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Important Changes to Quality Reporting for 2017

Important Changes to Quality Reporting for 2017

Did you know that at the end of 2016, the Physician Quality Reporting System (PQRS) ended and was replaced by CMS' new Quality Payment Program (QPP)? This means that 2016 was the final year in which providers, including audiologists, will be eligible to participate in the PQRS program. The year 2017 marks the first performance year for CMS' new QPP, with payment adjustments being distributed in 2019. In the first two years of MIPS, the only providers considered eligible professionals to participate in the program are the following: physicians, physician assistants, certified registered nurse anesthetists, nurse practitioners, clinical nurse specialists, and groups that include such professionals. Audiologists are ineligible to formally participate in the new QPP during the first two years of the program (2017 and 2018); however, there are opportunities for voluntary reporting.

What do audiologists need to know about the end of PQRS and the transition to MIPS/APMs?

It is important to note that audiologists are ineligible to participate in MIPS for at least the first two years (2017, 2018). The Secretary of the US Department of Health and Human Services (HHS) has the authority to include other professionals, including audiologists, beginning in 2019. This means that audiologists will not be required to report on anything in 2017, but will have the option to voluntarily report on measures through MIPS.

What are the options for participation in the QPP?

There are two pathways for participation in the QPP. The first is through the Merit-based Incentive Payment System (MIPS) and the second is through Advanced Alternative Payment Models (APMs). MIPS streamlines existing CMS quality programs including PQRS, the Value Modifier Program (VM) and the Medicare Electronic Health Record (EHR) Incentive Program. Under MIPS, payment adjustments will now be calculated across four categories: Quality, Clinical Practice Improvement Activities, Advancing Care Information, and Resource Use. An APM is a payment approach that gives added incentive payments to providers who demonstrate high-quality and cost-efficient care. CMS anticipates that most providers will participate in the QPP via MIPs in the initial years of the program, hence the Academy's focus on this pathway.

Why should I report voluntarily when audiologists are technically not required to participate in these programs until 2019?

Voluntary reporting is exactly that- voluntary. Reporting is not required; however, because reporting will be similar to what you are reporting under PQRS, you may consider continuing to report. This will allow you to become familiar with the new program without being subject to penalties. CMS has also pledged to offer feedback reports to voluntary reporters allowing providers to track their progress and become familiar with this new system. Voluntary reporting may also allow you to keep up to date with the new program as it evolves.

We fully expect that CMS will issue further guidance about voluntary reporting throughout 2017.   We encourage you to maintain the momentum and practice reporting under this new system.   Again, there will be no penalty adjustment for participating on a voluntary basis. If you do experience any difficulty or denials that you think are related to your voluntary participation in MIPS, please immediately contact your Medicare contractor and e-mail the Academy.

What can I voluntarily report on under MIPS?

There are four performance categories under MIPS: Quality, Improvement Activities, Advancing Care Information and Cost/Resource Use.

Audiologists are unable to report on measures in or be assessed in the Advancing Care Information or Cost Categories: The Cost category will be calculated for eligible clinicians (not audiologists) in 2017, but it will not be used to determine a payment adjustment. The Advancing Care Information category replaces the Medicare EHR Incentive Program also known as Meaningful Use. Audiologists were excluded from the Meaningful Use program; therefore, do not current have applicable measures to (voluntarily) report under MIPS. This means that audiologists will not be able to report, even voluntarily in these two categories, leaving the Quality and Clinical Improvement Activities categories available for practice reporting. Note: audiologists may still not have applicable measures in these categories by 2019. CMS has determined that they will reweight other categories to determine composite scores in these situations.

Quality and Improvement Activities: Audiologists will be able to voluntarily report in these two categories. Quality reporting will maintain similar, if not the same, measures and process as PQRS reporting. Clinical Improvement Activities is a new category in which most providers select up to 4 improvement activities for a minimum of 90 days. Groups with 15 or fewer participants or those in rural or health professional shortage areas only need to demonstrate that you completed up to 2 activities for a minimum of 90 days. Many of these measures involve beneficiary engagement and improving the experience of and communication with patients.

How do I report under MIPS?

Quality Reporting: Under MIPS, eligible clinicians are directed to report up to 6 quality measures, including an outcome measure, for a minimum of 90 days. A list of all measures can be viewed here. For audiologists reporting voluntarily, all six measures that audiologists were eligible to report on via PQRS, are currently available for reporting under MIPS.

Clinical Improvement Activities Reporting: For most participants under MIPS, providers must attest that they have completed up to 4 improvement activities for a minimum of 90 days. These requirements are different for groups with fewer than 15 participants or if you are in a rural or health professional shortage area. In these cases, providers only need to attest that they have completed up to 2 activities for a minimum of 90 days. A full list of clinical practice improvement activities are listed here and available in a searchable format. To report via "attestation" means to report via a secure mechanism, specified by CMS and submit the required data for clinical practice improvement activities performance category. See Table 1 for a sample of CPIAs that may apply to audiology

Did I need to be ready to start reporting on January 1, 2017?

The performance period for the first year of MIPS began on January 1, 2017; however, CMS has indicated that they intend to allow providers to "pick their pace" in terms of participation during this first performance period. In 2017, eligible physicians and other clinicians will have multiple options for participation to ensure they do not receive a negative payment adjustment in 2019. Again, audiologists are not eligible for full participation in 2017 but may engage in practice reporting. Audiologists will not receive a payment adjustment (negative or positive) for the 2017 performance period.

Below are three options for participation in 2017. As you will see, providers may choose to begin on January 1 or may opt to adopt a more flexible performance timeline.

  1. First Option: Test the Quality Payment Program: If providers submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity at any point in 2017), they will avoid a negative payment adjustment. This first option is designed to ensure that providers' systems are working and that people are prepared for broader participation in 2018 and 2019. This option provides a learning opportunity to adjust to the new system.
  2. Second Option: Participate for part of the calendar year: Providers may choose to submit MIPS information for 90 consecutive days. This means that the first performance period could begin later than January 1, 2017, and practices could still qualify for a small positive payment adjustment.
  3. Third Option: Participate for the full calendar year: For practices that are ready to go on January 1, 2017, they may choose to submit QPP information for a full calendar year. This means the first performance period would begin on January 1, 2017. Providers reporting for a full year would likely receive a higher positive payment adjustment.

Resources:

CMS Blog

Quality Payment Program Web Site

Table 1: Sample Clinical Practice Improvement Activities

Subcategory

Activity

Weighting

Expanded Practice Access

Provide 24/7 access to MIPS eligible clinicians, groups, or care teams for advice about urgent and emergent care (e.g., eligible clinician and care team access to medical record, cross-coverage with access to medical record, or protocol-driven nurse line with access to medical record) that could include one or more of the following:

  • Expanded hours in evenings and weekends with access to the patient medical record (e.g., coordinate with small practices to provide alternate hour office visits and urgent care);
  • Use of alternatives to increase access to care team by MIPS eligible clinicians and groups, such as evisits, phone visits, group visits, home visits and alternate locations (e.g., senior centers and assisted living centers); and/or
  • Provision of same-day or next-day access to a consistent MIPS eligible clinician, group or care team when needed for urgent care or transition management.

High

Expanded Practice Access

Use of telehealth services and analysis of data for quality improvement, such as participation in remote specialty care consults, or teleaudiology pilots that assess ability to still deliver quality care to patients.

Medium

Expanded Practice Access

Collection of patient experience and satisfaction data on access to care and development of an improvement plan, such as outlining steps for improving communications with patients to help to understand urgent access needs.

Medium

Population Management

Take steps to improve healthcare disparities, such as Population Health Toolkit or other resources identified by CMS, the Learning and Action Network, Quality Innovation Network, or National Coordinating Center.

Refer to the local Quality Improvement Organization (QIO) for additional steps to take for improving the health status of communities as there are many steps to select from for satisfying this activity. QIOs work under the direction of CMS to assist eligible clinicians and groups with quality improvement, and review quality concerns for the protection of beneficiaries and the Medicare Trust Fund.

Medium

Care Coordination

Timely communication of test results defined as timely identification of abnormal test results with timely follow-up.

Medium