-for-service patients for

individual claim-based and

qualified registry-based

reporting)

bull 90 of all applicable patients

regardless of payer if using

QCDR5 qualified registry or is

EHR-based

bull 80 for individual ECrsquos

applicable Medicare Part B

patients if using claims-based

Scoring

Special Considerations

Key Considerations for

Quality Public Comment

bull Should CMS provide more specialty-

specific measure sets

bull Should CMS decrease the data

completeness requirement

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement6 is met so the

total possible points can vary between ECs

bull Performance points assigned for a

measure based on benchmark decile range

created from the baseline year7

bull Non-patient-facing ECs do not need to

report cross-cutting measure

bull Generous bonus points8 awarded for

Reporting extra outcome or high-priority

measures9

End-to-end electronic reporting

1) Group practice reporting option

2) Exceptions for certain specialty measure sets ECs without 6 applicable measures andor without applicable outcome

measures and CMS Web Interface reporting

3) ldquoCross-cuttingrdquo measures are broadly available to all clinicians with patient-facing encounters regardless of specialty

4) Incudes all-cause hospital readmission acute conditions composite and chronic conditions composite

5) Qualified clinical data registry

6) Minimum 20 cases for all quality measures except 200 for all-cause hospital readmission for group reporting

7) Baseline year is 2 years before the performance year For example 2015 is the baseline for the 2017 performance year

8) Each type of bonus point is capped at 5 of total possible points

9) High-priority domains are appropriate use patient safety efficiency patient experience and care coordination

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 13: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

13

MIPS Resource Use Performance Category

New Cost Measures Performance Assessment Based on Claims

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

1) Diabetes mellitus

2) Chronic obstructive pulmonary disease

3) Coronary artery disease

4) Congestive heart failure

5) Tax Identification NumberNational Provider Identifier

VBPM MIPS Resource Use

Cost

Measures

6 measures

bull Total Per Capita

bull Medicare Spending Per

Beneficiary (MSPB)

bull Four Per Capita Costs for

beneficiaries with four

specific conditions (DM1

CPOD2 CAD3 CHF4)

Total number of measures

assessed depend on

applicable episode-based

measures

bull Total Per Capita

bull MSPB

bull New 41 clinical condition

and treatment episode-

based measures

Data

Submission

ECsgroups do not need to separately report data for this

category CMS uses the data submitted through

administrative claims to assess cost performance

Minimum

Case

Required

bull 20 cases for Total Per

Capita and 4 Per Capita

Costs with specific

conditions

bull 125 cases for MSPB

bull 20 cases for all measures

Attribution

Level of

Analysis

bull Cost measures are

evaluated at a TIN level

bull Individual reporting

TINNPI5 level

bull Group reporting TIN

level

Scoring

Special Considerations

bull Resource use reweighted to ldquo0rdquo for

ndash Non-patient-facing ECs

ndash MIPS APM preferential scoring standard

bull Measures are equally weighted for a

maximum of 10 points each

bull A measure is included in the scoring only if

minimum case requirement is met so the

total possible points can vary between ECs

bull Performance points assigned for a measure

based on benchmark decile range from the

performance year

Key Considerations for

Resource Use Public Comment

bull Should benchmarks be based on the

performance year or earlier baseline year

bull Should CMS include Medicare Part D drug

costs in measures for future years

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 14: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

14

MIPS CPIA Performance Category

Brand New Requirement More Than 90 Activities to Choose From

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR

28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research

and analysis

bull If reporting as a group how should CMS give

credit if one practice within the TIN is PCMH

while the other practices in the TIN are not

bull Are there other CPIA activities that could be

added to the proposed list

Reporting Requirements

Scoring

Two Measure Types

H

M

High-weighted activity 20 points

Medium-weighted activity 10 points

bull The activity must be performed for at least

90 days during the performance period

bull Yesno response for CPIA activities

included in the CPIA inventory

bull Maximum score of 60 points

bull Any combination of high-weighted or

medium-weighted activities Key Considerations for CPIA Public Comments

1) Health Professional Shortage Areas

Example Reported Activities Points

Earned

1 50

2 60

3 60

M H M M

M H M H

M H M H H

Special Considerations

Reporting Flexibility The following types of ECs

and groups may report any 2 activities to receive full

credit each activity is worth 30 points

bull Small groups (15 ECs or less)

bull Groups located in rural areas or HPSAs1

bull Non-patient-facing ECs

Scoring Flexibility Certain participants get

preferential scoring

bull MIPS APM Automatic 30 points

bull Certified PCMH Automatic 60 points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 15: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

15

MIPS ACI Performance Category

New Name for MU Rewards Participation and Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Health Care IT Advisor research and analysis

1) Certified EHR technology

2) Measures are equally weighted for a maximum of 10 points each Points

are awarded based on numeratordenominator performance rate eg

95 performance equals 95 points

3) Up to one bonus point total is awarded for reporting any public health

measure in addition to Immunization Registry

How Three Key Tenets of MU Change Under ACI

MU ACI Changes

Year 2017 2018+ 2017 2018+

Objectives

and

Measures

Modified Stage 2

OR

Stage 3 (optional)

Stage 3

ACI measures correlating to

Modified Stage 2 OR

ACI measures correlating to

Stage 3

ACI measures

correlating to Stage 3

Slight

changes a

few measures

easier

CEHRT 1

Allowed 2014 andor 2015

Edition

2015 Edition

only 2014 andor 2015 Edition 2015 Edition only No change

CQM

Reporting 9 measures No longer required as it is combined with

the quality category Aligned

Scoring

Type Possible Points

Base 50

Performance1 Modified Stage 2 60

Stage 3 80

Bonus2 1

Total Capped at 100

Special Considerations

bull Hospital-based advanced

practitioners non-patient-

facing and those qualifying for

hardship are not scored (ie ACI

category reweighted to zero)

bull First-time participants do not have

a shorter reporting period in ACI

unlike MU

bull New data submission

mechanisms allow for reporting

alignment

Key Considerations for

ACI Public Comment

bull How should CMS redefine a

ldquomeaningful userrdquo)mdash75 points

or 50 points Affects ifwhen

ACI category reweighted

within MIPS composite score

bull Is there a limitation on the

number of years hardship

exceptions could apply

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 16: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

16

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

MIPS ACI Pocket Guide Correlates to Stage 3 MU

Conduct or review a

security risk

analysis

Query for a drug formulary

-AND-

Electronically transmit

prescriptions (EPs)

Clinical decision support

interventions

-AND-

Drug-drug and drug-

allergy interaction

checking

Medication orders

Laboratory orders

Diagnostic imaging

orders

Protect Electronic

Health Information

Electronic

Prescribing

Clinical Decision

Support

Computerized Provider

Order Entry

Patient electronic

access1

through VDT and

application

programming

interface (API)

Actively engaged through any

combination of VDT andor

API actions

Provide outbound

electronic summary of

care Required

bull Immunization registry

Optional2

bull Syndromic surveillance

bull Electronic case reporting

bull Public health registry

bull Clinical data registry

Secure electronic

messaging

Incorporate inbound

electronic summary of

care

Provide electronic

access to patient

education

resources

Incorporate non-clinical

setting data (including

patient-generated data)

Perform clinical

information reconciliation

of patient data

Patient Electronic

Access

Patient

Engagement

Health Information

Exchange (HIE)

Public Health

Reporting

Note The red box indicates ACI measures included in the performance score The dark grey shading indicates the

objectivesmeasures CMS proposes to eliminate

1) All three functionalities (view download and transmit - VDT) and an API must be present and accessible to meet the measure

2) Providers can earn up to one bonus point if they report any of the optional public health measures

3

Performance Measures

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 17: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

17

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 18: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

18

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

The Most Important

Operational

Action Item

Succeed in MIPS

88 CMS estimate of

Medicare-eligible

clinicians under MIPS

track in 2019

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and

Alternative Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria

for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016

httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 19: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

19

Not Much Time to Prepare for 2017 Performance

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative

Payment Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused

Payment Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-

10032 Advisory Board research and analysis

MACRA Implementation Timeline

2017 2016

Providers may not be

certain which track

they will fall into when

reporting in 2017 Today

2018

Merit-Based Incentive

Payment System (MIPS)

Alternative Payment

Models (APM)

Final Rule

Released

Compressed Timeline Between Now and First Performance Period

bull CMS indicates they will release the Final Rule by November 1 2016

bull Not much time until January 2017 for many providers to get involved in Advanced APMs

or prepare for MIPS performance

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 20: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

20

Key Considerations for MIPS-Related Policies

Clinicians May Bring Payment Adjustment Baggage with Them

Source Advisory Board research and analysis

bull Clinician onboarding EC affiliation changes

pose challenges for example

ndash Payment adjustmentmdashpractices may ldquoinheritrdquo

an ECrsquos past MIPS performance score and

related payment adjustment

ndash Performance reportingmdashpractices must

onboard ECs quickly and incoming ECs may

require separate individual reporting

bull Group reporting How will CMS account for a

variety of ECs within the group Do all ECs report

the same measures and report every category

even those that qualify for special considerations

bull Performance feedback Will clinicians have

enough information in order to benchmark predict

performance and make course corrections for a

given performance year

bull Public reporting data Which measures should or

should not be made available on the Physician

Compare

2017 2018 2019

Payment Adjustment Two-Year

Look-Back Policy

Performance

period

Payment

adjustment year

Payment Adjustment Applied

at TINNPI Level

If no performance associated with the

TINNPI is available CMS will apply

performance from TIN(s) the NPI billed

under from the performance period

Key Considerations for

Public Comment

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 21: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

21

Key Considerations for APM-Related Policies

Potential APM Track Participants Donrsquot Be Caught in MIPS by Surprise

Source Advisory Board research and analysis

Performance period

for track determination

APM

incentive

payment

Track notification

APM incentive base

calculation period

APM Incentive Payment Timeline

bull Partial QP MIPS decision Will ECs have enough

information to determine whether or not to

participate in MIPS if later deemed Partial QPs

bull APM incentive calculation timing How will CMS

calculate the incentive if the APM contract ends

during the calculation base period

bull Definition of Advanced APM CMS seeks public

comment Advanced APM criteria Should CMS

revise the financial risk percentages or otherwise

allow for other payment models to qualify

bull Advanced APM CEHRT use The APM track

requires CEHRT use among the Advanced APMrsquos

participant entities Should the requirement be set

to 50 use CEHRT in the first year and 75 in

future years

bull MSSP MU requirements Currently MSSP

measures MU participation How will the

previously defined MU definition harmonize

with the new definition in MACRA

Key Considerations for

Public Comment

Track Assignment Notification

Occurs After Performance Period

Participants notified 6 months after

the performance period concludes

at the earliest APM Entities that are

not QPs or Partial QPs are subject

to MIPS payment adjustments

2017 2018 2019

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 22: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

22

Strategize Your Approach to MACRA

Source Advisory Board research and analysis

1 Nearly all providers are affected and thus should

take notice

2 There is no time to waste with decision making

(and we donrsquot even have the final word)

3 Provider groups should assume they are in the

MIPS track for the first year

4 Under the MIPS providers have a lot of flexibility in

selecting performance measures that align with

their practice

5 APM Scoring in MIPS has a significant upside

6 While it may speed up pace of adoption MACRA

alone is not a sufficient impetus to assume

payment risk

7 MACRA may accelerate physician consolidation

8 Moving forward MACRA is likely to have other

significant downstream effects on medical group

operations and how physicians practice

Eight Strategic Implications

Archived Webconferences on

Strategic Implications

bull MACRA Strategic Implications

for Provider Organizations from

the Proposed Rules

bull MACRA What You Need to

Know Right Now About the

Proposed Rule

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 23: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

23

Recognize How IT Is Critical to MIPSAPM Success

Time Has Come for IT and Quality Operational Partnership

Source Advisory Board research and analysis

Keep in Lock-Step with Health IT Vendors

Ask about vendorsrsquo MIPSAPM preparedness and how they plan to stay on

top of evolving requirements as part of their product roadmap

Align Reporting Methods

bull Reporting alignment helps reduce

reporting burden across MIPS

performance categories

Enable Analytics

bull Critical to monitor

performance and identify

improvement opportunities

bull Allows analysis of APM

participation risks and

benefits

Maximize Performance

bull Quality bonus points for end-to-

end electronic reporting

bull ACI focus on interoperability and

patient engagement

bull CPIA credit for telehealth HIE

Expect New IT Requirements

bull Advanced APM CEHRT use

requirement may evolve to

include participation in an HIE

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 24: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

24

2

3

1

Road Map

copy2016 Advisory Board bull All Rights Reserved bull 32913

Key Points from the Proposal

Greatest MACRA Challenges for Providers

Considerations for Health Care IT Vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 25: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

25

Considerations for Health Care IT Vendors

1 Understand MACRArsquos

impact

Assess implications for portfolio and

future customer needs 4 Serve as source for

MACRA information

Act as trusted information source for

customers 2 Configure reporting

functionality

Enable customers to calculate

performance if applicable 5

Submit public

comment

Voice opinions and suggestions by

June 27

3 Encourage aligned

submission methods

Port customer data using preferred

submission mechanisms 6 Utilize Advisory

Board resources

Tap into your existing Advisory Board

resources for further assistance

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 26: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

26

Understand MACRArsquos Impact

1) Understand MACRArsquos Impact

Source Advisory Board research and analysis

Assess

Portfolio Position

Assemble product

management and strategy

staff to assess how and if

MACRA impacts portfolio

position

Identify

Customer Needs Market

SolutionServices

Get your message to

existing and new

relevant audiences once

solutionservices are

developed

Seek out input on product

functions that will support

clientsrsquo transition to MACRA

and add to roadmap if

applicable

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 27: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

27

The Math Behind Qualifying Participant Thresholds

2) Configure reporting functionalitymdashAPM example

1) Medicare Part B-covered professional services

2) During the performance period

3) Evaluation and management

Payment threshold

for QPs in 2019

25

Numerator

Denominator

All payments for services1

furnished by ECs in the APM Entity

to attributed beneficiaries2

All payments for services1 furnished

by ECs in the APM Entity to

attribution-eligible beneficiaries2

Patient count threshold

for QPs in 2019

20

Numerator

Denominator

Unique number of attributed

beneficiaries to whom ECs in the

APM Entity furnish services12

Number of attribution-eligible

beneficiaries to whom ECs in the

APM Entity furnish services12

Not enrolled in Medicare

Advantage or Medicare

Cost Plan

Medicare not a

second payer

Medicare Parts A and B

enrollment

At least 18 years old

US Resident

At least 1 EampM3 claim

within the APM entity

Attribution-Eligible Beneficiary Criteria

1 2 3

4 5 6

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)

Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161 Federal

Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 28: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

28

Category Category Scoring Per Reported Measures Points Weight CPS

Quality Earned 482

Bonus 455

ECrsquos total

possible 70

50

3764

(52770)x50

Resource

Use Earned 252

ECrsquos total

possible 40

10 63

(25240)x10

CPIA Earned 60

CPIA total

cap 60

15 15

(6060)x15

ACI Earned 842

ACI total

cap 100

25 2105

(842100)x25

Complicated Calculations Even for a Simple Example

How Category Scores Convert to 2017 MIPS Score for a Fictional EC

2) Configure reporting functionalitymdashMIPS example

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment

Model (APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment

Modelsrdquo 81 FR 28161 Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory

Board research and analysis

1) Not scored below required case minimum

2) Not applicable to individual eligible clinicians

3) These measures are reported via CEHRT so the provider earns 1 bonus point per measure

4) The additional high-priority measure beyond the required outcome measure earns the provider 1 bonus point

5) Two types of bonus points in the quality category end-to-end electronic reporting and high-priority measures

Each category is capped at 5 of the total possible points

1 High Activity 4 Medium Activities

20 Pts 10 Pts 10 Pts 10 Pts 10 Pts

Total per Capita MSPB Up to 41 Episode-Based measures

56 Pts NA 85 Pts 63 Pts 48 Pts NA

Below Case

Threshold No Attributed

Cases

ECrsquos Total MIPS CPS8 7999

Reported 5 of 6 Measures 3 Population-Based Measures

86 Pts 73 Pts NA1 61 Pts NA2 10 Pts 62 Pts 10 Pts 0 Pts

Outcome

Measure3

Process

Measure3

Not

Reported

Process

Measure3

High

Priority34

Cross

Cutting3

Acute Composite

Chronic Composite

All-Cause Readmission

6) Patient Electronic Access

7) Medication Reconciliation

8) Composite Performance Score

50 Pts 91 Pts 36 Pts 76 Pts 15 Pts 97 Pts 27 Pts

Base Score Performance Score

Patient

Education

Secure

Message HIE

Patient

E-Access6 VDT Med

Rec7

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 29: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

29

ABCs of Submission Mechanisms in MIPS

3) Encourage aligned submission methods

Sources CMS QCDRs CMS EHR Reporting CMS Qualified

Registries CMS Web Interface Group Reporting Option CAHPS

Vendor Advisory Board research and analysis

Qualified Clinical

Data Registry

Meets specific CMS qualifications

but scope of registry is not limited to

PQRS measures

For more QCDRs available

EHR

Office of the National Coordinator-

certified EHR submits data

directly to CMS

For more certified EHRs available

CMS Web Interface

Group practice reporting option via

CMSrsquo QualityNet website

For more see QualityNet

Qualified Registry

Meets specific CMS qualifications

and scope of registry is limited to

PQRS measures

For more registries available

Attestation or

Claims

Attestation TBD CMS may utilize

existing MU attestation portal

Claims Coded data inputted

through claims

CAHPS Vendor

CMS-certified vendor used for

combined CAHPS and

PQRS reporting

For more see approved vendors

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 30: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

30

MIPS Reporting Alignment Options

Vendor Capability Crucial to Alignment Opportunity

3) Encourage aligned submission methods

Sources CMS ldquoMedicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model

(APM) Incentive under the Physician Fee Schedule and Criteria for Physician-Focused Payment Modelsrdquo 81 FR 28161

Federal Register May 9 2016 httpsfederalregistergova2016-10032 Advisory Board research and analysis

Note the dark outline box denotes submission methods that allow reporting alignment opportunity

1) Available for groups of 25 or more only

2) Available for individual reporting only

3) For groups only must be a CMS-approved survey vendor for MIPS

Submission

Methods QCDR EHR

Qualified

Registry

CMS Web

Interface1 Attestation Claims2 CAHPS

Vendor3

Quality

CPIA

ACI

MIPS Data Submission Mechanisms Report Individually or as a Group

bull Capability to report

measures for all MIPS

performance categories

bull Ongoing compliance with

CMS vendor audits

bull Record data in CEHRT

bull Export and transmit data

electronically

bull Option to use third party

intermediary with automated

software

Vendor

Readiness End-to-end

Electronic

Reporting

Reporting Alignment Quality Bonus Points

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 31: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

31

Make Your Voice Heard

Set Aside Resources to Review and Comment on Annual Changes

4) Submit public comment

Source Advisory Board research and analysis

bull Annual updates Health care IT vendors may be

challenged to react to annual updates to

requirements published each November

bull Compressed timeline Full-year 2017 performance

period fast approaching with little time for vendors to

prepare

bull Audit scope Uncertain which types of

documentation vendors must retain and for how long

(10 years)

bull Group reporting for practices with different

EHRs Group practices that do not share a common

EHR platform or vendor may be challenged to

aggregate consistent MIPS data across the TIN

Vendors may wish to offer CMS guidance for those

scenarios

bull Use of CEHRT for APMs CMS seeks comment on

new health IT standards and certification criteria for

future APM track CEHRT requirements

Key Considerations for

Vendorrsquos Public Comment November

CMS proposes to

publish annual

MIPSAPM Final Rule

January

Year-long performance

period starts 2 months after

requirements are finalized

JUN 27

Public comment closes

on June 27 2016 for the

MIPSAPM proposed rule

Annual MIPSAPM Updates

Leave Little Time to React

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 32: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

32

Three-Part MACRA Webconference Series

Immediate Strategic and Operational Insights for All Members

5) Serve as source for MACRA information

MACRA What You Need to

Know Right Now About the

Proposed Rule

Available On-Demand

bull Understand the basics of the

MIPS vs APM track

bull Learn the most important

(and surprising) things your

organization needs to know

right away

MACRA Strategic Implications

for Provider Organizations

Available On-Demand

bull Receive key advice on issues

such as maximizing pay-for-

performance navigating the

transition to risk-based

payment and the future of

hospital-physician alignment

bull Evaluate the economics of

physician payment transition

MACRA Operational Action

Items from the Proposed Rule

Available On-Demand

bull Receive detailed reporting

advice including how to

streamline Medicare

physician reporting

bull Assess key quality program

management implications

For More Advisory Board Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 33: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

33

Utilize Advisory Board Resources

Consult with experts about

product strategy andor for

orientation on MACRA and

its related regulations

Send a question to confirm

understanding of regulatory

requirements obtain references

for both internal and external use

Request presentation for

customers by Advisory

Board experts education can

make messaging consistent

Access educational resources

for internal staff and strategic

development Cheat Sheet

series very popular

Stay informed of new

regulatory and legislative

implications for your product(s)

with subscription alerts

Contact Your Dedicated Advisor for Assistance

Source Advisory Board research and analysis

6) Utilize Advisory Board resources

Cheat Sheet Series

See Health Care Industry Committee Cheat Sheets

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 34: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

34

Key Takeaways for Health Care IT Vendors

MACRA Has Significant

Impact

The law fundamentally

changes how Medicare pays

physicians and other clinicians

Most Providers Will Be in

MIPS

CMS estimates that at least

88 of Medicare providers

nationwide will fall under MIPS

track in 2017

Opportunities Exist to Support

Providers with Your

ServicesSolutions

Health IT systems are critical to

MACRA success providers have

yet to establish clear strategy

Plan for Final Rule and

Annual Rulemaking

Health care IT vendors should

prepare to revisit MACRA

plans in November plan for

yearly updates via rulemaking

MACRA Reflects Broader ldquoSea Changerdquo in Move from Volume to Value

Source Advisory Board research and analysis

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 35: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

35

MACRA Resources to Support You

Webconferences Tools Research

bull Three-part on-demand

series

ndash What You Need to Know

Right Now About the

Proposed Rule

ndash Strategic Implications for

Provider Organizations

from the Proposed Rule

ndash Operational Action Items

from the Proposed Rule

bull The Implications for Health

Care IT Vendors

bull How to Align Quality

Reporting Across PQRS

MU and VBPM on-

demand

bull Proposed MIPS

Measures List

bull Your questions about the

MACRA proposed rulendash

answered

bull Health Care IT Advisor

MACRA Cheat Sheet

bull MACRA Cheat Sheet for

Industry

bull Medicares new plan for

paying doctors 10 key

takeaways

bull Meaningful Use gets a

facelift under MACRAmdashbut

is it better Heres our view

bull 2016 Eligible Professional

Quality Reporting CMS

Offers More Flexible

Reporting Options But Itrsquos

Time to Align

For These and Forthcoming Resources on MACRA

httpswwwadvisorycomtopicsstrategymarket-trendsmacra

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 36: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

36

Ask a Question

To ask a question please type it into the

ldquoQuestionsrdquo box on your GoTo panel and

press send

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU

Page 37: MACRA: The Implications for Health Care IT Vendors...•Extra $500M for exceptional performers under MIPS; APM bonuses range from $146M to $429M Fall 2016 CMS expects to release final

copy2016 Advisory Board bull All Rights Reserved bull advisorycom bull 32913

37

Provide Your Feedback on Todayrsquos Presentation

Please note that the survey does not apply to webconferences viewed on demand

bull Once you or the presenter exits the

webconference you will be directed

to an evaluation that will automatically

load in your web browser

bull Please take a minute to provide your

thoughts on the presentation

THANK YOU