- Email: [email protected]
There is still time to avoid the 4% CMS payment penalty
UNDER THE MACRASCOPE There is still time to avoid the 4% CMS payment penalty Patrick Ryan, MD,a Brad Johnson, MD,b Jill Rathbun, MHSA,c and Karen Woo, MD, MS,d Nashville, Tenn; Tampa, Fla; Chicago, Ill; and Los Angeles, Calif
Under the Medicare Access and CHIP Reauthorization Act (MACRA), providers who receive payment from Medicare must participate in either the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (APM) in 2017 in order to avoid a 4% payment penalty in 2019. As there are currently no vascular APMs available, the majority of vascular providers will participate in MIPS in 2017. MIPS is a scoring system comprised of four components: Quality (60%); Clinical Practice Improvement Activity (CPIA, 15%); Advancing Care Information (ACI, 25%dpreviously known as Meaningful Use); and Cost.1 In 2017, cost will not be included in the score, but feedback will be given. This year is a transition year with three options for providers to “Pick Your Own Pace”: (1) Full participation- report six quality measures, four medium-weighted or two high-weighted CPIA and all of the five required ACI measures for the entire 2017 calendar year to be eligible for the maximum positive payment adjustment based on performance. (2) Partial participation-submit 90 days of the data required for full participation anytime between January 1 and October 2, 2017 to be eligible for a positive payment adjustment. (3) Test participation- submit a minimum amount of data for 90 days, defined as one quality measure, one CPIA or all five of the required ACI measures to avoid the 4% 2019 payment penalty. Participation in a clinical registry, particularly a qualified clinical data registry (QCDR), can satisfy requirements for Quality and CPIA.2 Even if a provider is not currently participating in a QCDR, there are a variety of reporting strategies that will allow providers to avoid the 4% penalty in 2019. Anyone who uses a certified electronic health record (EHR) can satisfy the five measures
From the Nashville Vascular and Vein Institute, Nashvillea; the Department of Surgery, Division of Vascular Surgery, University of South Florida, Tampab;
required for the ACI base score: protecting patient health information, electronic prescribing, patient electronic access, send a summary of care and request/accept summary of care. Submission of these five ACI measures alone would fulfill test participation. There are a number of Quality measures and CPIA that can be reported through claims, the CMS Web Interface and/or EHR. The full list of measures is available on the Quality Payment Program website.3 The following highlights measures that vascular providers are likely already doing or can easily accomplish. For Quality, measures that can be reported outside of a registry include: (1) Diabetic foot exam; (2) documentation of current medications in the EHR; (3) body mass index screening and follow up plan; (4) tobacco use screening and cessation intervention; and (5) pain assessment and follow-up plan. For CPIA, measures that do not require registry participation include: (1) Seeing new and follow-up Medicaid patients in a timely manner; (2) engagement of patients, family, and caregivers in developing a plan of care and prioritizing their goals for action, documented in the EHR; (3) use of evidence-based decision aids to support shared decision making; and (4) use of EHR to capture patient-reported outcomes. For providers participating in an Intersocietal Accreditation Commission (IAC) accredited vascular lab and/or vein center, the IAC Quality Improvement SelfAssessment Tool satisfies the “Implementation of formal quality improvement methods, practice changes or other practice improvement processes” CPIA. Also, the IAC Quality Improvement Maintenance of Certification (MOC) activity satisfies the “Participation in MOC Part IV” CPIA. It is not too late for providers to satisfy 2017 MIPS requirements. Test participation with minimal reporting will allow providers to avoid the 4% payment penalty in 2019.
the Society for Vascular Surgery Quality and Performance Measures Committee, Chicagoc; and the Department of Surgery, Division of Vascular Surgery, David Geffen School of Medicine at UCLA, Los Angeles.d Author conflict of interest: none. Correspondence: Karen Woo, MD, MS, Department of Surgery, Division of Vascular Surgery, David Geffen School of Medicine at UCLA, 200 UCLA Medical Plaza Ste 526, Los Angeles, CA 90095 (e-mail: [email protected]). The editors and reviewers of this article have no relevant financial relationships to disclose per the Journal policy that requires reviewers to decline review of any manuscript for which they may have a conflict of interest. J Vasc Surg: Venous and Lym Dis 2017;5:606 2213-333X Published by Elsevier Inc. on behalf of the Society for Vascular Surgery. http://dx.doi.org/10.1016/j.jvsv.2017.04.002
606
REFERENCES 1. Duwayri Y, Johnson B, Rathbun J, Woo K. The vascular surgeon’s roadmap to success in the Quality Payment Program. J Vasc Surg 2017;65:1536. 2. Mansour A, Johnson B, Rathbun J, Woo K. Utilizing registries to meet Medicare reimbursement requirements. J Vasc Surg: Venous and Lym Dis 2017;5:468. 3. Centers for Medicare and Medicaid Services. Quality Payment Program. Available at: https://qpp.cms.gov/. Accessed March 16, 2017.
Under the Medicare Access and CHIP Reauthorization Act (MACRA), providers who receive payment from Medicare must participate in either the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (APM) in 2017 in order to avoid a 4% payment penalty in 2019. As there are currently no vascular APMs available, the majority of vascular providers will participate in MIPS in 2017. MIPS is a scoring system comprised of four components: Quality (60%); Clinical Practice Improvement Activity (CPIA, 15%); Advancing Care Information (ACI, 25%dpreviously known as Meaningful Use); and Cost.1 In 2017, cost will not be included in the score, but feedback will be given. This year is a transition year with three options for providers to “Pick Your Own Pace”: (1) Full participation- report six quality measures, four medium-weighted or two high-weighted CPIA and all of the five required ACI measures for the entire 2017 calendar year to be eligible for the maximum positive payment adjustment based on performance. (2) Partial participation-submit 90 days of the data required for full participation anytime between January 1 and October 2, 2017 to be eligible for a positive payment adjustment. (3) Test participation- submit a minimum amount of data for 90 days, defined as one quality measure, one CPIA or all five of the required ACI measures to avoid the 4% 2019 payment penalty. Participation in a clinical registry, particularly a qualified clinical data registry (QCDR), can satisfy requirements for Quality and CPIA.2 Even if a provider is not currently participating in a QCDR, there are a variety of reporting strategies that will allow providers to avoid the 4% penalty in 2019. Anyone who uses a certified electronic health record (EHR) can satisfy the five measures
From the Nashville Vascular and Vein Institute, Nashvillea; the Department of Surgery, Division of Vascular Surgery, University of South Florida, Tampab;
required for the ACI base score: protecting patient health information, electronic prescribing, patient electronic access, send a summary of care and request/accept summary of care. Submission of these five ACI measures alone would fulfill test participation. There are a number of Quality measures and CPIA that can be reported through claims, the CMS Web Interface and/or EHR. The full list of measures is available on the Quality Payment Program website.3 The following highlights measures that vascular providers are likely already doing or can easily accomplish. For Quality, measures that can be reported outside of a registry include: (1) Diabetic foot exam; (2) documentation of current medications in the EHR; (3) body mass index screening and follow up plan; (4) tobacco use screening and cessation intervention; and (5) pain assessment and follow-up plan. For CPIA, measures that do not require registry participation include: (1) Seeing new and follow-up Medicaid patients in a timely manner; (2) engagement of patients, family, and caregivers in developing a plan of care and prioritizing their goals for action, documented in the EHR; (3) use of evidence-based decision aids to support shared decision making; and (4) use of EHR to capture patient-reported outcomes. For providers participating in an Intersocietal Accreditation Commission (IAC) accredited vascular lab and/or vein center, the IAC Quality Improvement SelfAssessment Tool satisfies the “Implementation of formal quality improvement methods, practice changes or other practice improvement processes” CPIA. Also, the IAC Quality Improvement Maintenance of Certification (MOC) activity satisfies the “Participation in MOC Part IV” CPIA. It is not too late for providers to satisfy 2017 MIPS requirements. Test participation with minimal reporting will allow providers to avoid the 4% payment penalty in 2019.
the Society for Vascular Surgery Quality and Performance Measures Committee, Chicagoc; and the Department of Surgery, Division of Vascular Surgery, David Geffen School of Medicine at UCLA, Los Angeles.d Author conflict of interest: none. Correspondence: Karen Woo, MD, MS, Department of Surgery, Division of Vascular Surgery, David Geffen School of Medicine at UCLA, 200 UCLA Medical Plaza Ste 526, Los Angeles, CA 90095 (e-mail: [email protected]). The editors and reviewers of this article have no relevant financial relationships to disclose per the Journal policy that requires reviewers to decline review of any manuscript for which they may have a conflict of interest. J Vasc Surg: Venous and Lym Dis 2017;5:606 2213-333X Published by Elsevier Inc. on behalf of the Society for Vascular Surgery. http://dx.doi.org/10.1016/j.jvsv.2017.04.002
606
REFERENCES 1. Duwayri Y, Johnson B, Rathbun J, Woo K. The vascular surgeon’s roadmap to success in the Quality Payment Program. J Vasc Surg 2017;65:1536. 2. Mansour A, Johnson B, Rathbun J, Woo K. Utilizing registries to meet Medicare reimbursement requirements. J Vasc Surg: Venous and Lym Dis 2017;5:468. 3. Centers for Medicare and Medicaid Services. Quality Payment Program. Available at: https://qpp.cms.gov/. Accessed March 16, 2017.