December

1.    Who can join a virtual group?  
A Virtual Group is a combination of 2 or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter specialty or location) to participate in MIPS for a performance period of a year.

2.    How are virtual groups treated?  
The policies that apply to groups generally apply to virtual groups, but note that: 
The definition of a non-patient facing clinician includes eligible clinicians in a virtual group if more than 75% of NPIs billing under the virtual group’s TINs meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period. Virtual groups determined to be non-patient facing will have their Advancing Care Information performance category automatically reweighted to 0. For the 2018 MIPS performance period, the quality, improvement activities, cost and advancing care information performance category scores will be given weight in the final score, or be reweighted if a performance category score is not available.

  • A virtual group will have a small practice status if the virtual group has 15 or fewer eligible clinicians.
  • A virtual group will be designated as a rural area or Health Professional Shortage Area (HPSA) practice if more than 75% of NPIs billing under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA.
  • Virtual groups participate in MIPS across all 4 performance categories, and are subject to the same measure and performance category requirements as other groups reporting under MIPS. Virtual groups can submit data the same ways groups can. Each virtual group would aggregate its data across its TINs for each performance category and be assessed and scored at the virtual group level.

3. Can a virtual group qualify for small or rural considerations?
A virtual group will have a small practice status if the virtual group has 15 or fewer eligible clinicians.  A virtual group will be designated as a rural area or Health Professional Shortage Area (HPSA) practice if more than 75% of NPIs billing under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA.

4.  How do I join a virtual group?  
When eligible clinicians and groups want to form a virtual group, they have to go through the election process. The election to participate in MIPS as a virtual group has to happen before the performance period and can’t change during the performance period. For the 2018 MIPS performance period, the election period began on October 11, 2017 and ends on December 31, 2017 as described in the 2018 Quality Payment Program final rule. You will find the full 2 step process and guidelines located on the QPP Resource page under the 2018 Virtual Group Toolkit link. 

5. Why would I join a virtual group?  
Solo practitioners or groups with 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician) may not have enough cases to be reliably measured on their own, but if a solo practitioner or such group forms a virtual group with another solo practitioner or group, together they could increase the performance volume in order to be reliably measured. Additionally, if you’re a solo practitioner and/or have a group with 10 or fewer eligible clinicians and join a virtual group, you’d be able to work together, share resources, and potentially increase performance under MIPS.  For a fact sheet and more information, go to the QPP Resource page and click on the 2018 Virtual Group Toolkit link.


November

1.    What is an Alternative Payment Model? 
An Alternative Payment Model (APM) is a payment approach that gives added incentive payments to provide high-quality and cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population.

2.    What is an Advanced Alternative Payment Model? 
Advanced APMs are a subset of APMs, and let practices earn more for taking on some risk related to their patients' outcomes. You may earn a 5% incentive payment by going further in improving patient care and taking on risk through an Advanced APM.

3.    Where can I find a list of Advanced Alternative Payment Models?
The list is located on the Centers for Medicaid and Medicare Quality Payment Program website: www.qpp.cms.gov

In 2017, the following models are Advanced APMs:

4.    How do I join an Advanced Alternative Payment Model?
Learn more about Advanced Alternative Payment Model’s and how to apply: here

5.    Is there a resource to help me and my team design an Alternative Payment Model? 
You can access the CMS Alternative Payment Model design toolkit: here



October

On September 18, 2017, CMS made the 2016 Annual Quality and Resource Use Reports (QRURs) available to all group practices and solo practitioners nationwide. Please join us on October 24th at for the Colorado QPP Coalition webinar on Understanding your QRUR Report. To register for this webinar event, please click here 

To better prepare you for this event, here are 5 Fast Facts in 5 minutes about the Quality & Resource Use Report.

1.  How do I obtain my 2016 QRUR? 
Visit How to Obtain a QRUR to access your report prior to the event.

2. Does every group and/or solo practitioner receive an annual QRUR? 
No, the QRUR reports are based on quality reporting metrics from the previous year. Therefore if you have not participated in previous quality reporting programs, such as PQRS, you will not receive a 2016 QRUR report for your physician practice. 

3. If I do not have an EIDM account, and I am a solo practitioner, what should I do? 
A solo practitioner is defined as a TIN with only 1 EP, as identified by a NPI, that bills under the TIN. To access a solo practitioner's QRUR, one person must first sign up for an EIDM account with the Individual Practitioner role. If you do not have an EIDM account, then follow the instructions provided here to sign up for an EIDM account with the correct role.

4. If I do not have an EIDM account, and I am participating in a group, what should I do?
 A group is defined as a TIN with 2 or more eligible professionals (EPs), as identified by their National Provider Identifier (NPI), that bill under the TIN. To access a group's QRUR, one person from the group must first sign up for an EIDM account with the Security Official role. If you do not have an EIDM account, then follow the instructions provided here to sign up for an EIDM account with the correct role.

5. Where can I go for more information or upcoming webinars? 
For assistance with interpreting QRURs and requesting an informal review of your data, contact the QRUR Help Desk at 888-734-6433 (select option 3) or pvhelpdesk@cms.hhs.gov.

There is also an upcoming Webinar hosted by CMS. Please click Register to sign up for this event! 

 


September

Question:  Do I have to use the same reporting methodology to submit my measures for each performance category under the MIPS track? 


Answer: Individual eligible clinician’s and groups may submit data for different performance categories via multiple submission mechanisms.  However, you must use only one reporting mechanism per performance category.  There is one exception to the requirement for one reporting mechanism per performance category.  Groups that elect to include CAHPS for MIPS survey as a quality measures must use a CMS-approved survey vendor.  Their other quality information may be reported by any single one of the other submission mechanisms. 


Question: What are the submission mechanism options for 2017?

Choose your submission mechanism and verify its capabilities. You can submit data via: 

  • Qualified Clinical Data Registry (QCDR) 
  • Electronic health record (EHR) 
  • Qualifying registry 
  • Claims 
  • CMS web interface 

Verify your EHR vendor’s, Registry’s or QCDR’s capabilities before your chosen reporting period. Contact your EHR, Registry or QCDR vendor directly to verify their reporting deadlines and confirm that they will be able to report your data to CMS.


Question:  We have not done anything with regard to the Quality Payment Program this year, is it too late? 

Answer:  No, you get to pick your pace for the Quality Payment Program 2017 Performance year. You can choose to start anytime between January 1 and October 2, 2017. Whenever you choose to start, you’ll need to send in your performance data by March 31, 2018.

 

Question:  What is the deadline to report for the 2017 Quality Payment Program?

Answer: You will have until March 31st, 2018 to submit your data to avoid a negative payment adjustment in 2019. 

 

Question: Are FQHC required to report on any of the 4 categories of MIPS? Is it my understanding they do not report the Quality component but what about the other 2 for 2017?
 

Answer: MIPS eligible clinicians furnishing items and services in FQHCs that are billed under the FQHC payment methodology are not required to participate in MIPS and would not be subject to a payment adjustment in 2019.  These MIPS eligible clinicians have the option to voluntarily report on applicable measures and activities for MIPS.  If such MIPS eligible clinicians voluntarily participate in MIPS, they would follow the requirements established for each performance category.  The data received from such MIPS eligible clinicians would not be used to assess their performance for the purpose of the MIPS payment adjustment.  
However, if MIPS eligible clinicians furnish items and services in FQHCs that are billed as Medicare Part B charges by the MIPS eligible clinician, these MIPS eligible clinicians would be required to participate in MIPS.  The Items and services furnished by a MIPS eligible clinician that are payable under the Medicare Part B payment methodology would be subject to the MIPS payments adjustment in 2019.  These MIPS eligible clinicians may be excluded from the requirement to participate in MIPS if they do not exceed the low-volume threshold.

 

Question: How can I stay up to date with QPP related news and resources available to help? 
 

Answer: We recommend you periodically review the CMS QPP website for news, fact sheets, webinars and resources to help you be successful in the Quality Payment Program. You can view this information here.   Information is being updated frequently.  The following fact sheets were added September 7th.
a.    Group Participation in MIPS
b.    MIPS Measures for Anesthesiologists and Certified Registered Nurse Anesthetists
c.    MIPS Measures for Emergency Medicine Clinicians
d.    MIPS Measures for Ophthalmologists
e.    MIPS Measures for Orthopedists
        

Register for the Colorado QPP Coalition Office Hours;  
September 26th  –  QPP Performance Category Reporting. 
October 24th  – Quality Resource & Utilization Report (QRUR) Education and Training 
November 28st – Why Alternative Payment Models Matter and Your QP Status
December 26th  –  Preparing for 2018 - The Final Rule.
January 23th  –  QPP Performance Category Reporting: The basics and guidance on how to report 

Registration Link: https://ucdenver.zoom.us/webinar/register/044cb914c32bb739d746f627e8486654


August

1. What is a Qualified Registry? 

 A qualified registry is an entity that collects clinical and non-clinical data from an individual clinician or group practice that is participating in the merit-based incentive payment system (MIPS) and submits it to the Centers for Medicare & Medicaid Services (CMS) on behalf of the clinicians. Clinicians work directly with a chosen CMS-approved registry to submit data on the selected measures or specialty set of measures. For a list of the 2017 approved qualified registries, click here. 

2. What is a Qualified Clinical Data Registry (QCDR)?

A QCDR is a CMS-approved entity that collects clinical data on behalf of clinicians for data submission directly to CMS for MIPS reporting. A clinical data registry records information about the health status of patients and the healthcare they receive in an organized system. QCDRs give a picture of the overall quality of care provided because QCDRs collect and report quality information on patients from all payers, not just Medicare patients. For the official list of the 2017 CMS-approved QCDRs that lists each measure collected (248 pages) click here.

3. What is the difference between a Qualified Registry and a QCDR?
The QCDR reporting option is different from a qualified registry because it isn’t limited to measures within the Quality Payment Program (QPP). The QCDR can host “non-MIPS” measures approved by CMS for reporting. Measures submitted by a QCDR might include measures from one or more of the following categories, with a maximum of 30 non-MIPS measures allowed per QCDR:

  •     Clinician and Group Consumer Assessment of Healthcare Providers and Systems (CAHPS), which must be reported via a CAHPS certified vendor 
  •     National Quality Forum (NQF) endorsed measures 
  •     Current 2017 MIPS measures 
  •     Measures used by boards or specialty societies 
  •     Measures used by regional quality collaborations 
  •     Other approved CMS measures 

4. Need a user friendly search tool for your Qualified Registry or QCDR research? 
Click here for a tool developed by the American Medical Association to search for a QCDR or registry approved by CMS for submitting QPP measures. This tool provides easy navigation and filtering options.

5. Where can I go to learn more about these reporting options? 
The QPP website offers excellent resources and education. Please click here to go to the resource library on this site. 

Stay tuned for the upcoming September webinar hosted by the Colorado QPP Coalition on “How to report for the 2017 QPP Performance Year.” For more information and to register for this webinar, please check the coalition webpage. http://www.cms.org/coqpp/.



July

Don’t let the June 20th release of the CMS Quality Payment Program Proposed Rule  confuse you!  The changes in the Proposed Rule do not effect 2017 reporting period and are proposed to begin in the second year (2018) of the QPP program.  As written now, the Proposed Rule aims to simplify reporting requirements, increase low-volume threshold, change reporting periods, add virtual groups and allow for more flexibility.  Comments are due by August 21st with the expected release of the QPP Final Rule for Year 2 in the fall of 2017.

For a Fact Sheet on the comparison between performance year 2017 and the 2018 proposed rule click here: https://qpp.cms.gov/docs/QPP_Proposed_Rule_for_QPP_Year_2.pdf

Have you see the official Merit Based Incentive Payment Program 2017 Approved list of Qualified Clinical Data Registries? Check it out:  https://qpp.cms.gov/docs/QPP_2017_CMS_Approved_QCDRs.pdf

CMS released the 2017 Approved Qualified Registry list.  You can review on here: https://qpp.cms.gov/docs/QPP_2017_CMS_Approved_QCDRs.pdf

Wondering how to participate as a group when reporting for the 2017 Quality Payment Program under the Merit Based Incentive Payment System track? This guide will review all you need to know! https://qpp.cms.gov/docs/QPP_Group_Participation_in_MIPS_2017.pdf
 


June

Have you seen the June Quality Payment Program (QPP) Updates and News Releases for the Merit Based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM)tracks? Be sure to check out the QPP website for new information that is being posted frequently. This month the following guides, fact sheets and information were released:

Introduction to Group Participation in MIPS for 2017: https://qpp.cms.gov/docs/QPP_Group_Participation_in_MIPS_2017.pdf

Medicare Shared Savings Program and the Quality Payment Program:
https://qpp.cms.gov/docs/QPP_MSSP_and_QPP.pdf

MIPS measures for Cardiologists:
https://qpp.cms.gov/docs/QPP_MIPS_Measures_for_Cardiologists.pdf

MIPS measures for Primary Care Clinicians:
https://qpp.cms.gov/docs/QPP_MIPS_Measures_for_Primary_Care_Clinicians.pdf

Predictive Qualifying Professional Fact Sheet:
https://qpp.cms.gov/docs/QPP_Predictive_QP_Methodology_Fact_Sheet.pdf


May


Question: When will I receive my letter from the Centers for Medicare and Medicaid Services (CMS) indicating clinician eligibility for the Quality Payment Program?
Answer: Currently the Medicare Administrative Contractors (MACs) are processing the production of eligibility letters.  All Tax Identification Numbers (TINs) should receive the letter no later than May 31, 2017.  Letters will be sent at the TIN level to the TIN representative on record, not at the individual clinician level.  Specific participation status that applies to individual clinicians (National Provider Identifier or NPIs) assigned to that TIN will be included.  You can access the sample letter and attachments about MIPS participation status being sent to clinician offices . here

Question: Is there information available that is specific to clinicians that are in small, rural or practices in underserved areas? 
Answer: Yes, there are several resources available on the QPP Website. Please click here for a fact sheet.
In addition to the fact sheet,  the following videos are also available that take around 10-15 minutes to complete.

Small, Rural, and Underserved Practices


Question: How do I choose and submit Improvement Activities for the Merit Based Incentive Payment System (MIPS) track?
Answer: There are approximately 94 Improvement Activities to choose from under the MIPS track. You can find a list of the activities, definitions and submission options on the QPP Website:  www.qpp.cms.gov  There is also a MIPS Improvement Activities Fact Sheet located on the Education and Tools tab of the QPP website.

Question: How do I register for group reporting using the CMS Web Interface?
Answer: You’ll need to complete the registration process (between April-June 2017) that notifies CMS that you are choosing this data submission option. Note: If you are a part of an Accountable Care Organization, you do not need to register to report via the CMS Web interface. You can find a CMS Web Interface Registration Guide  located on the QPP website. The Registration System can be accessed at qpp.cms.gov using a valid Enterprise Identity Management (EIDM) account.  In addition to meeting the quality performance category by reporting through the CMS Web Interface, MIPS groups can also use the system to submit the MIPS Improvement Activities and Advancing Care Information performance categories. The CMS Web Interface will open January 2018 for data submission

Question: Is there a Consumer Assessment of Healthcare Providers and Systems (CAHPS ) specific to MIPS?
Answer: Yes, there is. You can find more information about the 2017 CAHPS for MIPS on the CAHPS for MIPS Fact Sheet.


April

1. Who’s in the Quality Payment Program?

You’re a part of the Quality Payment Program in 2017 if you are in an advanced alternative payment model (APM) or if you bill Medicare more than $30,000 in Part-B allowed charges a year and provide care for more than 100 Medicare patients a year. You must meet the minimum billing and patient requirement to participate in the QPP in 2017. If you are below either requirement, you are not in the program.  To be eligible for the Merit-Based Incentive Payment System (MIPS), you must also be a:

  • Physician
  • Physician assistant
  • Nurse practitioner
  • Clinical nurse specialist
  • Certified registered nurse anesthetist


If 2017 is your first year participating in Medicare, then you will not be in the MIPS track of the QPP.
CMS is using the Low-Volume Threshold Assessment Period from Sept. 1, 2015 through Aug. 31, 2016. If a provider falls below the requirement of $30,000 billed to Medicare in allowable charges OR does not see at least 100 individual Medicare Part-B patients during that assessment period, CMS will notify the provider in a letter that he or she is exempt for 2017 performance reporting.

2. What are the options to report under the MIPS track for 2017?

Your options on how you report your performance data for MIPS is dependent on whether you report as an individual or as a group. You will only be able to report quality data using your Medicare claims data as an individual. You will need to submit as a group to use the CMS web interface. Individual and group reporting can be done through an electronic health record, registry, or a qualified clinical data registry.

3. What is the difference between reporting as an individual and reporting as a group?

Individual reporting: If you submit MIPS data as an individual, your payment adjustment will be based on your performance. CMS defines “individuals” as EPs who have a single national provider identifier (NPI) tied to a single tax identification number. These EPs will send their individual data for each of the MIPS categories through an electronic health record (EHR), registry or qualified clinical data registry. You may also send in quality data through your routine Medicare claims process.

Group Reporting: If you submit MIPS data with a group, the group will receive one payment adjustment based on its performance. A group is defined as a set of clinicians (identified by their NPIs) sharing a common tax identification number no matter the specialty or practice site. Your group will send in group-level data for each of the MIPS categories through the CMS web interface or an EHR, registry, or a qualified clinical data registry. To submit data through the CMS web interface, you must register as a group by June 30.

4. If our practice does not have an EHR, what are our options for reporting in 2017?
If you do not have an EHR, your only option is to report as an individual using claims data. For more information on how to submit claims data, click here.

5. Where do I go for help?

You are not alone! There is support available to you through the Colorado QPP Coalition.