Assess, Plan, and Be Flexible for MIPS

Judi Payne, BSM

The shift in healthcare from fee-for-service to value-based reimbursement took a giant leap on January 1, 2017, when the Quality Payment Program (QPP) officially started. Under the QPP, Medicare providers have 2 tracks from which to choose: the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model. Most providers, including community oncologists, are expected to fall under MIPS for the 2017 performance year.

Choosing the correct MIPS measures for a practice can be complicated (Figure). For instance, the Quality category contains more than 270 measures that practices must narrow down to just 6. A new category, Improvement Activities, has more than 90 measures to choose from and practices must select 2 to 4. The last category, Advancing Care Information (ACI), is the rebranded Meaningful Use (MU) program. While providers already have a certain degree of familiarity with these measures, the scoring has become complicated.

Figure: Practices Must Choose Value Measures for 2017

Quality Measures

Quality measures examine how well a provider performs certain tasks. Many of the measures that can be specialty-specific are similar to those in the Physician Quality Reporting System and Clinical Quality Measures from the MU program. In past years, performance thresholds were not observed, but in the new program, providers are graded on how well they perform compared with their peers. They can either receive a penalty or a positive payment adjustment based on their performance.

Selection of Quality measures depends on which are supported by the practice’s electronic health record (EHR). For example, McKesson’s iKnowMed EHR supports 16 measures. Providers need to select 6 measures that best match their practice’s services and capabilities.

Working from the list of supported measures, providers should assess their current performance and determine where they are doing well and where they need improvement. Providers should choose a variety of measures where performance is excellent, specialty-specific, or may be in need of minor adjustment

Providers must also select at least 1 outcome measure, but selecting more than 1 will earn bonus points. Examples of outcome measures commonly used in oncology are Proportion of Patients in Hospice and Controlling High Blood Pressure. The selection of outcome measures should be based on current performance, priority, and specialty.

Improvement Activities

Lastly, providers should ascertain which submission methods are supported by their EHR. Data can be submitted by claims, direct EHR, registry, or attestation. All measures within the Quality category must be submitted using the same method.Improvement Activities are the actions the practice takes to accomplish and perform well on Quality and ACI measures. By selecting Improvement Activities that may cross into other MIPS categories, requirements for the entire MIPS program can be met efficiently. An example of this is Manage Medications: it is an Improvement Activity, and it can cross over to a Quality measure, Documentation of Current Medications, and to an ACI measure, Medication Reconciliation.

Practices should review the list of Improvement Activities and select measures based on their current processes and participation in improvement efforts. For example, if the practice conducts patient surveys or has a quality improvement committee, there are several Improvement Activities that, conveniently, relate to patient surveys and quality improvement, respectively. Practices using iKnowMed, as well as some other EHR systems, will have the option to participate in a Qualified Clinical Data Registry (QCDR) to meet their public health registry measure.

Some activities have multiple bullet points, but only 1 of the bullets from the list needs to be met to fulfill the requirement. The unfulfilled items provide insight into how the practice can further enhance processes or services in the future.

Practices should select at least 1 activity, from several options, that indicates a certified EHR was used. Choosing at least 1 adds an additional 10 points to the ACI score while providing some cross-coverage on scoring.

Avoid certain types of measures. Stay away from those with thresholds, as it is often difficult to prove the requirement was met. Also, avoid measures that do not pertain to the practice. For example, the activities specific to Rural Health Clinics, Indian Health Service, and Federally Qualified Health Centers should be avoided unless the practice serves many patients who would be in those categories.

Advancing Care Information

ACI is the new MU category, and for 2017, most of the measures are very similar to the old MU. Although the new program does not have performance thresholds, providers should continue to perform at the previously set thresholds because this will allow them to earn the maximum number of points for ACI without much difficulty.

For providers who have struggled with portions of MU, such as the health information exchange or patient portal measures like electronic access or secure messaging, the new program provides the opportunity to focus on other measures while improving upon those with which they had difficulty in the past. These providers should now concentrate on such measures as patient education or medication reconciliation to raise their performance results as high as possible. Since CMS will most likely conduct an audit to verify that activities were performed, practices should carefully document their activities. Proofs of performance can include Standard Operating Procedures, policies in place, proof of qualified clinical data registry participation, quality improvement committee meeting minutes, or similar documentation.

Assess, Plan, and Be Flexible

Providers can achieve success with MIPS through careful analysis, planning, and flexibility. By thoroughly assessing the measures in all categories, they can determine which are best for their practice. A plan should be developed that will serve as a roadmap to meet the requirements.

Although it is important to have a plan, it is equally important to be flexible while executing it. Practices should remain flexible throughout 2017, adjusting workflows and processes and even replacing measures if necessary. Providers need to realize that MIPS is a journey with many twists and turns in the road.

Selecting the right measures can mean the difference between success and failure within the program, and substantial revenue is at stake. With careful analysis and planning, community oncology practices can choose measures that are a good fit and hold the most opportunity for revenue enhancement. Here are a few points to consider when selecting MIPS measures.