medicare

Advancing Care Information and Improvement Activities-Q&A

shutterstock_498951139The Merit Based Incentive Program (aka MIPS) defines four categories of eligible clinician performance, contributing to an annual MIPS final score of up to 100 points (relative weights are indicated for the CY2017 performance year and associated CY2019 payment year):

  • Quality (60% for 2017)
  • Advancing Care Information (ACI, renamed from Meaningful Use) (25% for 2017)
  • Improvement Activities (CPIA) (15% for 2017)
  • Cost (0% for 2017, but will be weighted for 2018 and beyond)

On December 13, 2016 the Centers for Medicare & Medicaid Services (CMS), briefly discussed two of the four Merit-based Incentive Payment System (MIPS) categories: Advancing Care Information (ACI) and Improvement Activities. Most of the 90-minute session was reserved for questions and answers. Here are some of the questions your colleagues asked, with answers from CMS.

Q: How is the ACI scored for hospital-based and non-facing patient clinicians who are part of a large multi-specialty reporting as a group?

A: That would depend on whether they choose to submit data, or not; they still have the option because they’re hospital-based. If they choose to participate, they will be scored as a group. The resulting update will apply to everybody in the group.

Q: When ACI is set to zero, to what category is the percentage applied?

A: The entire 25 points is moved to the Quality category, so instead of the Quality category being worth 60 points, it will be worth 85 points of the composite performance score (CPS).

Q: Will providers be submitting data through the same system for ACI and Improvement Activities as they did for the Electronic Health Record (EHR) Incentive Program?

A: No. There will be a new system for MIPS. However, if you are eligible to participate in the Medicaid EHR Incentive Program, you will need to attest through the same system as before.

Q: When reporting as a group, will nurse practitioners and physician assistants be excluded from ACI scoring if no data is submitted?

A: Yes. But if they are part of a group ,they will get the same update as everyone else in the group.

Q: Do eligible clinicians need to inform CMS in advance whether they will be attesting as an individual or a group? If so, how do they do that?

A: They don’t have to inform CMS; they just submit the data — unless they are reporting as a group through the CMS Web Interface or reporting Consumer Assessment of Healthcare Providers and Systems (CAHPS) data. Information on these protocols are forthcoming.

Q: For the test portion of Pick Your Pace, which allows for one improvement activity to receive credit, can we pick any activity or do we need to pick a high or medium activity?

A: You can pick a high or medium activity, but a medium activity will only give you have the points (7.5) toward your final score.

Q: If we do not use an EHR and cannot attest to ACI, do we have to attest or submit this fact anywhere?

A: No. Just don’t complete that part of the reporting requirements.

Q: The rule states that ACI performance for groups will be based on a group score. Does that mean the reports showing the numerator/denominator for each eligible clinician in the group have to be combined?

A: The attestation should be aggregate there is one submission — one numerator and denominator per measure — for the group. If the group is using multiple EHR technologies, you will have to sum the numerator/denominator for each measure across the different EHRs for the group.

Q: If you do group reporting, do you only need a “1” in the numerator for the entire group to get credit for the base score under ACI?

A: Yes.

Q: When will the specifics of the improvement activities be released? The working on the 90-plus activities are vague and open to interpretation.

A: We are not planning to issue more specific language around the activities for the transition year. We aren’t requiring any specific data to be submitted. What you see is on the Quality Payment Program (QPP) website is all that is required.

Q: Will the bonus payment be a one-time payment?

A: Whatever score you get in MIPS will be applied to your Physician Fee Schedule amount. The method for paying the added bonus for exceptional performers is still being worked out.

Q: What if your certified EHR technology (CEHRT) year changes mid year due to an upgrade and your submitting a full year of data?

A: You can submit a combination. Aggregate your data between the  two EHRs and submit the data for the ACI category as one submission. This is not the case for Quality reporting, however. You will need to work with a data aggression vendor to report electronic Clinical Quality Measures (eCQMs), in that case.

Q: Does MIPS reporting take the place of EHR reporting? Do we still have to use a qualified EHR or can we do claims-based reporting?

A: The data needs to come out of your EHR. For Quality measures, you’re no longer required to submit eCQMs to earn credit. In the Quality category, you could submit via claims and it wouldn’t count against you.

Q: Can you report as a group under MIPS if not all of your providers are using a CEHRT?

A: Yes.

Q: What type of documentation is required for improvement activities?

A: For improvement activities, we are not requiring documentation. But providers should retain copies of medical records, charts, reports, and any electronic records that are applicable and appropriate for up to 10 years after the conclusion of the performance period, in case of an audit.

See the whole presentation:

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New EHR Attestation Deadline

New EHR Attestation Deadline for Eligible Professionals:
March 31, 2014

CMS is extending the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program 2013 reporting year from 11:59 pm ET on February 28, 2014 to 11:59 pm ET March 31, 2014.
In addition, CMS is offering assistance to eligible hospitals who may have experienced difficulty attesting to submit their attestation retroactively and avoid the 2015 payment adjustment.
This extension will allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment.
This extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including the electronic submission for the Physician Quality Reporting System EHR Incentive Program Pilot.

How to attest?
If you are an eligible professional, you may use the registration and attestation system to submit your attestation for meaningful use for the 2013 reporting year. You must attest prior by 11:59 pm ET on March 31, 2014 to meet the new 2013 program deadline.
If you are an eligible hospital, you may contact CMS for assistance submitting your attestation retroactively. You must contact CMS by 11:59 pm on March 15, 2014 in order to participate for the 2013 program year.

Resources
If you are an eligible professional working on your attestation for the 2013 reporting period, there are resources available to help you with the registration and attestation process.
Stage 1 Meaningful Use Calculator
Registration and Attestation User Guides
EHR Incentive Program Website
The EHR Information Center is open to assist you with all of your registration and attestation system inquiries. Please call, 1-888-734-6433 (primary number) or 888-734-6563 (TTY number). The EHR Information Center is open Monday through Friday from 7:30 a.m. – 6:30 p.m. (Central Time), except federal holidays.

Tips
In addition, there are some simple steps you can take which will help to make the process easier for you:
• Ensure that your payment assignment and other relevant information is up to date in the Medicare payment system PECOS
• Make sure to include a valid email address in your EHR program registration
• Consider logging on to use the attestation system during non-peak hours such as evenings and weekends
• Log on to the registration and attestation system now and ensure that your information is up to date and begin entering your 2013 data
• If you experience attestation problems, call the EHR Incentive Program Help Desk and report the problem
• If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation.

Eligible Hospital Instructions:
1. Send the following information to EH2013Extension@Provider-Resources.com no later than 11:59 PM EST on 3/15/2014:
o CCN
o Hospital Name
o Contact Person Name
o Contact Person Email
o Contact Person Phone
2. Type “EH 2013 EXTENSION” in the subject line of the email note
3. Each Hospital must be identified in a separate email
CMS will contact the person that you designate in your request to provide additional instructions regarding the Eligible Hospital 2013 attestation submission.

Other changes for 2014

sunriselogo2009With all the chatter going on with ICD-10, I thought it appropriate to write something that doesn’t revolve around ICD-10.  There are changes in Meaningful Use stage 1, and new criteria for Stage 2 Meaningful Use, Clinical Quality Measures and PQRS.  Happy reading!

If you have attested for at least 2 years for stage 1 meaningful use, then stage 2 is next on the docket for your practice. If you have attested once for stage 1 then all those things you attested to before now will change this year. Stage 1 requirements change in 2014 as well as Stage 2 Meaningful Use objectives for those of you who have successfully completed two years of Stage 1.

 Let’s first tackle those changes in 2014 to Stage one Meaningful Use:
1. Electronic Health Record (EHR) software systems have to re-certify their product to meet new regulations for 2014. Right now your current EHR has undergone the certification process for 2014 and will be available early spring of 2014.
2. For those of you that plan on doing stage 1 in 2014, certain “core” and “menu” objectives have been removed/combined and you can no longer count measure exclusions toward meeting menu objectives. You will have to meet 5 of the 9 menu items and 13 (as opposed to 15 in previous years) core objectives.
3. Clinical Quality Measure reporting will change as well. You will have to report on 9 and those 9 need to cover at least 3 of the 6 National Quality Strategy Domains. I’ve explained more later on.
4. Reporting is done in one calendar quarter, as opposed to 90 consecutive days previously (for example, April 1 2014- June 30, 2014). Rules for Medicaid incentive have not changed for 2014 so you can report for any continuous 90 days under Medicaid.
5. This is the last year you are eligible to begin to get incentive payments. If you are planning to start your first year this year you can still earn as much as $24,000 in incentives. AND your meaningful use performance in 2014 will be the basis for 2016 payment adjustments.
6. CPOE Denominator changes-now required (you will not be able to exclude from this measure).
7. Vital sign age limit is 3 years and older (changed from 2 years and older) for blood pressure and no age limit on height and weight. Since BP is separate, you can exclude from the BP measure.
8. The old stage 1 requirement for providing patients with an electronic copy of their health information upon request will be changed in 2014 to “Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP”.
9. The old stage 1 requirement for providing patients timely electronic access to their health information within 4 business days will be changed in 2014 to “More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP’s discretion to withhold certain information”.

Moving on to what is next with Stage 2 Meaningful Use.

Stage 2 retains the same basic structure as Stage 1; however, all those Menu items in stage 1 become CORE items for Stage 2 with higher thresholds that you must achieve. There are also some new Stage 2 core and menu objectives.

STAGE 1

STAGE 2

 

13 Core Objectives 17 Core Objectives
5 of 10 Menu Objectives + 3 of 6 Menu Objectives
18 total objectives 20 total objectives

+CQM’S

=STAGE 2 MEANINGFUL USE

What are the requirements?
17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.
3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

The following is a list of the Stage 2 Meaningful Use 17 Core Objectives
1. Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders
2. Generate and transmit permissible prescriptions electronically (eRx)
3. Record demographic information
4. Record and chart changes in vital signs
5. Record smoking status for patients 13 years old or older
6. Use clinical decision support to improve performance on high-priority health conditions
7. Provide patients the ability to view online, download and transmit their health information
8. Provide clinical summaries for patients for each office visit
9. Protect electronic health information created or maintained by Certified EHR Technology
10. Incorporate clinical lab-test results into Certified EHR Technology
11. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
13. Use certified EHR technology to identify patient-specific education resources
14. Perform medication reconciliation
15. Provide summary of care record for each transition of care or referral
16. Submit electronic data to immunization registries
17. Use secure electronic messaging to communicate with patients on relevant health information
In addition to the 17 core objectives, there are 6 Menu Objectives (and remember, you’ll only have to do 3 of the 6).
1. Submit electronic syndromic surveillance data to public health agencies ($-for the additional interface)
2. Record electronic notes in patient records
3. Imaging results accessible through CEHRT
4. Record patient family health history
5. Report cancer cases to a public health central cancer registry
6. Report specific cases to a specialized registry
Important Note: While there are exclusions provided for some of these menu objectives, you cannot select a menu objective and claim the exclusion if there are other menu objectives that you could report on instead.

Changes to Clinical Quality Measures
Beginning in 2014, the reporting of clinical quality measures (CQMs) will change for all providers.
You have the option of submitting three months of CQM data online through the CMS Registration & Attestation System. This will be the same website you go to for attestation now.
You also have the option to submit a full year of data electronically using the QRDA format to receive credit for the EHR Incentive Program and the Physician Quality Reporting System.
Please note that your attestation for the Medicare EHR Incentive Program is not complete until you submit clinical quality measure data, so your EHR incentive payment will be held until your electronic submission is processed.
If you are a provider using Medicaid, you must submit your clinical quality measurement data to your State Medicaid Agency.
How to Select CQM’s in 2014
Beginning in 2014, eligible professionals must select and report on 9 of a possible list of 64 approved CQMs for the EHR Incentive Programs.
There is also a new requirement in 2014 that the quality measures selected must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services’ NQS priorities for health care quality improvement. The 6 domains are:
• Patient and Family Engagement
• Patient Safety
• Care Coordination
• Population and Public Health
• Efficient Use of Health Care Resources
• Clinical Processes/Effectiveness
In short there are a lot of changes this year in addition to ICD-10 implementation.

Stay tuned….

Sunrise Services, LLC

 

PQRS..more than just letters in the alphabet!

In all the whorl wind of Meaningful Use Stages one and two, e-RX incentives (or penalties), ICD-10 implementation, there’s another “oldie but goodie” program for providers to participate in.  The program has been around for a few years, but did you know come 2015, you may be subject to another penalty (on top of everything else) for not participating in this program?

According to CMS- The Physician Quality Reporting System (PQRS) is a reporting program that uses a combination of incentive payments and payment adjustments to promote reporting of quality information by eligible professionals. Beginning in 2015, the program also applies a payment adjustment to eligible professionals who do not satisfactorily report data on quality measures for covered professional services.

Planning to participate in 2013?  Here are some things you should know:

  • To earn the 2013 PQRS incentive payment and avoid the 2015 PQRS payment adjustment you need to collect your data from January 1 through December 31 of this year.
  • Decide if you are going to report through your EHR (you may have to discuss with your vendor if you can report through your EHR), or if you are going to report your measure on claims.
  • Become very familiar with the CMS website- http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS
  • Report on each eligible claim
  • Avoid including multiple dates of service and/or multiple rendering providers on the same claim – this will help eliminate diagnosis codes associated with other services being attributed to another provider’s services
  • For measures that require more than one code, ensure that all codes are captured on the claim
  • If your claim with the reporting codes on it was denied for payment the PQRS codes will not be included in the program analysis.
  • Check you remittance advice for remark code N365, which reads “This procedure code is not payable. It is for reporting/information purposes only.”
  • Review all diagnoses (if applicable) and CPT Service (encounter) codes for denominator inclusion in PQRS/eRx (i.e., claims that are denominator-eligible).

Participation this year in the program could earn you incentives of up to 1%.  Failure to report could land you a whopping 1.5% pay cut (in addition to all those other penalties from CMS).

Need to learn more?  Visit us on the web at www.sunrize.com.  CMS also has a new eHealth Website that has some useful information as well- http://www.cms.gov/ehealth.