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where we cover interesting and relevant news, insights, events, and more related to the health care industry and pMD. Most importantly, this blog is a fun, engaging way to learn about developments in an ever-changing field that is heavily influenced by technology.


What do you think of when you hear the word "cybersecurity"? If you’re anything like me, then this word can lead to a feeling of anxiety as headlines from the recent Equifax breach or the WannaCry attack flash across your mind. While cybersecurity can be an intimidating endeavor, take comfort in knowing that there are some straight forward steps that can be taken in order to strengthen cybersecurity in any industry. Before tackling preventative measures, however, we need to discuss what cybersecurity encompasses and its connection to health care.

What is cybersecurity?


Cybersecurity is "the body of technologies, processes, and practices designed to protect networks, computers, and data from attack, damage, and unauthorized access". This may seem like a lengthy definition, but it does cover all the aspects of cybersecurity and, more importantly, it highlights that cybersecurity is NOT just technology. Often, cybersecurity processes are more important than the technology itself in fending off malicious attackers.

Why is cybersecurity important in health care?


According to KPMG’s Cyber Healthcare & Life Sciences survey, 47% of health care providers reported instances of HIPAA violations or cyber attacks this year, rising 10% from the 2015 report. This number is only compounded by the increasing prevalence of connected devices, or the “Internet of Things,” which has contributed to the growth of new exploits that take advantage of lower security thresholds on these seemingly limited devices.

HIPAA’s Security Rule addresses some of the concerns that stem from having extremely valuable personal health information open to potential attacks by providing “a framework for managing risk.” The rule basically covers administrative safeguards, which includes performing risk analysis, designating security credentials, and training employees. This rule also details physical safeguards, which includes everything from locks on doors, to password protected workstations, to actual security guards. And finally, technical safeguards are also discussed, which is the part that you would more likely think of when you hear the word “cybersecurity” and includes things like access control and transmission security. While this framework gives broad suggestions on how to avoid potential security breaches, it doesn’t dive deep into specific suggestions, which begs the question:

What can we do to ensure our patients' health information is safe?


1. Stay up to date on industry trends and cybersecurity threats

One great resource to remain up to date is the HIMSS Cross-Sector Cyber Security reports. These reports are released frequently and include updates on attacks and vulnerabilities across health care and other industries.

2. Update systems regularly

A core lesson from the WannaCry attacks: updating software systems regularly and utilizing cloud-based systems (like pMD!) when possible to avoid running outdated versions of software can help ensure that known vulnerabilities are not left exposed.

3. Be wary of potentially harmful links

Spam email remains one of the top ways malware spreads throughout networks. Being vigilant of the links you click on and where you enter sensitive data is an easy way to avoid falling victim to phishing attacks.

4. Plan your response

If you do experience an attack, a response plan can help prevent exacerbating the situation through mismanagement. Coordinated response efforts are key to minimizing the impact of any attack and the plan should include addressing the root of the problem, not just the effects.

From employee training, to processes for handling sensitive patient data and reacting in the event of a violation, to technical specifications, one thing is clear: cybersecurity is a team effort.

If you have any questions about today’s blog post or would like to find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

More Resources:
http://nvlpubs.nist.gov/nistpubs/ir/2013/NIST.IR.7298r2.pdf
http://www.healthcareitnews.com/news/healthcare-organizations-are-underestimating-cybersecurity-risks

 

 

Image: Alden Chadwick/Getty Images

Here's The Latest in Health Care:


•  The Veterans Coordinated Access and Rewarding Experiences Act, or CARE act, would make it easier to share patient records between the VA and outside providers. The proposal hopes to continue to improve the veteran experience by building a high-performance network and address health IT problems.  Read More

•  On Wednesday, the F.D.A. approved the second gene-altering treatment that reboots a patient's own immune cells to kill cancer. The approval, however, is not without controversy. The side effects can be life-threatening and in some cases fatal. The treatment is currently available only at centers where doctors and nurses have been trained in providing this specific treatment.  Read More

•  At this year's Medical Group Management Association (MGMA) conference, two experts presented their advice on benchmarking. Benchmarking can help physician practices compare themselves to their competitors, evaluate their performance, and identify areas of strengths and weaknesses.  Read More

•  People with diabetes struggle with a lifelong challenge to maintain their blood sugar levels. However, new emerging diabetes technology may ease that blood testing process, some even avoiding the dreaded finger prick.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

pMD, a certified MIPS registry, makes understanding MIPS Improvement Activities scoring as easy as possible in Part 3 of the 4-Part series, MIPS Scoring, Simplified. In Part 1 of this series, we discussed the Basics of MIPS Scoring, and in Part 2, we discussed scoring for the Quality category. Today, we’ll discuss scoring for the Improvement Activities category. Then, in the series finale, Part 4, we’ll cover Advancing Care Information scoring, plus an overview of the MIPS payment adjustment calculation. So, without further ado, let’s talk Improvement Activities.

The Basics of Scoring the Improvement Activities Category



Improvement Activities scoring is, thankfully, much more straightforward than scoring for either Quality or Advancing Care Information. However, Improvement Activities is a completely new category, and unchartered territory can be confusing in and of itself. But, fear not, because when we boil Improvement Activities down to its essence, it’s a pass/fail category. So, as long as you are familiar with how the category applies to your particular situation, you should pass with flying colors.

Special Group Attributes: Small Group, Rural Practice, HPSA, Non-Patient Facing



The maximum number of points available under Improvement Activities is 40. To earn the full 40 points, the first thing you’ll need to determine is how many improvement activities you or your group needs to submit to earn the full points. The number of activities you need to submit is determined by whether or not your group qualifies for special scoring. Four attributes result in special scoring for Improvement Activities:

1) small practice;
2) practicing in a health professional shortage area (HPSA);
3) practicing in a rural area; or
4) qualify as non-patient facing clinicians.

If any of these four attributes apply to you or your group, then your Improvement Activities category will be scored differently than groups that do not have one of these attributes. For special attribute groups only, each medium-weighted improvement activity is worth 20 points, and each high-weighted improvement activity is worth 40 points. That means, to earn the full 40 points, special attribute groups only have to submit:

* 1 high-weighted improvement activity
or
* 2 medium-weighted improvement activities

To confirm whether one of these attributes applies to your group, head to the QPP website. Enter your NPI at this page, and a chart like this will appear:

You can see in the chart that this provider is considered a small group, but does not practice in a HPSA nor in a rural area, nor are they a non-patient facing provider. Note that all four of these attributes are the same for both the individual clinician (as listed under “For this clinician at this practice”) and the group practice (as listed under “For this practice”). This should always be the case - if they’re not, it’s worth a call to figure out why, since it’s possible CMS’s records are amiss. But, if any of these four attributes - small practice, rural, non-patient facing, or HPSA - says “yes”, then you can submit less improvement activities than larger practices, as discussed above.

Standard Groups



If none of these four special attributes apply to you, your chart on the NPI look up page will look similar to this:

Note that the four attributes relevant to Improvement Activities - non-patient facing, small practice, rural, and HPSA - all say “No.” This means you and your group qualify for standard Improvement Activities scoring, so each medium-weighted Improvement Activity is worth 10 points, and each high-weighted Improvement Activity is worth 20 points. Based on that, if you want to earn the full 40 points for this category, you have to submit:

* 2 high-weighted improvement activities
or
* 4 medium-weighted improvement activities
or
* 1 high-weighted improvement activity AND 2 medium-weighted improvement activities

Reporting Improvement Activities



At the end of the performance period, you’ll attest to successful performance of your chosen improvement activities, for at least 90 days. So, using your submission mechanism, you’ll attest by indicating “Yes, I completed this improvement activity” or “No, I did not complete this improvement activity.” If you chose the correct number of improvement activities, and you positively attest to completing each activity, you’ll receive the full credit for the Improvement Activities category.

There are just a few more things to keep in mind about this category. First, you can’t earn bonus points for the Improvement Activities category. So, even if you submit more than your required activities, you’ll only receive 40 points. Second, everything outlined above applies to clinicians that are not participating in APMs. If you participate in some form of APM, then the rules for Improvement Activities are different for you. Third, many groups fret about what completing one of these activities actually means. Unfortunately, CMS is not giving a lot of guidance on this, and they don’t intend to give more. As far as I can find, there are only two decent sources of information to explain what each improvement activity requires. The QPP website’s improvement activities page, found here, and the “MIPS Data Validation Criteria” zip, which is available in the QPP Resource Library, found here. One helpful rule of thumb is to think about what documentation you or your group would point to if CMS ever audited your Improvement Activity attestation. If you feel confident that you have enough documentation to fully prove that you completed the specified activity, then you are in good shape.

Ok! See? I told you Improvement Activities scoring is easier! Now, stay tuned for Part 4, where we’ll discuss how the Advancing Care Information section is scored and how the final payment adjustment is determined. And as always, if you have any questions or would like to find out more about our MIPS registry, give us a call! To find out more about pMD's suite of products, which includes charge capture, secure messaging, and care coordination software and services, please contact pMD.

References:

Improvement Activities is a completely new category: “Improvement Activities: In this new performance category for 2017, clinicians are rewarded for care focused on care coordination, beneficiary engagement, and patient safety.” See https://qpp.cms.gov/mips/improvement-activities.

The maximum number of points available under Improvement Activities is 40: “To get the maximum score of 40 points for the Improvement Activity score…” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also “To achieve the maximum score of 40 points for the Improvement Activity score…” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3758. (“[W]e are only requiring a total of 40 points to receive the highest score for the improvement activities performance category.”)

Four attributions indicate your group qualifies for special scoring, (1) if you are a small practice; (2) if you practice in a health professional shortage area (HPSA); (3) practice in a rural area; or (4) non patient facing clinicians: “For these clinicians [small groups, non-patient facing, rural area, or HPSA], each medium-weighted activity is worth 20 points of the total Improvement Activity performance category score, and a high-weighted activity is worth 40 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

For special attribute groups only, each medium weighted improvement activity is worth 20 points, and each high weighted improvement activity is worth 40 points: “For these clinicians [small groups, non-patient facing, rural area, or HPSA], each medium-weighted activity is worth 20 points of the total Improvement Activity performance category score, and a high-weighted activity is worth 40 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

Standard Improvement Activities scoring means each medium weighted improvement activity is worth 10 points, and each high weighted improvement activity is worth 20 points: “Each medium-weighted activity is worth 10 points of the total Improvement Activity performance category score, and each high-weighted activity is worth 20 points of the total category score.” See MIPS Improvement Activities Fact Sheet pdf, pg. 3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

For standard scoring, if you want to earn the full 40 points for this category, you have to submit 2 high weighted improvement activities, or 4 medium weighted improvement activities, or 1 high weighted improvement activity AND 2 medium weighted improvement activities: “Groups with more than 15 clinicians: Each activity is weighted either medium or high. To get the maximum score of 40 points for the Improvement Activity score, you may select any of these combinations: 2 high-weighted activities; 1 high-weighted activity and 2 medium-weighted activities; Up to 4 medium-weighted activities.” See MIPS Improvement Activities Fact Sheet pdf, pg. 2-3, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

To receive full credit, you must report successful performance of your chosen improvement activities for 90 days: “You must attest by indicating ‘Yes’ to each activity that meets the 90-day requirement (activities that you performed for at least 90 consecutive days during the current performance period).” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf; see also 81 FR 77186, https://www.federalregister.gov/d/2016-25240/p-2387, (“we are finalizing at § 414.1360 that MIPS eligible clinicians or groups must perform improvement activities for at least 90 consecutive days during the performance period for improvement activities performance category credit.”)

So, using your submission mechanism, you’ll attest to completing your chosen improvement activities: “Eligible clinicians may submit their improvement activities by attestation via the CMS Quality Payment Program website, a qualified clinical data registry, a qualified registry, or, when possible, from their electronic health record system. Groups of 25 or more may choose to use the CMS Web Interface.” See MIPS Improvement Activities Fact Sheet pdf, pg. 2, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

You will receive the full points available for each improvement activity that you positively attest to completing: “In alignment with the reduction in total points required, we are finalizing that the following scoring that will apply to MIPS eligible clinicians who are a non-patient facing clinician, a small practice, a practice located in a rural area, or practice in a geographic HPSA or any combination thereof: *Reporting of one medium-weighted activity would result in 20 points or one-half of the highest score. *Reporting of two medium-weighted activities would result in 40 points or the highest score. *Reporting of one high-weighted activity would result in 40 points or the highest score. In alignment with the reduction in total points required, we are finalizing the following scoring that will apply to MIPS eligible clinicians who are not a non-patient facing clinician, a small practice, a practice located in a rural area, or a practice in a geographic HPSA: *Reporting of one medium-weighted activity would result in 10 points which is one-fourth of the highest score. *Reporting of two medium-weighted activities would result in 20 points which is one-half of the highest score. *Reporting of three medium-weighted activities would result in 30 points which is three-fourths of the highest score. *Reporting of four medium-weighted activities would result in 40 points which is the highest score. *Reporting of one high-weighted activity would result in 20 points which is one-half of the highest score. *Reporting of two high-weighted activities would result in 40 points which is the highest score. *Reporting of a combination of medium-weighted and high-weighted activities where the total number of points achieved are calculated based on the number of activities selected and the weighting assigned to that activity (number of medium-weighted activities selected × 10 points + number of high-weighted activities selected × 20 points). See 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3758.

No bonus points are awarded in the Improvement Activities category: “The most any MIPS eligible clinician or group can achieve for the improvement activities performance category is 40 points, so if more activities are selected than, for example, 4 medium-weighted activities, the total points that could be achieved is still 40 points.” See 81 FR 77318, https://www.federalregister.gov/d/2016-25240/p-3770.

Participants in APMs have different Improvement Activity scoring than is outlined above: See MIPS Improvement Activities Fact Sheet pdf, pg. 3-4, available at https://qpp.cms.gov/docs/QPP_2017_Improvement_Activities_Fact_Sheet.pdf.

Unfortunately, CMS is not giving a lot of guidance on this, and they don’t intend to give more: “We are not planning to issue any more specific language around the activities for the transition. We kept it simple, and for the reason that we're just doing a simple adaptation. We aren't requiring any specific data to be submitted. So, for the transition year, what you find on the QPP website for the improvement-activities description is all that we're issuing at this point for the transition year.” See Webinar Transcript, held on 12/13/16, “Merit-Based Incentive Payment System (MIPS) Overview: Understanding Advancing Care Information (ACI) & Improvement Activities,” available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-transcript.pdf

Participants should consider the documentation they have that support the chosen improvement activities, in case of audit: “So, for improvement activities, we're not exactly requiring documentation, but what we are telling providers is that you should retain copies of medical records, charts, reports, and any electronic data utilized, to determine which measures and activities were applicable and appropriate for their scope of practice, and patient population for reporting under MIPS for up to 10 years after the conclusion of the performance period, to prepare For verification in the event that you're selected for an audit. This record-retention timeframe aligns with the record-retention timeframes already in place for the APMs, either established in regulation or included in participation agreements. CMS may request any records or data retained for the purposes of MIPS for up to six years and three months. And we will provide audit specifications through subreg. guidance. And MIPS-eligible clinicians or groups selected for data validation audits will be provided instructions and examples of documents required.” See Webinar Transcript, held on 12/13/16, “Merit-Based Incentive Payment System (MIPS) Overview: Understanding Advancing Care Information (ACI) & Improvement Activities,” available at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MIPS-ACI-and-IA-transcript.pdf

Image: Ben Edwards/The Image Bank, via Getty Images

Here's The Latest in Health Care:


•  Researchers at the American Cancer Society predict there will be a quarter-million new cases of breast cancer in the U.S. in 2017. Women living in the U.S. have a one in eight chance of being diagnosed with breast cancer over their lifetime. However, death rates from breast cancer have declined 39 percent from 1989 through 2015, largely as a result of early diagnosis and advanced treatments.  Read More

•  While tech companies are working hard to help target the opioid crisis, tech can also be seen as a separator. For example, the lack of interoperability and the challenge in changing antiquated provider workflows can stand in the way of opioid prescription management.  Read More

•  It has been a devastating week of wildfires in California's wine country region. The effects of the fires have also extended into the surrounding Bay Area, creating a layer of air pollution that has not been this unhealthy since 1999 and can be compared to high pollution days in China. Officials recommend minimizing outdoor activities and even leaving the region until air quality improves.  Read More

•  On Thursday, the President signed an executive order that aims to revamp health insurance markets in the U.S. While the order itself does not implement any policies, it does seek to direct federal agencies to draft regulations.  However, health care experts and insurers have been vocal about the potential impact and consequences the executive order may bring.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

Image:  Healthcare IT News

Here's The Latest in Health Care:


•  On Monday, Health Affairs published research indicating that less than 30% of health system EHRs are fully interoperable, and fewer than 20% of them actually use the data transferred from another provider. Hospitals are urged to demand better interoperability, especially when it comes to discussions about bundled payments.  Read More

•  Bisphenol A, or BPA, is prevalent in many household plastic products, such as food storage containers and water bottles as well as the inside lining of many metal cans, which prevents the leaching of aluminum taste into food or drink. Manufacturers are not required to disclose the use of BPA in their products. Consumption of BPA may be cause for health concerns down the line, so take precautions and do your research!  Read More

•  Internet of Things medical devices are prime targets for cybercriminals. It is imperative for health care systems to take these 5 steps to prevent hackers from gaining access to health information. First, security systems should segment their networks. Second, health care execs should think beyond just network security and consider building security into applications. Third, hospitals must implement authorization protocols. Fourth, health care CIOs should always assess risk and improvement. And lastly, organizations should always monitor device behavior.  Read More

•  A gene therapy milestone had been reached for the first time as doctors were able to hold off a fatal degenerative brain disease, predominantly diagnosed in young boys, with the use of a disabled form of HIV.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

pMD’s Care Coordination solution is empowering oncology practices to navigate new performance-based, episodic payment models for cancer care.  

In 2017, the Centers for Medicare and Medicaid Services (CMS) launched a new payment and care delivery model for the treatment of cancer patients.  The Oncology Care Model (OCM) was created to improve care quality while lowering cost by incentivizing practice redesign towards oncology care coordination. Applications were submitted to CMS, which ultimately selected nearly 200 U.S. physician practices to participate in the OCM.  The model also included 14 payers, meaning that Medicare will not be the only payer participating.  Inclusion of other payers supports the main goal of the OCM, as stated by CMS, to incentivize practice-wide care transformation, not to just improve care coordination for Medicare beneficiaries but for all oncology patients.

To participate in the OCM, practices were required to implement 6 redesign activities which included providing patients with 24/7 access to a clinician, the utilization of patient navigation and care coordination services, and the collection and analysis of data for continuous quality improvement, among others.

OCM redesign activities sought to address the challenging nature of delivering coordinated oncology care across a team of clinical and support staff. One patient’s treatment may be administered over several months.  High-risk patients may require more frequent intervention.  Oral chemotherapy patients may require timely interaction for symptom management given they receive treatment outside of the clinic, increasing the risk that patient concerns may go unreported. And post-treatment follow-up may extend over several decades.

Evolution of Care Navigation

The utilization of clinical nurse navigators supporting education and coordination as “air traffic controllers” for care is not new to oncology.  But navigator support under the OCM may now extend to manage urgent care appointment slots or to triage patients after hours all in a time when appropriate use of emergency department and or hospital resources is even more important.  

Additionally, the utilization of non-clinical navigators can greatly impact both care quality and patient satisfaction.  Duties may include support coordinating treatment appointments, facilitating communication between clinical nurse navigators, and orchestrating other patient-centric support services, including financial counseling, psychosocial programs, and patient transportation.

 

Image: Centers for Medicare & Medicaid Services


*There are 192 practices (List) and 14 payers participating in the Oncology Care Model


Through the OCM, CMS incentivizes practices to implement clinical and non-clinical navigation services in two ways.  First, in addition to standard fee-for-service payment, practices will receive a per-beneficiary-per-month payment (PBPM) for each six-month treatment episode that initiates with outpatient chemotherapy. And secondly, practices will also be eligible for performance-based payments based on a number of factors including managing the cost of each care episode, meeting quality requirements, and receiving high marks in patient satisfaction.  But the question remains: what is the correct level of staffing and/or intervention to produce higher-quality at a lower cost?

Data-powered Quality Improvement

An organized tracking system that easily collects information on various patient interactions across the care team is vital not only for successful implementation of the OCM but also in delivering high-quality care.

The coordination of patient-centric activity among clinical and non-clinical navigators and support staff is a need many OCM practices have identified.  Capturing patient call type, frequency, and duration plus face-to-face patient interactions provides practices the insight necessary to appropriately resource these services. Further, when patient engagement data is tied to clinical outcomes, then a model for care coordination emerges that can be copied and scaled based upon patient volume, diagnosis, and risk scoring.  And activity data further supports care quality discussions with payers.

pMD’s Care Coordination solution includes expertise and technology to help practices meet the navigation requirements of the OCM. But care coordination is vital beyond oncology and the OCM.  pMD is passionate about helping practices to manage the complexity of care delivered across specialities supporting all care communities.  If you have any questions or would like to find out more about pMD's suite of products, which includes our MIPS registry, charge capture, secure messaging, and care coordination software and services, please contact pMD.

References:

https://innovation.cms.gov/initiatives/Oncology-Care/
https://innovation.cms.gov/Files/slides/ocm-overview-slides.pdf
https://voice.ons.org/news-and-views/how-the-oncology-care-model-is-redefining-quality-care
http://www.ajmc.com/contributor/jessica-walradt/2017/05/nine-months-in-understanding-the-oncology-care-model

Image: ThinkStock

Here's The Latest in Health Care:


•  The Centers for Disease Control and Prevention released new figures on vaccination rates, showing that the influenza vaccination rate has plateaued over the past few seasons. Although the efficacy rate of the vaccine is under 50%, it is still estimated to have prevented more than 5.4 million flu cases and 86,000 hospitalizations last season. Government health officials are urging health care providers to promote the flu vaccine among their patients.  Read More

•  The bipartisan bill, Creating High-Quality Results and Outcomes Necessary to Improve Chronic (CHRONIC) Care Act of 2017, was unanimously passed by the Senate. The bill will expand telehealth access for chronically ill Medicare patients by building broader telehealth benefits into Medicare Advantage plans and expanding the use of virtual care for stroke and dialysis patients.  Read More

•  Senate Republicans have postponed plans to repeal the Affordable Care Act due to insufficient votes for the latest health law overhaul bill. The Graham-Cassidy bill would have taken money provided under the Affordable Care Act for insurance subsidies and the expansion of Medicaid and sent it to states in the form of block grants.  Read More

•  The FDA has selected nine digital health companies to participate in a new pre-certification pilot program. The agency hopes to identify ways that pre-certified companies could potentially submit less information to the FDA than is currently required before marketing a new digital health tool as part of a formal program. The companies selected are: Apple, Fitbit, Johnson & Johnson, Pear Therapeutics, Phosphorus, Roche, Samsung, Tidepool, and Verily.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

Image: Courtesy of The Francis Crick Institute

Here's The Latest in Health Care:


•  The Office of the National Coordinator (ONC) for Health IT recently announced two big changes to the meaningful use certification program. The first gives EHR makers the ability to self-declare compliance. The second provides more discretion around randomized surveillance of certified health IT products. These changes are designed to reduce burden on the health care industry.  Read More

•  For the first time, researchers have been able to modify a key gene in human embryo DNA which gives crucial insight into embryo development. This work may someday lead to new techniques that can help infertile couples have children or treat incurable diseases with embryonic stem cells.  Read More

•  In order to earn a small positive adjustment from Medicare, doctors and practices need to begin collecting data no later than Oct. 2 to fully participate in MIPS, or the Merit-based Incentive Payment System's 90-day reporting period. The government has even made it easier for doctors to avoid a payment penalty based on 2017 reporting by allowing them to pick one measure for one patient, at the very minimum.  Read More

•  After a series of failed Senate votes in July, one repeal-and-replace plan for the Affordable Care Act remains. The proposal turns control of the health care markets over to the states. So, rather than funding Medicaid and subsidies directly, that money goes to the state to develop any health care system it wants.  Read More

Each Friday, Signor Goat reports the latest from the week in health care. Check back next Friday for your dose of our little medical corner of health care news. Brought to you by pMD, innovators in charge capture software.

Hello again! As promised, I’m back with more simply explained goodies about MIPS scoring for the 2017 performance year. In Part 1 of this series, we discussed the Basics of MIPS Scoring. That post is chock full of great information (if I do say so myself!) so definitely check it out. In today’s post, Part 2, we’ll cover scoring the Quality category. Then, in Part 3, we’ll discuss scoring for the Improvement Activities category. And finally, Part 4 will cover Advancing Care Information scoring, tying it altogether with an overview of the MIPS payment adjustment calculation. But, first, Quality!

The Basics of Scoring the Quality Category

For most of our MIPS Registry participants, the Quality category feels the most comfortable. Many of the principles we came to learn and love in PQRS hold true in MIPS Quality, so it’s less of a puzzle to figure out. But, there are some important differences, and scoring is one of them. Keep in mind that Quality is worth the largest portion - at least 60% - of the overall MIPS Final Score (a calculation I’ll discuss in Part 4), so if you’re aiming for a positive payment adjustment, this category is an important one to pay attention to.  

For the quality category, each reported measure will receive between 3 and 10 points. In order to be considered to receive more than 3 points, a reported measure must:

1) Comprise of at least 20 reported qualifying events;
2) Have a benchmark; and
3) Meet the data completeness standard.*

*For registry, QCDR, and EHR reporting, data completeness means that measures must be reported on at least 50% of the qualifying events for that measure, based on your entire patient population (not just Medicare Part B FFS patients), and must include at least one Medicare Part B FFS patient.

If any of the above features are missing, the measure will receive 3 points. But, if all the above features are established, the measure can receive up to 10 points. To determine whether more points will be awarded, CMS compares your measure’s performance data to a national benchmark. The benchmarks provide a comparison point to determine if your performance was higher than the national average, thus meriting more points.

You’re probably now wondering: where does the national benchmark data come from? Well, for the MIPS 2017 performance year, the benchmarks are based on 2015 PQRS performance data. Each benchmark is broken down into performance deciles, with the worst performance in deciles 3 and below and the best performance in decile 10. Benchmarks also vary from submission mechanism to submission mechanism. So, there is a different benchmark for EHRs, Registries, QCDRs, etc. You can check out the benchmark data that will be used for the 2017 performance year by going to the QPP website’s resource library and downloading the zip file called “2017 Quality Benchmarks.”

So, this is the basic methodology used to score the Quality category. Ultimately, your score depends on the benchmark, but as a rule of thumb, you want to have the highest possible quality performance to maximize points per measure. Also, note that, unlike PQRS where you received an automatic ding if didn’t fully report, with MIPS Quality, if you report less than 6 measures, and you’ll be scored on whatever is submitted, and receive a “0” score for measures that you could have submitted but didn’t. So, your score won’t be high in this scenario, but it’s not an automatic negative. On the other side of the spectrum, if you choose to report more than 6 measures, your outcomes or high priority measure will be scored, and then the measures with the highest points earned will be used in your score. But, note that all measure results submitted will become public information, so consider your quality reporting strategy carefully before submission.

Bonus Points Awarded in the Quality Category

Before we move on from Quality scoring, there is one more thing you should know. That is, you can receive bonus points in the quality category for two separate reasons. The first is by reporting additional high priority measures, and the second is by reporting measures via end to end electronic reporting.

Bonus Points Earned by Reporting Additional High Priority Measures

The first way to earn bonus points in the Quality category is to report additional high priority measures. But, there are three nuances to earning these bonus points that you should keep in mind:

1) The total amount of bonus points available is capped at 10% of the total points available to the reporter in the quality category. So, this isn’t a huge bonus, but it’s still a bonus!
2) To receive bonus points, you must submit at least the one required, fully reported, scored outcomes or high priority measure. So, make sure at least your first outcomes or high priority measures has 20 cases reported and 50% of all encounters, plus at least 1 Medicare Part B FFS patient.
3) Bonus measures themselves must have at least 20 cases reported and 50% of all encounters, plus at least 1 Medicare Part B FFS patient.

Assuming the above is considered and satisfied, bonus points are awarded as follows:

- Each additional outcome or patient experience measure = 2 bonus points.
- Each additional high priority measure = 1 bonus point.

Note that if you don’t report six measures, you can still earn bonus points, but only if you’re doing so because of lacking availability of applicable measures. Otherwise, you can earn bonus points on as many high priority measures as you report - both including the initial six, and including any additional measures you report. So, be sure your measure selection strategy includes as many outcomes and high priority measures as possible!

Bonus Points Earned by Reporting Via End to End Reporting

The second way to earn bonus points in the Quality category is to report your measures via end to end electronic reporting. But, again, earning these bonus points has some nuances to keep in mind:

1) The amount of bonus points available is capped at 10% of the total points available to the reporter in the quality category. So, this isn’t a huge bonus either. But, note that each bonus point category is a separate cap, so you can max out both separately.
2) Bonus points can be earned only if reporting via qualified registries, QCDRs, EHRs, or the CMS Web Interface, and when end to end electronic reporting is utilized. Claims reporters won’t qualify for these bonus points.

Keeping these considerations in mind, each measure reported via end to end electronic reporting will receive 1 bonus point.

Once all of that is determined, both types of bonus points are added to the score from the initial measures, and then divided by the total points available to that reporter in the quality category. This number is then multiplied by 60, which is the weight of the quality category in the final score. This is your final score for the Quality category.

 

Image: 2017 MIPS Quality Performance Category Fact Sheet


Yahoo! That’s Everything for Quality!

We made it through Quality scoring! Noice! One last note before we go -  all the information above is most relevant to 2017 performance year registry reporting, and there are some quirks depending on which type of submission mechanism you choose. pMD is a qualified registry, so we focused on that aspect of MIPS Quality scoring. If you have any questions or would like to learn more about our MIPS registry, give us a call! And, of course, to find out more about pMD's suite of products, which includes charge capture, secure messaging, and care coordination software and services, please contact pMD.

References:

Each reported quality measure will receive between 3 and 10 points: “[W]e will provide points for all submitted measures, but only a subset of measures receives points based on performance against a benchmark.” See https://www.federalregister.gov/d/2016-25240/p-3502; see also Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502 (illustrating that there are two categories for submitted quality measures one category that recieves 3 points and one category that receives between 3 and 10 points).

To receive more than 3 points, the reported quality measure must have a benchmark, have 20 cases, and meet the data completeness standard: See Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502.

When reporting through QCDRs, qualified registries, and EHRs, data completeness means reporting on 50% of all-payer data for that measure, and including at least one Medicare patient: Data completeness will include “all-payer data for the QCDR, qualified registry, and EHR submission mechanisms... In addition, those clinicians who utilize a QCDR, qualified registry, or EHR submission must contain a minimum of one quality measure for at least one Medicare patient.” See https://www.federalregister.gov/d/2016-25240/p-1492.

If any of the reported quality measures are missing the minimum requirements, they will receive 3 points: See Table 17 in the Final Rule at https://www.federalregister.gov/d/2016-25240/p-3502; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.

Comparing reported quality data against the national benchmark determines if a measure will receive more than 3 points: “When a clinician submits measures for the MIPS Quality Performance Category, each measure is assessed against its benchmarks to determine how many points the measure earns.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.  

National benchmark data used for the MIPS 2017 performance year is taken from 2015 PQRS performance data: “These historic benchmarks are based on actual performance data submitted to PQRS in 2015, except for CAHPS.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”

Each benchmark is broken into deciles: “Each benchmark is presented in terms of deciles.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”; see also 81 FR 77286, available at https://www.federalregister.gov/d/2016-25240/p-3476.

There is a different benchmark for each submission mechanism: “Benchmarks are specific to the type of submission mechanism: EHRs, QCDRs/Registries, CAHPS and claims.” See Quality Measure Benchmarks Overview pdf, pg. 1, available for download from https://qpp.cms.gov/about/resource-library, in a zip titled “2017 Quality Benchmarks.”

To maximize your MIPS score, you should fully report at least 6 measures: “[F]or any MIPS eligible clinician who does not report a measure required to satisfy the quality performance category submission criteria, we proposed that the MIPS eligible clinician would receive zero points for that measure. For example, a MIPS eligible clinician who is able to report on six measures, yet reports on four measures, would receive two “zero” scores for the missing measures.” See https://www.federalregister.gov/d/2016-25240/p-3513.

If you choose to report more than 6 quality measures, then the measures with the highest points assigned with be used: “If a MIPS eligible clinician elects to report more than the minimum number of measures to meet the MIPS quality performance category criteria, then we will only include the scores for the measures with the highest number of assigned points, once the first outcome measure is scored, or if an outcome measure is not available, once another high priority measure is scored.” See https://www.federalregister.gov/d/2016-25240/p-3623.

All measure results submitted will become public information: “[W]e are finalizing our proposal to report on Physician Compare the final score for each MIPS eligible clinician, performance of each MIPS eligible clinician for each performance category, and to periodically post aggregate information of such data. Accordingly, we are finalizing § 414.1395(a), which provides that for public reporting of an eligible clinician's MIPS data in that for each program year, we will post on a public Web site, in an easily understandable format, information regarding the performance of MIPS eligible clinicians or groups under the MIPS.” See https://www.federalregister.gov/d/2016-25240/p-4762. See also 81 FR 77394, available at https://www.federalregister.gov/d/2016-25240/p-4767. (“[W]e proposed to make all measures under the MIPS quality performance category (81 FR 28184) available for public reporting on Physician Compare (81 FR 28291). This would include all available measures reported via all available submission methods, and applies to both MIPS eligible clinicians and groups.” Proposed policy finalized at 81 FR 77395, available at https://www.federalregister.gov/d/2016-25240/p-4781).

If you report less than 6 measures, you’ll be scored on whatever is submitted, and receive zero points for any measure that could have been reported but was not: “Previously in PQRS, EPs had to meet all the criteria or be subject to a negative payment adjustment. However, we proposed that MIPS eligible clinicians receive credit for measures that they report, regardless of whether or not the MIPS eligible clinician meets the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3513; “After consideration of the comments, we are finalizing at § 414.1380(b)(1)(vi) that MIPS eligible clinicians who fail to report a measure that is required to satisfy the quality performance category submission criteria will receive zero points for that measure.” See also https://www.federalregister.gov/d/2016-25240/p-3524.  

You can receive bonus points in the quality category, but these bonus points are capped at 10%: [W]e are increasing the cap for high priority measures from 5 percent to 10 percent of the denominator (total possible points the MIPS eligible clinician could receive in the quality performance category)  of the quality performance category for the first 2 years.” See https://www.federalregister.gov/d/2016-25240/p-3561/.

To receive bonus points, the reporter must submit at least one scored high priority measure: “The MIPS eligible clinician can receive bonus points on all high priority measures submitted, after the first required high priority measure submitted, assuming these measures meet the minimum case size and data completeness requirements...” See https://www.federalregister.gov/d/2016-25240/p-3550; see also 81 FR 77292 https://www.federalregister.gov/d/2016-25240/p-3529 (“We noted that a MIPS eligible clinician who submits a high priority measure but had a performance rate of 0 percent would not receive any bonus points. MIPS eligible clinicians would only receive bonus points if the performance rate is greater than zero.”)

If you do not submit 6 measures, due to lacking availability of measures, you can still receive bonus points: “The MIPS eligible clinician can receive bonus points on all high priority measures submitted, after the first required high priority measure submitted, assuming these measures meet the minimum case size and data completeness requirements even if the MIPS eligible clinician did not report all 6 required measures due to lack of available measures.” See https://www.federalregister.gov/d/2016-25240/p-3550.

Measures that receive bonus points must be reported with at least 20 instances, and meet the data completeness standard, which for registries is 50% of all encounters reported, with 1 Medicare Part B FFS patient included:  “Bonus points are also available for measures that are not scored (not included in the top 6 measures for the quality performance category score) as long as the measure has the required case minimum and data completeness.” See https://www.federalregister.gov/d/2016-25240/p-3529.

Bonus points will be awarded on all reported measures that hit the 20 case minimum and the data completeness standard - both including the original 6 reported and any additional measures reported: “Bonus points are also available for measures that are not scored (not included in the top 6 measures for the quality performance category score) as long as the measure has the required case minimum and data completeness.” See https://www.federalregister.gov/d/2016-25240/p-3529.

Each outcome or patient experience measure reported in addition to the required high priority measure will receive 2 bonus points: “[W]e are finalizing at § 414.1380(b)(1)(xiii) our proposal to award 2 bonus points for each outcome or patient experience measure ... that is reported in addition to the 1 high priority measure that is already required to be reported under the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3553.

Each high priority measure reported in addition to the required high priority measure will receive 1 bonus point: “[W]e are finalizing at § 414.1380(b)(1)(xiii) our proposal to award ... 1 bonus point for each other high priority measure that is reported in addition to the 1 high priority measure that is already required to be reported under the quality performance category submission criteria.” See https://www.federalregister.gov/d/2016-25240/p-3553.

The cap for bonus points earned via end to end electronic reporting is 10%: “[W]e are increasing the cap for using CEHRT for end-to-end reporting from 5 percent to 10 percent of the denominator of the quality performance category (total possible points for the quality performance category) for the first 2 years.” See https://www.federalregister.gov/d/2016-25240/p-3598.

The cap for end to end electronic reporting is distinct from the cap for reporting additional high priority measures: “MIPS eligible clinicians will be eligible for both the CEHRT bonus option and the high priority bonus option with separate bonus caps for each option.” See https://www.federalregister.gov/d/2016-25240/p-3598.

You can only earn the end to end electronic reporting bonus if reporting via qualified registries, QCDRs, EHRs, or the CMS Web Interface, and end to end electronic reporting is utilized: “We are finalizing that the CEHRT bonus would be available to all submission mechanisms except claims submissions. Specifically, MIPS eligible clinicians who report via qualified registries, QCDRs, EHR submission mechanisms, and CMS Web Interface in a manner that meets the end-to-end reporting requirements may receive one bonus point for each reported measure with a cap as described.” See https://www.federalregister.gov/d/2016-25240/p-3599.  

Each measure reported via end to end electronic reporting will receive 1 bonus point: 77298 “After consideration of the comments, we are finalizing at § 414.1380(b)(1)(xiv) one bonus point is available for each measure submitted with end-to-end electronic reporting for a quality measure under certain criteria described in this section.” See https://www.federalregister.gov/d/2016-25240/p-3598.  

To calculate the quality category final score, bonus points are added to the score of the initial measures, divided by the total possible points, and then that number is multiplied by 60: “We will sum the points assigned for the measures required by the quality performance category criteria plus the bonus points and divide by the weighted sum of total possible points. The quality performance category score cannot exceed the total possible points for the quality performance category.” See https://www.federalregister.gov/d/2016-25240/p-3623; see also 81 FR 77276-7, available at https://www.federalregister.gov/d/2016-25240/p-3375.; see also 81 FR 7300-1, available at https://www.federalregister.gov/d/2016-25240/p-3631 (examples of scoring calculation).

The weighting for the Quality category is 60%: “Therefore, we are finalizing at § 414.1330(b) for MIPS payment years 2019... 60 percent … of the MIPS final score will be based on performance on the quality performance category.” See https://www.federalregister.gov/d/2016-25240/p-1164.

Image: Eric Thayer for The New York Times

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