Five Best Practices to Meet MACRA/MIPS Requirements

Kim Hathaway, MSN, CPHRM, Healthcare Quality and Risk Consultant

Practices that have not yet developed their Medicare Access and CHIP Reauthorization Act (MACRA) plans face greater urgency to initiate their plans in 2018. According to the MIPS Scoring 101 Guide for the 2017 Performance Period, 2017 was a “transition year.” In 2017, a practice that earned a mere three points (by submitting just one quality measure on one patient) could avoid a penalty; scoring over the three-point threshold brought the possibility of a 4 percent payment increase. In 2018 the threshold to avoid a penalty increases to 15 points, and reaching >70 points hits the exceptional performance threshold. Also, in 2018, the payment adjustment up or down increases to 5 percent. Given these changes, practices that gained experience with MIPS reporting in 2017 may still feel overwhelmed. Regardless of the experience level, the following steps can help guide practices to succeed:

  1. Review past performance in quality measures such as the Physician Quality Reporting System (PQRS) or specialty measures that your practice has reported. These are strong indicators of how your practice will score in the future. Align activities and quality measures with what you are already doing in your practice and determine how to make capturing the needed data part of your team’s workflow. Educate and engage the entire workforce about what you are trying to accomplish and why. Ask for input from the frontline of your practice about the most efficient ways to collect the necessary data elements. Even if you participated in PQRS in the past, there are differences that will require a team effort to be successful. Don’t try to do it alone. Consider making quality measurement part of the annual review for employees.
  2. Study the specifications for each measure you are reporting to better understand its value. For claims or registry reporting, go to the Quality Payment Program website and choose the appropriate file. If you are reporting through your electronic health record (EHR), the vendor may be very helpful in choosing your measures. However, not all EHRs will report all measures, and there are some that collect data but don’t report to the Centers for Medicare and Medicaid Services (CMS). Clarify with the EHR vendor when and how the documentation is captured and counted toward the measure. The same applies to the various registries. Be sure to do your homework and know about pricing and any requirements related to system compatibility.
  3. Monitor your data on a weekly or biweekly basis. Compare the reports that you run in your office to those generated by your EHR or registry. Investigate any discrepancy so that it can be corrected now by coaching the team on documentation or timeliness of reporting. Don’t wait until the end of the reporting period to look at your performance data. There may not be time or the ability to correct it later.
  4. Understand that the scoring process for the quality measures is very different than it was in PQRS. Under PQRS, if you reported the measure enough times, you received credit. And if you reported on one patient, you would get a pass. Simple participation was often all that was required. Under the quality measure scoring process in MIPS, your performance rate will determine your score.

    Under the PQRS scoring process the performance rate didn’t matter, just that you participated (example is based on 100 patients):
    • Provider 1: 95 patients performance met, 5 patients performance not met = PASS.
    • Provider 2: 5 patients performance met, 95 patients performance not met = PASS.
  5. Under the quality measure scoring process, your performance rate will determine your score (based on 100 patients):
    • Provider 1: 95 patients performance met, 5 patients performance not met = 95 percent Performance Rate.
    • Provider 2: 5 patients performance met, 95 patients performance not met = 5 percent Performance Rate.
  6. In addition to the change in the scoring process from simply participating to a performance rate, the scores will be determined based on national benchmarks, with the highest performing deciles receiving a greater point value. It is important that you look at the benchmarks since some require a performance rate of 100 percent to score well in that metric.
  1. Review the Quality and Resource Use Report (QRUR) to fully understand how your practice performs in terms of quality and cost. Use the 2016 QRUR (published fall 2017) to identify potential weaknesses and address them, since cost returns as a scored category in 2018—cost will carry a weight of 10 percent toward the MIPS composite score.

    The QRUR is a complex report that requires familiarity to truly understand its content. The biannual report outlines the quality and cost data from PQRS and compares it to a national benchmark. Costs are determined by claims data. While there were no reporting requirements for the cost category in 2017, CMS will provide feedback on cost for the 2017 performance period in the fall of 2018. It was not counted in the final composite score for 2017, but starting in January 2018, it becomes 10 percent of the 2018 MIPS composite score. See the Cost Performance Category Fact Sheet for more information on the cost measure.

    Groups and solo practitioners may access their QRUR through the CMS Enterprise Portal. The person who accesses this report for the group will need to create a login at CMS’s Enterprise Identity Management (EIDM) system. This is a very secure site. It contains questions to verify and confirm the identity of the person registering, as well as information about specific providers in the group. Security is very strict around these reports, because they include patient health information so that groups may identify which patients may be attributed to them. For help interpreting your QRUR, consult the CMS website regarding QRUR analysis and payment. You will find additional resources, links to the EIDM System, and what to do if you believe your QRUR is not accurate on the CMS website.

The guidelines suggested here are not rules, do not constitute legal advice, and do not ensure a successful outcome. The ultimate decision regarding the appropriateness of any treatment must be made by each healthcare provider considering the circumstances of the individual situation and in accordance with the laws of the jurisdiction in which the care is rendered.

06/18

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