Happy Wednesday everyone. Welcome to today's webinar. I am Jill Rathbun, the moderator for today's webinar. And before we begin, I'd like to share that we will take questions at the end of the webinar. So we'll have our speakers first and they'll go through the slide content and then we'll get to everyone's question. But knowing that your question might come up as you're listening to the content, please feel free to type your question into the question box on the, depending on, I guess, which way you're headed, the left-hand side of your screen. And so that we'll have them all at the end of the presentation today. Today's webinar is titled Year Three of the Quality Payment Program. Do you know how to avoid the 7% penalty to your Medicare reimbursement? This webinar will be presented by Dr. Sarah Boyles, who's chair of the Oggs Quality Committee, and Dr. Jamie Long, who is the vice chair of the Oggs Quality Committee. So a lot of great stellar Oggs leadership here running our webinar today. Dr. Boyles completed her residency at The Ohio State University and her fellowship in Female Pelvic Medicine and Reconstructive Surgery at Oregon Health and Sciences University. And she practices in Portland, Oregon, which is fabulous. And Dr. Jamie Long received her degree from Penn State College of Medicine and completed her residency at Reading Hospital and Medical Center in Pennsylvania, followed by a fellowship in Female Pelvic Medicine and Reconstructive Surgery at the Mayo Clinic School of GME. After practicing in lots of different places in PA, she recently returned to Penn State and is there with them at the Hershey Medical Center. Notice we have two alumni here of the Big Ten football conglomerate. That's always good. Okay, so very exciting. So after the presentation, as I mentioned, we will go through your questions. So now I'm going to turn it over to Dr. Boyles, who will start us off on our slides today regarding the Quality Payment Program. Thanks, Jill. So our agenda for this evening is as follows. I'll start with an overview of the Quality Payment Program. Our focus tonight is on the Merit-Based Incentive Program and discussing the final rule with its associated payment and policy changes. Jamie will then take over to discuss the specific changes that have occurred for year three, including what types of providers are now eligible for participation, the different ways in which data can be submitted and reported, the specific changes to the four performance categories, which are quality, cost, improvement activities, and promoting interoperability. And then the performance threshold, possible payment adjustments, and bonuses. I'll take over at that point to run through a scoring example and discuss ACQUIRE, the OGS Quality Improvement Registry that I'm sure you've all heard about. The Quality Payment Program or QPP became law in 2015 when the Medicare Access and Children's Health Insurance Program Reauthorization Act, or MACRA, was signed into law. This legislation ended the sustainable growth formula and is intended to tie reimbursement to quality and not quantity. The specifics of the program are updated annually in a final rule. There are two arms to QPP, the Merit-Based Incentive Payment System, or MIPS, which impacts more providers. CMS anticipates that approximately 800,000 providers will participate in 2019. The other arm is Advanced Alternative Payment Programs, or APPs, which we will not be addressing tonight. You may remember participating in the Physician Quality Reporting System, or PQRS, the Value-Based Modifier System, VM, and the Medicare EHR Incentive Program. These programs no longer exist individually but are the legacy programs that have been combined to help create MIPS. Each participant in MIPS is awarded a score that is based on the scores from the individual performance categories. This score is then used to determine a provider's payment adjustment and potential bonus. Like year two, there are four performance categories. These categories are the same as year two, quality cost, improvement activities, and promoting interoperability, which was renamed from Advancing Care Information in year two. The weighting of the performance categories has changed somewhat in year three. Quality has decreased from 50% to 45%. Cost has therefore increased to 15% from 10%. And then the weights of the improvement activities and promoting interoperability have saved the same at 15% and 25%, respectively. The performance year for 2019 extends from January 1st to December 31st. The reporting period for quality and cost is 12 months. The reporting period for improvement activities and promoting interoperability is a consecutive 90 days during this year. Data must be submitted by the 31st of March 2020, with CMS providing feedback later in 2020. The actual payment adjustment will take place in January 2021. So as in previous years, there's a two-year lag between performance and the payment adjustment. In 2019, the payment adjustment is plus or minus 7%, an increase from the 5% payment adjustment for performance in 2018. Remember that there is a finite pool of money and that there will be both winners and losers based on performance. The bonus money or potential bonus money is from a separate resource, however. CMS releases the updates to the QPP in a final rule. These annual updates allow CMS to slowly implement a long-term plan such as gradually increasing the performance threshold, but also allows the collection and implementation of stakeholder input. There's been work in year three to decrease provider burden, make meaningful measures, and reshape the focus of interoperability. As I mentioned before, we will only be discussing the changes to MIPS. This final rule also includes revisions to the physician fee schedule, including our view changes and E&M coding changes, among the other changes that are listed here. If you're interested in learning more about these topics, they're highlighted in a webinar that was presented last December by the Coding Committee, and this is available on the OGS website. I'm going to turn the presentation over to Jamie now, and she'll dive deeper into the changes for MIPS in year three. Okay. So, one of the bigger changes this year in the 2019 performance year three for MIPS is the expansion of eligible clinician types, and this will be important to all of us as FPMRS specialists because of the inclusion of physical therapists. There are actually a total of seven new clinician types that were added to the eligible clinicians from the year before, and as Sarah mentioned, CMS is expecting us to take our total of 620 eligible reporting clinicians up to 800,000 reporting this year. Other eligibility changes include the new low-volume threshold exclusion criteria. There were two low-volume threshold criteria previously, which include the first two on the left here, the billing of less than $90,000 of covered professional services to Part B, or having less than 200 Medicare Part B beneficiaries made a clinician ineligible to participate in MIPS. And this year, a third criteria, which is 200 covered professional services under the physician fee schedule has also been added as another exclusion criteria. A covered professional service is essentially a professional claim line. So, each time a patient is seen in your office, so this can include things like the annual visit, a sick visit, a prescription renewal visit, and if clinicians meet any of these three criteria now, they can be excluded from participating in MIPS. The determination period for whether or not a clinician is low-volume has also changed slightly. This determination period had previously run from September to August, but it's been consolidated with the other special status termination periods now, and also aligned so that it runs along with fiscal years. So, now the determination periods are two, one that runs from October 1st to 2017, and then October 1st, 2017 to September 30th, 2018, and a second one which runs from October 1st, 2018 to September 30th, 2019. You can use the lookup tool on QPP.DMAS.gov to see if you would be eligible based on both your NPI and your tax ID number as a low-volume physician or not, or if you meet any other special status. Finally, another change to the rule of the low-volume threshold is the opt-in option. So, as I mentioned, there are three criteria that define a low-volume threshold, and previously, if you met either one of these, you were ineligible to participate in MIPS. Now, if you meet one or two, but not all three of these criteria, you can be eligible to opt-in for a payment adjustment. So, for example, if you bill over $90,000 in covered professional services to Medicare, and if you bill over 200 covered professional services, but you only have 100 beneficiaries, you can have three options. You can do nothing, you can volunteer your data, and CMS will provide performance feedback, but no payment adjustment, or you can opt-in to participate, which makes you eligible for the adjustment to your pay. It is important to note, though, that once you do opt-in for the performance year, you cannot change that choice. It is irrevocable, and CMS is studying the best mechanism to receive your election. And so, if you are interested in participating in user research, they encourage you to reach out to them at CMSQPPFeedbackatKetchum.com to understand what would be the lowest burden way to communicate that preference to them. So, assuming you are MIPS eligible, and you don't meet any of the exclusion criteria, you have the same three options for participation, and that is as an individual, a group, or a virtual group. You can participate as an individual, even if you have partners, and your score is assigned based on a unique tax ID and MPI combination, which there can be multiple of these if you practice at several different sites. So, it's important to check which tax ID number and MPI combination that you are eligible under, and you must satisfy all of the categories by yourself. If you report as a group, as you remember from previous years, you do not need to fulfill all the requirements in each category as a group. Virtual groups have the same advantage, and you can elect for a virtual group, but the election is due January 1st. So, if you have not done this for this year, you will have to wait until next year. The terminology for reporting data has also changed. Previously, CMS referred to all types of submission mechanisms as an all-inclusive term that meant both the method of data submission, like registries, EHRs, attestations, types of measures or activities that were being submitted, and also the entities that submitted such data. But that term, submission mechanism, was not real clear, nor did it allow for the flexibility that they had. So, now there are new submission terms that are meant to provide further clarity and flexibility, and these include collection types, which deal with the quality measures, the submission type, which is the mechanism by which the submitter submits the data, the submitter type, which is the person or third party who submits the data. And you can see on this slide your different options for submitting data, both as an individual or as a group. And one thing that's new this year, as well, is that you can now use multiple collection types to report your data to CMS. So, as Sarah mentioned, the performance categories remain the same, quality, cost, improvement activities, and promoting interoperability. The performance periods also remain the same as year two. The only change here is that the quality and cost have been reweighted with a 5% adjustment moving from quality to cost. CMS anticipates that this will gradually approach a 30-30 split over the period of the next several years. So, diving a little bit deeper into these different performance categories, we'll start with quality. The same basic rules apply to quality as they have in previous years, but the benchmarks are getting tougher, and there's fewer bonus points available now. So, you must still report on six individual measures, and one must be an outcome measure. If there are no outcome measures available, you can report on another high-priority measure, which includes the patient experience, the patient safety, care coordination, appropriate use, efficiency, and now opioid measures are also considered high-priority measures. Again, you can report these through several different mechanisms and for collection types. And again, new for this year in 2019, you can report these quality measures through multiple different collection types, whether they be eCQMs, NIPs CQMs, QCDRs, CMS website, the Medicare claims or CAHPS or administrative data, depending on certain criteria for which it's excluded. Additionally, these six quality measures can be taken from 257 general measures that are available to everyone. CMS added eight new measures, including four that are patient-reported outcomes and six that are high-priority, and they removed 26 measures that were either topped out, duplicative, or low-bar. You can also report on specialty-specific measures through your registry, and each of these has a maximum of 10 points if it's a measure with a benchmark or three points if it's a measure without a benchmark. There's no changes to the data completeness rules, but it is important to note that data completeness is different than case minimum. So, CMS would like you to report on all of your payer patients, and they will audit to make sure that you're reporting on at least 60% of your Medicare Part B patients based on your claims data. If you do not meet that data completeness, they will take that quality down to only one point. Additionally, there is topped-out measures, and CMS basically has set up a 4-year lifecycle for measures that are deemed to be topped out, and these measures are also worth fewer points. They're worth 7 points instead of 10 points, even if you have perfect performance. Additionally, there are extremely topped-out measures that are likely to be removed in the next lifecycle or next rulemaking cycle of CMS, and these are measures that it's very difficult to judge any meaningful performance improvement because they already typically rate in the 98th to 100th percentile. Fortunately, none of our augment measures are topped out, and QCDR measures are excluded from the 4-year lifecycle, but if they are identified as topped out, they will question it during our nomination process, and they may not be approved. There are two measures that General Surgery had proposed previously that are topped out, so it's important to note that these ones that we commonly use, the perioperative care of selection of prophylactic antibiotics, as well as the perioperative care of venous thromboembolism prophylaxis, are now worth only 7 points. You can earn bonus points in the quality performance category through the following actions, and these are the same as in 2018. You can report additional outcome or patient experience measures and earn 2 bonus points for each of these. You can report additional high-priority measures at 1 bonus point each. You can report measures using end-to-end electronic reporting and get 1 bonus point for each measure that's reported that way. And new this year is the small practice bonus, which gets 6 additional bonus points for submitting at least 1 quality measure. This was given in previous years, but it was previously added to the final score. This year, it's now in the quality score. Bonus points are capped at 10% of the category denominator, which is 60 points for most practices, and this has not changed either since year 2. Moving on to cost measures, the cost measures again moved from 10% to 15%, and eventually, we'll probably see it move up to 30% over the next few years. Total cost per capita and the Medicare spending per beneficiary are unchanged, but CMS did add 8 new episode-based measures that are either for inpatient or for procedure-specific episodes. Each of these do have case minimum. We do not yet have a specific Gerogon episode yet, so it's not likely that any of these current episode-based measures will apply to us. They deal with cataracts and screening colonoscopies, neartheroscopies, STEMIs, and pneumonia admission, so it's not likely that we would meet the case minimum for these as Gerogon, but we are hoping in the later part of 2019 to hopefully develop something for mid-gerital sling. We have several of our AUGS members who have been sitting on these NQF and CMS boards to try to get this type of measure approved for us. Remember that the total cost per capita and the Medicare spending per beneficiary are both determined by plurality of services that are rendered by a clinician and the cost is attributed to the clinician with the most E&M codes on a patient, but for the procedure-specific episodes and the acute inpatient medical condition episodes, these would be triggered by an E&M claim line and then attributed to the clinician who either performed that procedure or who billed the most E&M codes under that hospitalization. This is another new rule in the cost category this year, which is the facility-based scoring. This is a new option for physicians who work primarily in an inpatient hospital, an emergency room, or an on-campus outpatient hospital, and if you furnish at least 75% of your covered professional services there, you can elect to have your cost and quality scores based on your facility. So essentially what you do is you are borrowing the measure set from the fiscal year hospital value-based purchasing program of the hospital that begins during the applicable MIPS performance period. You can check if you're eligible for this again on the QPP portal, and it will be automatically applied for eligible individuals or groups who would benefit from using their cost and quality from their facility. However, groups must still submit their data from improvement activities or promoting interoperability measures. Individuals do not. So, for example, what is essentially scored in the facility-based measurement is the goals for the hospital VBS program, and they are assigned a percentage score for their total performance score, and then CMS takes that percentage and applies it to the physician's quality and cost scores and gives them a similar score based on that percentage. You can still, as a facility-based physician, collect your own quality scores and submit to CMS, and they will compare and be able to give you credit for the better value that you can produce there. You can also get a preview of what your facility's scores look like early in the first quarter of 2019 at the CMS website, both to confirm your eligibility and also to see what your scoring would look like if you went with a facility-based scoring. This is not something that you have to elect. CMS will automatically do it for you as long as you don't submit your own quality data or if the facility's data scores you better than your own. Just a few changes to the improvement activities performance category. There are six new activities that have been added. Five existing activities were modified, and one existing was removed. This is the same 15% of the final score, and it's still attestation-based. Promoting interoperability performance category, though, has had some major overhauls. Remember, Sarah told us that this was previously called Advancing Care Information, or ACI. It was previously a fairly easy category to score in. There were 160 points that you could accumulate to get your score of 100 points, but now there's only 100 category points, and they are no longer attestation. For the most part, they are now performance-based scoring, and each measure has a numerator and a denominator. So, these are harder measures, and there's fewer pathways to get a perfect score. You have to report six measures from four different categories, and those four different categories are e-scribing, where there are 10 available points and another 10 bonus points for two opioid-related measures, both using the PDMP and also having opioid agreements in place. To encourage data liquidity, there is the health information exchange point, which is actually two different categories of 40 points with the categories relating to both sending and receiving health information. The provider-to-patient exchange is essentially the patient portal, and this is probably one of the more important categories to focus on, because if a physician or clinician claims exclusion in one of the other categories, the points will be reallocated to this objective. So, it could potentially be worth even more points. It's important to therefore offer the patient portal to your patients at their first visit in 2019. Lastly, there's the public health and clinical data exchange, which is 10 points, and this essentially relates to choosing two different registries and submitting data to it. So, to earn your maximum points, there are still some attestations, including that everyone must now be using 2015 edition certified electronic health record technology for at least 90 days to qualify to score here. You also have to submit a yes to the prevention of information blocking attestation and a yes to the ONC directed U.S. attestation if applicable, submit a yes for the security risk analysis, and report the required measures of the objectives with the numerator and denominators that we just discussed or claim an exclusion. So, again, these are performance-based scores and will be done essentially with the numerator and denominator producing a performance rate times the score divided by the weight of it unless exclusions are claimed in one of those categories and the points are then allocated to the patient portal measure. There is automatic reweighting for some clinicians, including nurse practitioners, PAs, and physical therapists, as well as all of the new clinician types have some reduced requirements and small practices also have reduced requirements in this category. Same as year two, you can still get bonus points for complex patients, and you do not need to do anything extra for this. This is automatically calculated for you using the hierarchical condition category or HCC risk code, which is a score based on the percentage of your dual eligible beneficiaries. And it's assessed during the second 12 month segment of the determination period, which again remember is October 1st, 2018 to September 30th, 2019. To get this bonus, you just have to submit data in at least one category. Additionally, you can get bonuses or reduced requirements if you qualify for a special status, and these include a small practice. In this case, you can use your Medicare Part Bs to claim your quality submissions. You can also earn points for quality measures that don't meet data completeness. Instead of one point, you can have three points, and you can get extra points for submitting just even one quality measure or recording any improvement activities. Rural status physicians also have additional support services and bonus points, as well as the non-patient facing, hospital-based and ambulatory surgery centers. As we talked about, they have the ability to do facility-based scoring now and the ability for other adjustments in their score. So here's really where the meat of all of this is, interpreting the final score. The performance threshold has been moved up from 15 points in 2018 to 30 points in 2019. So this is the score that you have to meet to get in neutral payment adjustment. If you're above it, you have the potential for a positive payment adjustment subject to the scaling factor. If you're below it, you're going to be subject to a negative payment adjustment. We expect that this performance threshold is going to continue to rise until it reaches about 60, which should be the mean or median by year six of this. The other number to pay attention to on this slide is the 75, and this is the exceptional performance bonus, which is a separate bucket of money. So in addition to the budget neutrality scoring factor that you get for achieving a score above the performance threshold, if you score above 75, last year it was 70, you are also eligible for a separate bucket of money, which is $500 million that CMS has set aside for these exceptional performance performers. If you score either zero points or seven and a half points, essentially in the bottom quartile, by law though, you must now receive the maximum penalty, which is a minus 7% this year. It's also important to note because of these increased stringencies of the rules and less bonus points, most projections are calculating that clinicians can expect to see about a 12 to 16% drop in their score from last year. So with that encouraging news, I'm going to turn it back to Sarah for a scoring example. Thanks, Jamie. We've covered this a couple of times, but these are the new scoring category weights for year three. So once again, quality 45%, cost 15%, improvement activities 15%, and then promoting interoperability at 25%. There we go. So for the quality performance measure, you submit your data. Data completeness must be 60% and the new case minimum for each measure or the case minimum for each measure is 20. Your measure data is compared to national benchmarks. The data is divided into deciles and depending on the distribution of the score in the benchmark, you're given points for the measure. Depending on how you compare to the benchmarks. So in this example, the provider submitted data on seven measures, although only the top performing six are scored. You only have to submit six. Of these seven measures, three do not have benchmarks and the maximum score possible is three points per measure because there are no benchmarks. So measure one, the measure data is submitted. It has benchmarks. So there's a maximum of 10 points here. The provider did pretty well compared to the benchmarks and has allotted 9.6 points. Measure two, same, maximum points is 10. Provider did really well and received 10 points. Measure three, so in this measure, the participant did really well, got nine point, would have gotten 9.3 points, but because the measure is topped out, they only received seven points. And I know that Jamie covered this, but topped out measures are ones where the 75th percentile is virtually indistinguishable from performance at the 90th percentile. And extremely topped out measures where everyone's performing in the 98 to 100th percentile may be removed in the next cycle. So measures four to six in this example are all measures that were reported, but there were no benchmarks because there just haven't been enough reported cases. And the maximum allotted points are three. So the provider got three points in each of these categories. Measure seven, this measure is the extra one that they submitted. It doesn't meet the case minimum because there were only 18 cases submitted and not the 20 required. So the maximum number of points would be one. However, in this example, this measure is considered to be an outcome measure. And if you submit two or more outcome or high priority quality measures, you're eligible for a bonus. And so because of that, there's an additional two bonus points. So to score the quality performance category, these points are all added up, right? 9.6 plus 10 plus seven. So that 9.3 is an error and should be seven. Plus three, plus three, plus three, plus three, plus the two bonus points divided by the maximum allowed number of points or possible points. And then multiplied by the category weight. So in this example, the provider got 29.9 points. And that's out of a possible 45 total points. So this example is important because it illustrates how important measure choice for the quality performance category is. This provider performed really well on the measures, but received fewer points because of the selection of benchmarkless measures and topped out measures. I would also point out though, that the performance threshold is 30. And in this case, the provider was just below 30 on the quality category alone. So the next performance category is cost. There were no episode-based cost measures in this example. The measures are scored using total per capita cost, TPCC, and the Medicare Spending Per Beneficiary, MSPB. Case minimums are 20 and 35 respectively. The measure score you receive is compared to benchmarks just like in quality and your assigned points. So in this example, the provider received 6.5 points for TPCC and an additional 9.9 for the MSBP. Those points are added together, divided by the total available points and then multiplied by the category weight. So they received 12.3 points out of a possible of 15 in the cost category. So improvement activities. For the improvement activities, you need to pick your activities and then you attest that you did it for 90 consecutive days. The max number of points is 40. Medium-weight activities are allowed 10 points. High-weighted activities are allowed 20 points. So you need to do two high-weight activities or four medium-weight activities or a combination thereof. In this example, the provider attested to doing three medium-weight activities for 10 points each and one high-weight activity for 20 points. And this resulted in 50 points. The max is 40. So they got 40 points times the category weight of 15% and that's a total of 15 points. A quick note, some of the performance activities are, or the improvement activities are marked as certified EHR technology eligible, meaning that the activity is eligible for a 10% bonus in the promoting interoperability category. So you can get some additional points there. Okay, so promoting interoperability is our last performance category. As Jamie mentioned, some measures require just an attestation and others require data. So to qualify for this, you have to use the 2015 Certified Electronic Health Record technology for at least 90 days and you have to attest to the three measures, prevention of information blocking, allowing a direct review by the ONC and conducting or reviewing a security risk analysis. The remaining four measures have to be reported on. So the first one is e-prescribing. In this example, the provider submitted 180 prescriptions that were written by the clinician, queried by the formulary and then transmitted electronically out of a total possible of 192 prescriptions. In this performance category, the measure is not compared to benchmarks. You just have your performance and then that's multiplied by the total number of points. So they had 93.8 and that's multiplied by 10 points. And all of the specifics of each one of these measures are available on the QPP website. So health information exchange, same thing. Their performance rate is 89.1% here times 20 possible points for 17.8 points. Receiving and incorporating information, 88.2 times the possible of 20 points and that's 17.6 points. Provider to patient exchange performance rate is 87.4% and that's multiplied by a possible of 40 points for 35 potential points. And then in this example, the provider attested to reporting to an immunization registry and to a public health registry. And this is a total of 10 points. So these points are all added again, the 9.4 plus 17.8 plus 17.6 plus 35 plus 10 divided by 100 because that is the total potential points you can get for this category and then multiplied by the category weight. So 22.45 points. So in this scoring example, the difference performance scores for each category are added together. 29.9 plus 12.3 plus 15 plus 22.45 for a total of 79.7 points. So in this example, it is above the performance threshold of 30. So there should be a positive payment adjustment. It's hard to know the exact percentage until everyone's information is in. And because they're greater than 75 points, this provider is also eligible for an additional bonus for exceptional performance. So that's the end of the scoring example. The last thing that I just wanted to mention is ACQUIRE, which is the OGS Quality Improvement Registry. There are lots of different ways that you can submit data and ACQUIRE is one way to do this. It's free to members. You can access it from the OGS website. Data entry into it is fairly straightforward. And some users have been able to push the data from their EMR rather than manually entering the data. So that can be done as well. And when using ACQUIRE, you can use it to submit your data for MIPS or you can just use it to compare yourself to the registry averages if that's something that you're interested in. And this slide is a screenshot of ACQUIRE and what it looks like. Some of the measures that are in ACQUIRE, so ACQUIRE has quality performance measures. It also supports other performance measures, including improvement activities and interoperability. But some of the quality measures that are in the ACQUIRE registry are unique. There are eight QCDR quality measures that are not available anywhere else. And those are ones that are most pertinent to your gynecologist. So they're all listed here, these eight measures, but offering a preoperative pessary for pelvic organ prolapse, doing an ACQUIRE test, and doing a preoperative test for pelvic organ prolapse, doing an apical suspension at the time of hysterectomy to address prolapse. So measures that may feel more interesting to the urogynecologist. ACQUIRE also has measures that are available elsewhere. And these are measures that we're all familiar with. So the prophylactic antibiotic measure, DVT prophylaxis measure. So those additional measures can be used as well in ACQUIRE. This, I believe, yeah, is our last slide, which brings us to the question and answer section. So Jill, I don't know if there are any questions yet. No, but I, not yet. And we hope that folks will type some into our little question box. But I had a question that I thought would be important. Both Dr. Boyles and Dr. Long have talked about the needing to check your eligibility status on the QPP website, which is www.qpp.cms.gov. And are we aware of any members who have checked their status and then had their status change? And given the two different eligibility periods. So I am not aware of that. Yeah, nor am I. The only, yeah, I actually am, but mostly for people who have shown up on advanced APM sheets, if they were unaware that they had somehow got included in an accountable care organization. So that gets updated on a quarterly basis. So that's important. Also, if you're brand new to practice, I just come out of fellowship, there is an exempt year for new people who are practicing. And sometimes the start time for that exempt year doesn't always line up exactly with the two eligibility determination periods. So it's really important for people to check both in the beginning of the year and at the end of the year kind of fall timeframe right around the August annual meeting to make sure that they are totally up to snuff, so to speak, and that they are also aware of what group they're being affiliated with if they are doing group reporting. I've also seen people who showed up on the QPP affiliated with a group that they are affiliated with multiple groups on the list that they were not aware that a group had them listed because they see patients at multiple hospitals. So it's really good to check your eligibility status now in the January timeframe and in the sort of August annual meeting timeframe just to make sure, because you can submit your data for a previous year up till March 31st of the following year. So, ah, Rick has a good question. So anyway, you can submit your data for the three months after the new year has started. Rick says, if we were in an ACO for the first two years and now that ACO is terminating, what can we do about those reported measures? Well, first of all, Rick, you're going to have to find a new method for doing your MIPS reporting because if the ACO is terminating, you will no longer be covered in an advanced alternative payment model for 2019. So that is an issue. So you're going to want to either, A, sign up for the Acquire Registry PDQ, because as Jamie and Sarah said, you have to report your quality measures for 12 months, or B, find another ACO that's an advanced alternative payment model in your community that is looking to add additional physicians and sign up with them so that you would be in the second quarter update to their list. Those are sort of the two options, but Rick also brings up a very good point. CMS is revamping the Accountable Care Organization program and unfortunately we believe many, about half of the current Accountable Care Organizations will choose to no longer participate in the program. So anyone who is or has had their QPP covered through being part of an ACO, if that ACO decides not to participate any longer, you're going to need to scramble and get yourself set up to do that. So Rick says, yeah, Athena Health. So Athena Health is an electronic medical record company. They may provide some quality measure reporting to the QPP program because electronic health record is an eligible method for reporting quality data. However, I would also stress that Athena has been purchased by another company. I don't know how that other company will treat their business going forward. So I would definitely, if you've been using Athena as your quality measure reporter, I would definitely check in with them for the 19 quality year, make sure they're still going to be able to offer that service for the entire 12 months of 2019 since the reporting period is 2019. And that they have recertified those same quality measures. And that as both Jamie and Sarah said, a number of quality measures have been taken out of the program for 2019 that any measures that they were reporting are still in the program. So lots of good questions. Thank Rick. He's helping us out there. Get good information out to everybody. So we have some more time. Any additional questions? I would also really stress to everyone when you're another reason to check your QPP status is the cost measure part. We do not yet have experience with the cost measures because 2018 was the first year of cost being measured and we won't see those results till later this year in 2019. I was at a meeting yesterday where there was a discussion and we do have some concern that as a surgeon, you will be tagged for all of that patient's costs, their hospital costs, their anesthesiology costs, their surgeon costs, as the anesthesiologist will be tagged for all of their costs. So the benchmarking for the total capita cost and the Medicare spend per beneficiary could affect us not positively. And so it's going to be very important that people check their cost projections on the QPP website so that you're not surprised if your points under the cost are not good. The other thing I would say is as Jamie mentioned, CMS has made some changes that are gonna drive the scoring down a little bit for the 2019 year and they've increased the threshold to 30 points. And from the 2017 experience, we know that for small practices, their median was about 36 points and that was at the go at your own pace year, but still that is a concern. So again, for folks who are in practices with less than 15 eligible clinicians, that includes all your nurse practitioners, your PAs, your physical therapists, you want to be really tracking your performance during the entire year and make sure that you're going to be doing okay on the points. And as Sarah said, really think about what measures you're selecting. So can we opt to use Athena measures instead of ACO? Well, if you're covered under an ACO list, you're gonna automatically go into the advanced alternative payment model side and then you're no longer eligible for MIPS. So your measure scores under Athena, if they're better, would not matter. You're going to be tagged with however well the ACO did period across the board. If you're going to be in the MIPS program now because your ACO is terminating, yes, you should talk to Athena ASAP and make sure they're still going to be a quality reporter for customers, find out the cost for them to do that for you. And if the measures you've been reporting on are going to be eligible in the MIPS program for 2019. So those are, that's probably a phone call, Rick, that you want to make yet this week or first of next week and get all that signed down with Athena and make sure you're covered. So any additional questions, thoughts, things we can help with? Okay, well, first I want to, on behalf of the AUG's quality committee, thank everyone for being on this webinar and also know that this webinar will be available on demand on the AUG's education system. So please, we hope that you all will download it again if necessary, share it with your colleagues, et cetera. And I want to really thank Sarah Boyles and Jamie Long for their great work this evening and help on the slides and Colleen Scow, AUG staff who helps and runs the choir and her great work on the content as well. We really appreciate their efforts and all of your time and efforts for joining us this evening for this webinar. And again, it will be on demand and hope that you will share it with your colleagues. The next AUG's webinar will be Integrative Medicine Meets Urogynecology. Wow, a current review. That sounds pretty interesting. Presented by Dr. Carolyn Eccles on February 13th, notice the day before Valentine's Day. So I hope folks will mark their calendars for that. So if there are any additional questions here, we're happy to take them. Otherwise, we're gonna give everybody about five minutes back of time for their evening.

Year Three

Quality Payment Program

7% penalty

Medicare reimbursement

webinar

Dr. Sarah Boyles

Dr. Jamie Long

performance categories

Acquire Registry