Overview of Proposals for PQRS & VBM

Overview of Proposals for PQRS & VBM

Making Sense of MACRAs Alphabet Soup: What does it mean for Internal Medicine? How Can ACP Help? September 2016 Shari M. Erickson, MPH Vice President, Governmental Affairs & Medical Practice April 2015 Congress Passed Landmark, Bipartisan Law MACRA Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) focused on Part B Medicare Congressional Intent of MACRA: Sustainable Growth Rate repeal Improve care for Medicare beneficiaries Change our physician payment system from one focused on volume to one focused on value MACRA is now being recast as the Quality Payment Program - NPRM April 27, 2016 2

Quality Payment Program In a Nutshell Law intended to align physician payment with value The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Or now the Quality Payment Program Merit-Based Incentive Payment System (MIPS) Advanced Alternative Payment Models (APMs) 3 Merit-based Incentive Payment System (MIPS) 4 This new MIPS report card will replace current Medicare reporting programs

There are currently multiple individual quality and value programs for Medicare physicians and practitioners: Physician Quality Reporting Program (PQRS) Value-Based Payment Modifier (quality and cost of care) Meaningful use of EHRs MACRA streamlines those programs into MIPS: Merit-Based Incentive Payment System (MIPS) Source: www.lansummit.org/wp-content/uploads/2015/09/4G-00Total.pdf 5 How will Clinicians Be Scored Under MIPS? A single MIPS composite performance score will factor in performance in 4 weighted performance categories: Year 1:

Quality 50% Clinical practice Advancing Care improvement activities Information 25% 15% Cost 10% MIPS Composite Performance Score Source: www.lansummit.org/wp-content/uploads/2015/09/4G-00Total.pdf

6 MIPS Proposed Rule: Quality Performance Category Selection of 6 measures 1 cross-cutting measure and 1 outcome measure, or another high priority measure if outcome is unavailable Select from individual measures or a specialty measure set Population measures automatically calculated Key Changes from Current Program (PQRS): Reduced from 9 measures to 6 measures with no domain requirement Emphasis on outcome measurement Year 1 Weight: 50% 7 What is ACP saying about measures? In the short term, ACP encourages CMS to consider adopting a core set of measures identified through the Americas Health Insurance Plans (AHIP) coalition. Over the longer term, CMS must continue to improve the measures and reporting systems to be used in MIPS to ensure that they:

measure the right things move toward clinical outcomes and patient experience do not create unintended adverse consequences, such as treating to the measure, increasing healthcare disparities, e.g. avoiding sicker and less compliant patients 8 What is ACP saying about measures? Fill critical gaps in quality measurement Obtain stakeholder input into the measure development process Focus on outcomes-based measures, patient and family experience measures, care coordination measures, and measures of population health and prevention over time Critically important to minimize the burden related to data collection and reporting in the quality category (as with all of the MIPS categories) Ensure that performance measurement and reporting becomes increasingly patient-focused 9 ACP Recommendations* re: MIPS Quality Performance Category CMS must: Take concrete actions to provide clear options for specialties that

may be most impacted by too few appropriate measures; Remove the mandate for clinicians to report on at least 1 outcome measure (but give them bonus points if they do); Remove the 3 population health measures (and provide optional points for these as well); Make CAHPS for MIPS reporting voluntary; Improve risk adjustment methodology (including incorporating SES); Keep data completeness at 50%; and Hold physicians harmless from reporting on topped-out measures. *Selected recommendations included here, complete list with detailed information can be found at: 10 https://www.acponline.org/acp_policy/letters/comment_letter_macra_proposed_ rule_2016.pdf CMS Final Measure Development Plan - Released on May 2, 2016 Initial Priorities for Measure Development:

Clinical Care Incorporating patient preference and shared decision-making Cross-cutting Focused for specialities with clear gaps Medication safety Use of new technologies Patient and Caregiver Experience

Safety Diagnostic accuracy Team-based care Outcomes Care Coordination

PROMs and additional topics Population Health and Prevention Outcomes at population level IOM Vital Signs topics Detection and prevention of chronic disease Affordable Care overuse measures https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Asses sment-Instruments/Value-Based-Programs/MACRA-MIPS-and-AP 11 Ms/Final-MDP.pdf From Meaningful Use to Advancing Care

Information What is final? Stage 2 modifications for 2015-2016 2015 Certification Required for 2018, optional for 2017. So, what about Stage 3? The MACRA NPRM proposes to replace MU with Advancing Care Information (ACI). 2017 MU (renamed ACI) is proposed to be the first reporting period for MIPS. 2015 Edition certified EHR technology is required to report on all primary performance measures. Alternative measures are available for those without a full 2015 Edition. **New Proposal from CMS would shorten 2016 MU reporting to any continuous 90-day period** 12 PROPOSED RULE 13 MIPS: Advancing Care Information Performance Category The overall Advancing Care Information

score would be made up of a base score and a performance score for a maximum score of 100 points 13 PROPOSED RULE MIPS: Advancing Care Information Performance Category CMS proposes six objectives and their measures that would require reporting for the base score: 14 14 ACP Recommendations* re: MIPS ACI Category CMS must: Simplify the reporting requirements and scoring! ACP proposed a specific alternative scoring approach:

Removing all yes-required or threshold requirements except for the protecting patient health information attestation Selecting from a longer list of health IT activities Focus on applying health IT to improve quality and value and not simply the use of the technology; Change the reporting period to 90-days; Reduce burden including providing physicians with up-front estimates of the cost and time involved in submitting their attestations. Not hold physicians accountable for information blocking factors that are beyond their control; and

*Selected recommendations included here, complete list with detailed information can be found at: 15 https://www.acponline.org/acp_policy/letters/comment_letter_macra_proposed_ rule_2016.pdf Clinical Practice Improvement Activities (CPIA) Minimum selection of one CPIA activity (from 90+ proposed activities) with additional credit for more activities - High-weighted = 20 points; Medium-weighted = 10 points max score of 100 points Lower bar for small, rural, and/or HPSA area practices Full credit for patient-centered medical home & PCMH specialty practices (as defined in the rule) Minimum of half credit for other APM participation Key Changes from Current Program: Not applicable (new category) Year 1 Weight: 15% 16 ACP Recommendations* re: MIPS Clinical Practice

Improvement Activities Category CMS must: Weight all activities the same at 5 points per activity Full scoring would be accomplished by attesting to 3 activities OR being a PCMH, PCMH Specialty Practice, or other APM); Include the following on the list of activities: ACP Practice Advisor ACPs High-Value Care resources Certain defined CME activities (i.e., that involve QI-related work) Establish a clear and transparent process for adding new items; and Permit practicing clinicians to submit alternative activities for credit and/or consideration for future credit. *Selected recommendations included here, complete list with detailed information can be found at: 17 https://www.acponline.org/acp_policy/letters/comment_letter_macra_proposed_ rule_2016.pdf

Patient-Centered Medical Homes (PCMHs) & PCMH Specialty Practices in CPIA CMS definitions for full CPIA credit: PCMH 1. 2. 3. Nationally accredited PCMH; Medicaid Medical Home Model; or Medical Home Model. PCMH Specialty Practice Nationally accredited ACP Recommends: Broaden their definitions include other programs with a demonstrated track record of support by non-Medicare payers, state Medicaid programs, employers, and/or others 18 Cost (aka Resource Use) Assessment under all available resource use measures, as applicable to the clinician

CMS calculates based on claims so there are no reporting requirements for clinicians Key Changes from Current Program (Value Modifier): Adding 40+ episode specific measures to address specialty concerns Year 1 Weight: 10% ACP Recommendation CMS Must: Adjust resource use to zero for the first performance year the measures are not yet proven to be reliable and validated in their application to physicians. 19 How Much Can MIPS Adjust Payments? Based on the MIPS composite performance score, physicians and practitioners will receive positive, negative, or neutral adjustments up to the percentages below. MIPS adjustments are budget neutral. 4% 5% 7%

9% Adjustment to providers base rate of Medicare Part B payment MAXIMUM Adjustments Those who score in top 25% are eligible for an additional annual performance adjustment of up to 10%, 2019-24 (NOT budget neutral) -4% -5% -7% -9%

2019 2020 2021 2022 onward Merit-Based Incentive Payment System (MIPS) 20 PROPOSED RULE MIPS Performance Period 21 2 MIPS Performance 2017 2018 Period (Begins 2017) Performan ce Period

All MIPS performance categories are aligned to a performance period of one full calendar year. Goes into effect in first year (2017 performance period, 2019 payment year). 2019 Payme nt Year 2020 2021 2022 2023

2024 2025 ACP Recommended that CMS must: Start the initial performance period July 1, 2017 (rather than January 1, 2017) Initial reporting period for quality would remain 12 months, but CPIA and ACI would be any continuous 90-day period 21 ACPs Recommended Scoring Approach Total points for Quality = #/60 Not #/80 x 50% as proposed Total points for Resource Use = 0 Not an average of applicable measures x 10% Total points for CPIA = #/15 Not #/60 x 15% Total points for ACI = #/25 Not #/100 (which could actually be up to 131 points) x 25%

22 Advanced Alternative Payment Models (APMs) 23 Advanced Alternative Payment Models (APMs) Initial definitions from MACRA law, APMs include: CMS Innovation Center model (under section 1115A, other than a Health Care Innovation Award) MSSP (Medicare Shared Savings Program) Demonstration under the Health Care Quality Demonstration Program Demonstration required by Federal Law As defined by MACRA, advanced APMs must meet the following criteria: The APM requires participants to use

certified EHR technology. The APM bases payment on quality measures comparable to those in the MIPS quality performance category. The APM either: (1) requires APM Entities to bear more than nominal financial risk for monetary losses; OR (2) is a Medical Home Model expanded under CMMI authority. 24 PROPOSED RULE Advanced APM Criterion 1: Requires use of CEHRT Certifie d EHR useAdvanced APM Example: An

An Advanced APM must require at least 50% of the eligible clinicians in each APM Entity to use CEHRT to document and communicate clinical care. The threshold will increase to 75% after the first year. For the Shared Savings Program only, the APM may apply a penalty or reward to APM entities based on the degree of CEHRT use among its eligible clinicians. has a provision in its participation agreement that at least 50% of an APM Entitys eligible clinicians must

use CEHRT. APM Entit y Eligible Clinicia Source: CMS webinar slides, ns 25 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instrument s/Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-M PROPOSED RULE Advanced APM Criterion 2: Requires MIPS-Comparable Quality Measures Qualit y Measur es

An Advanced APM must base payment on quality measures comparable to those under the proposed annual list of MIPS quality performance measures; No minimum number of measures or domain requirements, except that an Advanced APM must have at least one outcome measure unless there is not an appropriate outcome measure available under MIPS. Comparable means any actual MIPS measures or other measures that are evidence-based, reliable, and valid. For example: Quality measures that are endorsed by a consensus-based entity; or Quality measures submitted in response to the MIPS Call for Quality Measures; or

Any other quality measures that CMS determines to have an evidence- based focus to be reliable and valid. Source: CMS webinar slides, https:// 26 www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-BasedPrograms/MACRA-MIPS-and-APMs/Quality-Payment-Program-MACRA-NPRM-Slides.pdf PROPOSED RULE Advanced APM Criterion 3: Requires APM Entities to Bear More than Nominal Financial Risk An Advanced APM must meet two standards: Financi al Risk Financial Risk

Standard APM Entities must bear risk for monetary losses. & Nominal Amount Standard The risk APM Entities bear must be of a The Advanced APM financial risk criterion is completelycertain met if magnitude. the APM is a Medical Home Model that is expanded under CMS Innovation Center Authority Medical Home Models that have not been expanded will have

different financial risk and nominal amount standards than those for other APMs. Source: CMS webinar slides, 27 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments /Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-MA PROPOSED RULE Medical Home Models A Medical Home Model is an APM that has the following features: Participants include primary care practices or multispecialty practices that include primary care physicians and practitioners and offer primary care services. Empanelment of each patient to a primary clinician; and At least fourcoordination of the following: Planned of chronic and

preventive care. Patient access and continuity of care. Risk-stratified care management. Coordination of care across the medical neighborhood. Patient and caregiver engagement. Shared decision-making. Source: CMS webinar slides, Payment arrangements in 28 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Val addition to, or substituting ue-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-MACRA-NP Medical Home Models: Have a unique financial risk criterion for becoming an Advanced APM. Enable participants (who are not excluded from MIPS) to receive the maximum score in the MIPS CPIA category.

Important Information to Note about APMs and Advanced APMs MACRA does not change how any particular APM rewards value. Only some APMs will be considered advanced APMs Within an advanced APM, a clinician must meet payment or patient requirements to be a qualified participant APM participants who are not Qualified Participants will receive favorable scoring under MIPS. Over time, more advanced APM options will become available. 29 How does MACRA Provide Additional Rewards for Participation in Advanced APMs? Most clinicians who participate in APMs will be subject to MIPS and will receive favorable scoring under the MIPS clinical practice improvement activities performance category. Those who participate in the most Advanced APMs may be determined to be qualifying APM participants (QPs).

As a result, QPs: 1. Are not subject to MIPS 2. Receive 5% lump sum bonus payments for years 2019-2024 3. Receive a higher fee schedule update for 2026 and onward APM participants Advanced APMs QPs 30 PROPOSED RULE APM Incentive Payment Be excluded from MIPS QPs will: Receive a 5% lump sum bonus

Bonus applies in payment years 20192024; then QPs receive higher fee schedule updates starting in 2026 The APM Incentive Payment will be based on the estimated aggregate payments for professional services furnished the year prior to the payment year. E.g., the 2019 APM Incentive Payment will be based on 2018 services. Source: CMS webinar slides, 31 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ValueBased-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-MACRA-NPRM-Sl Proposed Rule Advanced APMs Based on the proposed criteria, which current APMs will be Advanced APMs in 2017? Shared Savings Program (Tracks 2 and 3) Next Generation ACO Model Comprehensive ESRD Care (CEC) (large dialysis

organization arrangement) Comprehensive Primary Care Plus (CPC+) Oncology Care Model (OCM) (two-sided risk track available in 2018) Source: CMS webinar slides, https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instrum3232 ents/Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Prog MACRA provides additional rewards for participating in APMs. Potential financial rewards Not in APM MIPS adjustments In APM In Advanced APM MIPS adjustments

APM-specific rewards APM participation = favorable scoring in certain MIPS categories Source: CMS webinar slides, 33 https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments /Value-Based-Programs/MACRA-MIPS-and-APMs/Quality-Payment-Program-MA The Quality Payment Program provides additional rewards for participating in APMs. Potential financial rewards Not in APM MIPS adjustments In

APM In Advanced APM MIPS adjustments + APM-specific rewards If you are a APM-specific rewards + 5% lump sum bonus Qualifying APM Participant 34

Source: CMS webinar slides, (QP) https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/M Independent PFPM Technical Advisory Committee PFPM = Physician-Focused Payment Model Goal to encourage new APM options for Medicare clinicians Submission of model proposals by Stakeholders Technica l Advisory Committe e

11 appointed care delivery experts that review proposals, submit recommendations to HHS Secretary Secretary comments on CMS website, CMS considers testing proposed models For more information on the PTAC, go to: https://aspe.hhs.gov/ptac- physician-focused-payment-model -technical-advisory-committee 35 PROPOSED RULE Physician-focused Payment Model (PFPM) Proposed definition: An Alternative Payment Model wherein Medicare is a payer, which includes physician group practices (PGPs) or individual

physicians as APM Entities and targets the quality and costs of physician services. Proposed criteria fall under 3 categorie s Payment incentives for higher-value care Care delivery improvements Information availability and enhancements Any PFPM that is selected for testing by CMS and meets the criteria for an Advanced APM would be an Advanced APM. 36 ACP Recommendations re: PCMHs as Advanced APMs: CMS should allow PCMH to qualify as advanced APMs without financial risk, if it meets the criteria laid out in the

law CMS should allow multiple pathways for PCMHs: 1. Expedited analysis if Comprehensive Primary Care Initiative and advance planning to expand CPCI 2. Deeming Process for PCMH programs run by states (e.g., Medicaid programs), non-Medicare payers, and employers 3. Inclusion of PCMH programs and practices that meet the Medical Home Model Standard for financial risk and nominal amount (beyond CPC+) 37 ACP Recommendations re: Advanced APMs Give priority via PTAC for CMMI testing of models involving specialty/subspecialty categories where there are current NO recognized APMs and advanced APM options available. Reduce the nominal risk amount for advanced APM models Create a platform to expedite testing for APM recognition of bundled payment and similar episodes of care models. MSSP/Medicare ACOs Track One MSSP ACOs should qualify; also consider adding a new track within MSSP to help bridge the transition 38

Recent MACRA Advocacy from ACP Letter to HHS on MACRA Patient Relationship Categories and Codes (8/15/2016): https://www.acponline.org/acp_policy/letters/cms_rfi_patient_relationship_codes_ 2016.pdf ACP Testimony to Senate Finance Committee on MACRA (7/13/16): https://www.acponline.org/acp_policy/testimony/statement_record_finance_macra _2016.pdf MACRA Proposed Rule Response (6/27/2016): https://www.acponline.org/acp_policy/letters/comment_letter_macra_proposed_ru le_2016.pdf Letter to ONC on Interoperability in MACRA (6/2/2016): https://www.acponline.org/acp_policy/letters/acp_comments_onc_interoperability_ macra_2016.pdf

MACRA RFI Response (11/17/16): www.acponline.org/acp_policy/letters/acp_comment_letter_macra_rfi_2015.pdf 39 Recent MACRA Advocacy from ACP (cont.) Meaningful Use Stage 3 Comments: www.acponline.org/acp_policy/letters/acp_mu_stage_3_comments_2015.p df (Dec. 14, 2015) healthaffairs.org/blog/2016/01/14/its-time-to-fix-meaningful-use/ (Jan. 14, 2016)

RFI re: EHR Certification and Reporting of Electronic Clinical Quality Measures (1/27/16):www.acponline.org/acp_policy /letters/acp_comments_cms_certification_frequency_rfi_2016.pdf CMS Care Episode and Patient Condition Groups (3/1/16): www.acponline.org/acp_policy/letters/acp_episode_grouper_letter_2016.pdf CMS Measure Development Plan (3/1/16): www.acponline.org/acp_policy/letters/comments_cms_draft_quality_measures _development_plan_2016.pdf 40 Things You Can Do This Year to Prepare 41 ACP Resources for MACRA and Value-Based Payment Overall

42 Coming soon 43 Specific Support for IM Subspecialists Ongoing workgroup/advisory panel of IM subspecialists members to help ACP develop our strategy for supporting our subspecialty members Setting up an online special interest group discussion board for IM subspecialists regarding MACRA and APM development What else? 44 Contact Information e-mail: [email protected] webpage: acponline.org/macra ACP can help you navigate upcoming payment changes 45

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