QPP Frequently Asked Questions

Since last year, we’ve been actively in pursuit of 2015 Edition EMR certification (CEHRT). This started with understanding the CMS requirements for what providers need to do for MIPS, as well as what the ONC requires from EMR software to be certified to assist providers in not just meeting – but exceeding – both Medicare Quality Payment Program (QPP) and Medicaid EHR Incentive Program requirements. We’re actively in the process of certification testing with certifying body Drummond and expect to have our MicroMD EMR 201 5 Edition certified Version 13.5 listed on the Certified Health IT Products List (CHPL) in May.

Representatives from MicroMD departments (Executive, Marketing, Product Management, Development, Client Support, Training, Client Success) participate in a QPP Task Force. The MicroMD QPP Task Force is busy launching and creating new client-focused MIPS educational resources, including webinars, eBooks, and Blogs, as well as reminder and operational communications, MIPS guides for maximizing payment adjustments, and programs for self-study, group webinars, and client-specific training. Be sure to register for MicroMD Client Alert emails to be kept in the loop. To add contacts to receive Client Alert emails, click here.

First, practices and providers should visit the CMS QPP website. The site is filled with information and tools to learn about the program, including provider eligibility, reporting categories, measures, reporting methods and scoring rationale. Be sure to scroll to the bottom of the page to “Subscribe to Email Updates”. Practices should start by determining how invested they want to be in the 2017 QPP transition year. For MIPS, CMS is offering a “pick your pace” option where Eligible Clinicians (ECs) can opt submit a minimum “test” submission for each of the MIPS categories (Quality, Improvement Activities and Advancing Care Information) to simply avoid the negative payment adjustment. ECs that are interested in a positive payment adjustment will need to understand the scoring requirements for each of the MIPS categories and determine what makes sense for them to tackle. Next, select appropriate Quality measures, Improvement Activities (IAs), and which Advancing Care Information (ACI) measure set to pursue. Also, target your reporting period. Do you plan to meet the “test” submission, submit 90 days or measures or more? Determining your reporting method in advance is also a good idea as some QPP reporting registries have tools that allow you to monitor and track your success with Quality measures, etc. Then connect with your EMR vendor to confirm their MIPS and EHR Incentive Program plan.

MicroMD clients with ECs that opt to pursue the Advancing Care Information Objectives and Measures (versus the 2017 Advancing Care Information Transition Objectives and Measures) within the Advancing Care Information (ACI) category will need to upgrade to the MicroMD EMR 2015 Edition certified (CEHRT) version in order to access additional functionality for this measure set that will only be available in the 2015 Edition CEHRT. Additionally, the 2015 Edition CEHRT will also include updates to the reporting and dashboard areas that will allow users to be able to select reporting for either MIPS or the CMS EHR Incentive Program.

Be sure to register for MicroMD Client Alert emails to stay in the know on educational resources, training opportunities, and version releases that can assist in meeting QPP requirements. Client should also ensure they are accessing and exploring product documentation, training and support materials to understand how MicroMD EMR works for Quality measures, selected IAs and ACI measures. To add contacts to receive Client Alert emails, click here.

• Quality Category
  The Quality Category will be based on our current certified clinical quality measures. Training and documentation will be available to walk clients through how and where to enter the appropriate data for the specific measures they chose within MicroMD EMR. The clinical quality measures dashboard will allow clients to run reports and track their numbers for their chosen measures during the reporting period.

• Improvement Activities
  MicroMD will provide a list of recommended improvement activities along with some education on how to capture and store the appropriate data where applicable. We would also look for a way to help the practice keep track of the list of activities that are chosen for each provider.

• Advancing Care Information
  Training and documentation will be available through MicroMD to walk clients through how and where to enter the appropriate data for both the ACI and the ACI transition options. MicroMD will also provide a dashboard that enables clients to track their progress in each of the ACI criterion to ensure that they are meeting their goals.

For the MIPS Quality category, MicroMD EMR individual and group-level data reporting may be accomplished through either EHR direct submission of a QRDA III file through Version 13.5 or through our integrated ReportingMD qualified registry submission. Group Web Interface for groups of 25+ ECs is not available through MicroMD EMR. The Advancing Care Information (ACI) and Improvement Activities (IA) categories will be reported via attestation per CMS requirements once released.

Eligible Clinicians (ECs) have a “pick your pace” option under MIPS in 2017 that will allow them to avoid the negative payment adjustment, although without a certified EMR they will be at a disadvantage as they will not be able to secure positive payment adjustments. ECs without an EMR may be able to achieve the minimum “test” submission for 2017 MIPS to avoid the negative payment adjustment by submitting 1 Quality Measure (achieved through Claims submission) OR 1 Improvement Activity (Seek one that is manual process oriented) for any point in 2017.

MIPS eligible clinicians that want to earn a positive payment adjustment must use certified electronic health record technology (CEHRT) to report to the Advancing Care Information (ACI) Performance category. If they do not have a certified EHR, they must meet certain criteria in order to qualify for a reweighting of the performance category to 0% so that it is not included in the total score. Simply lacking CEHRT is not sufficient to qualify to have the Advancing Care Information Performance category weight to be set at 0% of the MIPS final score. MIPS ECs without EMR that could meet the requirements for the Quality category through PM Claims-based submission AND the Improvement Activities (IA) – if there are enough IA measures that can be done without an EMR – but that do not have EMR COULD be eligible to have the ACI category reweighted IF they meet the following requirements:

A MIPS eligible clinician’s performance score may be reweighted for the following reasons:

1. They apply for reweighting, citing one of three specified reasons:

• Insufficient Internet Connectivity
• Extreme and Uncontrollable Circumstances
• Lack of Control over the Availability of CEHRT

These MIPS eligible clinicians must submit an application for CMS to reweight the Advancing Care Information performance category to 0%. More information about the application will be available in 2017.

2. They are one of the following MIPS eligible clinicians that qualify for an automatic reweighting:

• Hospital-based MIPS clinicians
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Clinicians who lack face-to-face interactions with patients

These MIPS eligible clinicians can still choose to report if they would like, and if data is submitted, CMS will score their performance and weight their Advancing Care Information performance accordingly.

For these two groups of MIPS eligible clinicians, CMS will reweight the category to 0% and assign the 25% to the Quality performance category to maintain the potential for participants to earn up to 100 points in the MIPS Final Score.

MicroMD PM-only clients that have another EMR should follow up with their EMR vendor to ensure they will have the required EMR certification and to get connected with resources for how to meet and exceed QPP requirements. MicroMD PM-only clients that work with a vendor that may not be certified or that would like to implement EMR for the first time can contact us to discuss our 2015 Edition certified EMR to maximize positive payment adjustment for the 2017 MIPS reporting year. Contact MicroMD Client Success Manager John Webb at john.webb@henryschein.com

We have a schedule of client email communications slated for the Medicare QPP and Medicaid EHR Incentive Programs, including CMS notifications, product releases, education, training and resources to help you meet and exceed requirements and maximize your payment adjustments and reimbursements with MicroMD EMR. To add contacts to receive Client Alert emails, click here.

The 2015 Edition CEHRT of MicroMD EMR will feature over 45 2017 Quality measures across multiple specialties for ECs that opt to report their Quality category measures via direct EHR data submission with a QRDA III file or through the EMR-integrated qualified registry reporting ReportingMD Total Outcomes Management (TOM) solution. Each Quality measure is outlined for clients in a “2017 Clinical Quality Measurement Calculations” guide that includes each measure description, links to measure codes (Encounters, LOINC, referral & medication), how the measure is calculated in MicroMD, assistance with identifying which patients meet the measure, and measure exclusions & exceptions. We will also provide lists of certified Quality measures by submission type and specialty that will be available through EHR direct reporting in MicroMD EMR, through Claims-only submission in MicroMD PM, or through the ReportingMD TOM registry reporting solution.

MicroMD is integrated with ReportingMD’s Total Outcomes Management (TOM) reporting registry tool that enables ECs to have Quality data from selected measures fed automatically from MicroMD EMR to ReportingMD. The ReportingMD registry will assist ECs with nearly real-time monitoring of measure success and ensure validated data submission. Contact MicroMD Client Success Manager John Webb to explore use of the ReportingMD TOM reporting tool for the MIPS Quality measure category: john.webb@henryschein.com.

MicroMD EMR has functionality, workflows, and reporting in place for many of the 90 Improvement Activities (IAs) CMS has outlined. We will provide guidance on which IAs can be accomplished in MicroMD for successful attestation of activities under this category.

MIPS ECs must use certified electronic health record technology (CEHRT) to report to the Advancing Care Information performance category. Our 2015 Edition certified MicroMD EMR will include functionality, workflows, and dashboard reporting for selected Base, Performance, Bonus Score measures that make up the total ACI score. MicroMD will provide guidance on how to accomplish the Base, Performance, and Bonus Score measures in MicroMD EMR, as well as training programs to assist in the steps to capture data to ensure the appropriate data is captured for the calculation of the measures. Additionally, we’ll provide information on how ECs can increase their potential for positive payment adjustment by completing Improvement Activities (IAs) specified under the ACI Performance Score category.

Medicaid providers that are eligible to participate in the EHR Incentive Program will be able to use the 2015 Edition certified MicroMD EMR to complete Objective and Measure requirements for Stage 2 Modified or Stage 3.

The CMS QPP site offers a host of references and training resources. Sign up for their emails to be notified of program requirements, deadlines, and educational webinars and resources. MicroMD will be offering both group webinar and client-specific training options for understanding how to maximize MIPS participation. And be sure to register your staff to receive MicroMD Client Alert emails to stay in the loop on MicroMD QPP resources. To add contacts to receive Client Alert emails, click here.

• e-Prescribing
• Provide Electronic Access
• Send a summary of care
• Request/Accept Summary of Care (also known as Transition of Care)
• Health Information Exchange (HIE interface capability)
• View, Download and Transmit
• Patient Specific Education
• Secure Messaging
• Patient Generated Health Data
• Transitions of Care (Summary of Care)
• Clinical information Reconciliation
• Medication Reconciliation
• Syndromic Surveillance
• Public Health Registry

We’re targeting our 2015 Edition certified (CHERT) release of MicroMD Version 13.5 for May. This version will contain all the workflows and functionality to be able to complete steps and capture the required data for both MIPS Quality and ACI categories, as well as Measure and Objective requirements for the Medicaid EHR Incentive Program Stage 2 Modified and Stage 3 for 2017 reporting. Development will continue to enhance the software to improve alignment between the program names, quality measures, measure sets, objectives, etc. in both the reporting and dashboard areas. In the meantime, we’ll provide clients with crosswalk documentation to help identify the alignment between prior and current program names and requirements until clients are able to upgrade to the version that will contain the refined reports and dashboard areas.

MicroMD EMR Version 13.5 will be the version where all CQMs are certified and has the 2015 Edition Certification along with the new reporting options for the MIPS program. The new reporting options will allow practices to choose which track, ACI or ACI transition and view and track the criteria for those within a dashboard.

We’re targeting our 2015 Edition certified (CHERT) release of MicroMD Version 13.5 for May. This version will contain all the workflows and functionality to be able to complete steps and capture the required data for both MIPS Quality and ACI categories, as well as Measure and Objective requirements for the Medicaid EHR Incentive Program Stage 2 Modified and Stage 3 for 2017 reporting. Development will continue to enhance the software to improve alignment between the program names, quality measures, measure sets, objectives, etc. in both the reporting and dashboard areas. In the meantime, we’ll provide clients with crosswalk documentation to help identify the alignment between prior and current program names and requirements until clients are able to upgrade to the version that will contain the refined reports and dashboard areas.

Quality will either be through claims, EHR data which is exported out to a QRDA file and uploaded or through our certified registry partner.

Improvement Activities (IA) as it stands right now will likely be through attestation. Advancing Care Information (ACI) as it stands right now will likely be through attestation.

On October 14, 2016, the Department of Health and Human Services (HHS) issued its final rule with comment period implementing the Quality Payment Program (QPP) that is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The QPP improves Medicare by helping clinicians focus on care quality and the one thing that matters most — making patients healthier. MACRA ended the Sustainable Growth Rate formula, which threatened clinicians participating in Medicare with potential payment cliffs for 13 years. The QPP’s purpose is to provide new tools and resources to help you give your patients the best possible, highest-value care. The QPP is focused on moving the payment system to reward high-value, patient-centered care. CMS expects the Quality Payment Program to evolve over multiple years. The QPP is intended to reform Medicare payments for more than 600,000 clinicians across the country, and is a major step in improving care across the entire health care delivery system. Clinicians can choose how they want to participate in the Quality Payment Program based on practice size, specialty, location, or patient population and features two tracks:

1. Advanced Alternative Payment Models (APMs)
2. The Merit-based Incentive Payment System (MIPS)

MACRA replaced three Medicare reporting programs with MIPS (Medicare Meaningful Use, the Physician Quality Reporting System, and the Value-Based Payment Modifier). Under the combination of the previous programs, ECs would have faced a negative payment adjustment as high as 9% total in 2019, but the MACRA ended those programs, reduced the potential negative payment adjustments in the early years, and streamlined the overall requirements. While these three programs will end in 2018, if an EC has participated in these programs in the past, they will have an advantage in MIPS because many of the requirements should be familiar. MACRA defined four performance categories for MIPS, linked by their connection to quality and value of patient care:

1. Quality: Replaces PQRS – Makes up 60% of the MIPS Composite Performance Score (CPS). Each provider/practice will select 6 measures to report on. 1 of the 6 measures must be an outcome measure or other high priority measure if no outcome measure is available.
2. Improvement Activities (IAs): New (Doesn’t replace an existing program) – Makes up 15% of the MIPS CPS. Providers/practices choose activities from the CPIA inventory, which lists over 90 proposed activities. Full credit for this category for all patient-centered medical homes. MIPS APM participants can also receive IA category credit based on their Alternative Payment Model (APM) participation. Participation must be in a short list of qualifying APMs.
3. Advancing Care Information (ACI): Replaces Meaningful Use – Makes up 25% of the MIPS CPS. Scoring the ACI category will be comprised of a score for participation and reporting, which is the “base score”, a score for performance, called the “performance score” and offer an opportunity for a payment bonus called the “bonus score”

Not Scored in 2017: Cost: Replaces cost from the Value-Based Payment Modifier (VM) – This category has been weighted to zero for the 2017 transition year and will be calculated by CMS and will be based solely on claims to calculate total per capital cost for all attributed beneficiaries, Medicare spending per beneficiary (MSPB), and several episode-based measures will be used to calculate Resource Use. 2019 payment adjustments and bonuses will not be based on this category, although ECs will have the opportunity to review their performance to assist in planning for when the category is weighted and activated.

Eligible Clinicians (ECs) can begin as early as January 1, 2017 by starting to collect performance data. If an EC is not ready on January 1, they can choose to start anytime between January 1 and October 2, 2017. Whenever an EC chooses to start, they’ll need to send in their performance data by March 31, 2018. The first payment adjustments based on 2017 performance go into effect on January 1, 2019.

For the 2017 and 2018 MIPS performance periods, the following Eligible Clinician (EC) types can participate in MIPS:

• Physicians, which includes doctors of medicine, doctors of osteopathy (including osteopathic practitioners), doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors
• Physician assistants (PAs)
• Nurse practitioners (NPs)
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Any clinician group that includes one of the professionals listed above

ECs must bill more than $30,000 to Medicare AND provide care to more than 100 Medicare patients per year. Both elements of this criteria must be met to participate.

ECs must participate to potentially earn an upward adjustment and avoid a negative adjustment to their Medicare Part B payments. ECs can participate as an individual or as part of their group. ECs can pick the pace of their participation for the first performance period. If they’re ready, ECs can collect performance data beginning with services that were furnished beginning on January 1, 2017. ECs can also choose to start anytime between January 1 and October 2, 2017. ECs must submit any MIPS data to Medicare beginning January 1, 2018 and no later than March 31, 2018 to qualify for a positive or neutral payment adjustment, which will affect their 2019 Medicare Part B payments, and avoid up to a 4% negative payment adjustment in 2019.

Depending on the track of the QPP chose (APM or MIPS) and the data submitted by March 31, 2018, 2019 Medicare payments will be adjusted up, down, or not at all. The information provided below is only relevant for the 2019 payment year. CMS will provide additional information on payment adjustments for 2020 and beyond beginning next year. The options for 2017 “pick your pace” participate include:

• Do not participate: If an EC doesn’t send in any 2017 data, they’ll receive a negative 4% payment adjustment
• Submit something: If an EC submits a minimum amount of 2017 “test” data to Medicare (for example, one quality measure or one improvement activity), they can avoid a downward payment adjustment
• Submit a partial year: If an EC submits 90 days of 2017 data to Medicare, they may earn a neutral or small positive payment adjustment
• Submit a full year: If an EC submits a full year of 2017 data to Medicare, they may earn a moderate positive payment adjustment

The size of your payment adjustment will depend both on how much data the EC submits and their quality results. Note for ECs participating in the Advanced APM track: If an EC receives 25% of Medicare covered professional services or sees 20% of Medicare patients through an Advanced APM in 2017, then they will earn a 5% Medicare incentive payment in 2019.

In general, Eligible Clinicians (ECs) participating on the Medicare QPP MIPS program, regardless of the ACI measure set selected for the 2017 transition year, can use a 2014 Edition CEHRT, 2015 Edition CHERT or a combination of both, although ECs that opt to pursue the Advancing Care Information Objectives and Measures (versus the 2017 Advancing Care Information Transition Objectives and Measures) within the Advancing Care Information (ACI) category will need to upgrade to the MicroMD EMR 2015 Edition certified (CEHRT) version in order to access additional functionality for this measure set that will only be available in the 2015 Edition CEHRT. Additionally, the 2015 Edition CEHRT will also include updates to the reporting and dashboard areas that will allow users to be able to select reporting for either MIPS or the CMS EHR Incentive Program.  Eligible Professionals (EPs) participating in the Medicaid EHR Incentive Program for 2017 Modified Stage 2 can use a 2014, 2015 or combination of both. Medicaid EPs opting for Stage 3 requirements must use a 2015 Edition CEHRT.

For 2017 scoring, each provider/practice will select 6 measures to report on. 1 of the 6 measures must be an outcome measure or other high priority measure if no outcome measure is available.

• Most participants: Report up to 6 quality measures, including an outcome measure, for a minimum of 90 days.
• Groups using the web interface: Report 15 quality measures for a full year.
• Groups in APMs qualifying for special scoring under MIPS, such as Shared Savings Track 1 or the Oncology Care Model: Report quality measures through your APM. You do not need to do anything additional for MIPS quality.

ECs can start by:

1. Reviewing and selecting measures that best fit your practice, specialty, patient population and reporting method
2. Selecting up to six measures – they are listed on the CMS QPP website – including one outcome measure; if an outcome measure is not available that is applicable to your specialty or practice, you may choose another high priority measure
3. Check with your EMR vendor for guidance on steps in the software and required fields that will allow ECs to record the correct quality data for specific measures
4. Understand what’s required to meet the measures and train staff and clinicians for how to consistently capture that information in your EHR
5. Use one of the reporting methods authorized for quality measure submission (Direct EHR submission, registry or claims)

For 2017 scoring, providers/practices choose activities from the IA inventory, which lists over 90 proposed activities. Full credit for this category is given for patient-centered medical homes. MIPS APM participants can also receive IA category credit based on their Alternative Payment Model (APM) participation.

• Most participants: Attest that you completed up to 4 improvement activities for a minimum of 90 days.
• Groups with fewer than 15 participants or if you are in a rural or health professional shortage area: Attest that you completed up to 2 activities for a minimum of 90 days.
• Participants in certified patient-centered medical homes, comparable specialty practices, or an APM designated as a Medical Home Model: You will automatically earn full credit.
• Groups in APMs qualifying for special scoring under MIPS, such as Shared Savings Program Track 1 or Oncology Care Model: You will automatically receive points based on the requirements of participating in the APM. For all current APMs under the APM scoring standard, this assigned score will be full credit. For all future APMs under the APM scoring standard, the assigned score will be at least half credit.
• Participants in any other APM: You will automatically earn half credit and may report additional activities to increase your score.

ECs can start by:

1. Reviewing and select up to 4 improvement activities from over 90 available listed in the QPP website that best fit your practice, specialty and patient population; the activities are weighted as High or Medium depending on the complexity; to meet the minimum “Test” to avoid the downward payment adjustment, eligible clinicians must submit 1 High or Medium weight activity; Partial and full participation is achieved by selecting one of the offered combination of high and medium weighted activities.
2. Check with your EMR vendor for guidance on how your software can help automate and document some of the improvement activities
3. Understand what’s required to meet the activity and train staff and clinicians for how to consistently complete the activities
4. Be prepared to submit attestation via the CMS determined method

2017 scoring the ACI category will be comprised of a score for participation and reporting, which is the “Base Score”, a score for performance, called the “Performance Score” and offer an opportunity for a payment bonus called the “Bonus Score”. MIPS eligible clinicians need to fulfill the requirements of all the base score measures in order to receive the 50% base score. If these requirements are not met, they will get a 0 in the overall ACI performance category score. In order to receive the 50% base score, MIPS eligible clinicians must submit a “Yes” for the security risk analysis measure, and at least a 1 in the numerator for the numerator/denominator of the remaining measures.

• The Base Score 2017 Advancing Care Information Transition measures are:

1. Security Risk Analysis
2. e-Prescribing
3. Provide Patient Access
4. Health Information Exchange

• The Base Score Advancing Care Information measures are:

1. Security Risk Analysis
2. e-Prescribing
3. Provide Patient Access
4. Send a Summary of Care
5. Request/Accept Summary of Care

• To achieve a neutral or positive payment adjustment, ECs must fulfill the required measures for a minimum of 90 days
• ECs may choose to submit up to 9 measures for a minimum of 90 days for additional credit
• ACI Performance Score: Is calculated by using the numerators and denominators submitted for measures included in the performance score, or for one measure, by the yes or no answer submitted. The potential total performance score is 90%. For each measure with a numerator/denominator, the percentage score is determined by the performance rate. Most measures are worth a maximum of 10 percentage points, except for two measures reported under the 2017 Transition measures, which are worth up to 20 percentage points. Essentially, the better your measure scores, the higher your composite score will be for ACI.
  • Advancing Care Information Measures – Report up to 9 measures
  • 2017 Advancing Care Information Transition Measures – Report up to 7 measures

• ACI Bonus Score: ECs may also earn bonus credit for Reporting Public Health and Clinical Data Registry Reporting measures OR use CHERT to complete certain Improvement Activities. MIPS ECs can earn bonus percentage points by doing the following:
  • Reporting “Yes” to 1 or more additional public health and clinical data registries beyond the Immunization Registry Reporting measure will result in a 5% bonus
  • Reporting “Yes” to the completion of at least 1 of the specified Improvement Activities (IAs) using CEHRT will result in a 10% bonus. There are 18 designated IAs that can be accomplished under this ACI Bonus scoring, many of which can be accomplished with MicroMD EMR.

For scoring purposes, in the Advancing Care Information performance category (weighted at 25% of the total score), MIPS ECs may earn a maximum score of up to 155%, but any score above 100% will be capped at 100%. This structure was deliberately created to ensure that clinicians have flexibility to focus on measures that are the most relevant to them and their practices. The Advancing Care Information score is the combined total of the following three scores:

1. Required Base Score Measure = 50% of available ACI score; ECs MUST submit at least 1 in the numerator for each measure to count with the exception of the Immunization Registry Reporting which is a Yes/No attestation; MIPS eligible clinicians need to fulfill the requirements of all the base score measures in order to receive the 50% base score. If these requirements are not met, they will get a 0 in the overall Advancing Care Information performance category score.
2. Performance Score = Up to 90% of available ACI score; this is an opportunity for ECs to earn a positive payment adjustment; the performance score is calculated by using the numerators and denominators submitted for measures included in the performance score, or for the Security Risk Analysis measure, by the yes or no answer submitted. The potential total performance score is 90%. For each measure with a numerator/denominator, the percentage score is determined by the performance rate. Most measures are worth a maximum of 10 percentage points, except for two measures reported under the 2017 Transition measures, which are worth up to 20 percentage points. Depending on which Measure Set chosen, ECs will submit:

• Advancing Care Information Measures – Report up to 9 measures
• 2017 Advancing Care Information Transition Measures – Report up to 7 measures

3. Bonus Score = Up to 15% of available ACI score; a 5% bonus is available for being able share with data with surveillance and registry reporting organizations and a 10% bonus is available for using the CEHRT to report certain Improvement Activities.

ECs can start by:

1. Reviewing and selecting the ACI Measure Set you’ll pursue (In 2017, providers must use a certified EHR (CEHRT), for the Base Score. With 2015 Edition certified MicroMD EMR, ECs can choose either of the two measure sets
   • 2017 Advancing Care Information Transition Objectives and Measures (4 Base Score Measures): Security Risk Analysis, e-Prescribing, Provide Patient Access, Health Information Exchange
   • Advancing Care Information Objectives and Measures (5 Base Score Measures): Security Risk Analysis, e-Prescribing, Provide Patient Access, Send a Summary of Care, Request / Accept A Summary of Care
2. Choose to submit data for up to 9 measures for a minimum of 90 days for additional credit
3. Choose to participate in Bonus Scoring; review, select, and implement IAs and ensure have any required registry interfaces in place between your EMR and the registries
4. Establish target goals for Measure Performance Scoring and understand what’s required to meet the measures and train staff and clinicians for how to consistently capture that information in your EHR

Be prepared to submit attestation via the CMS determined method

In 2017, the Cost category will not be weighted for final scoring, although CMS will review the 2017 data and provide feedback for providers to prep for how to meet the requirements in 2018 and beyond when it does become a weighted category.

If an EC sends MIPS data in as an individual, their payment adjustment will be based on their performance. An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number. Individual ECs will send their individual data for each of the MIPS categories through a certified electronic health record, registry, or a qualified clinical data registry. You may also send in quality data through your routine Medicare claims process. If a practice opts to send MIPS data as a group, the group will get one payment adjustment based on the group’s 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. The group will send in group-level data for each of the MIPS categories through the CMS web interface or a third-party data-submission service such as a certified electronic health record, registry, or a qualified clinical data registry. To submit data through the CMS web interface, a group must register as a group by June 30, 2017.

MicroMD EMR client group-level data reporting may be accomplished through either direct EHR or ReportingMD registry submission.

MIPS ECs must use certified electronic health record technology (CEHRT) to report to the Advancing Care Information performance category. If they do not have a certified EHR, they must meet certain criteria in order to qualify for a reweighting of the performance category to 0% so that it is not included in the total score. Simply lacking CEHRT is not sufficient to qualify to have the Advancing Care Information performance category weight to be set at 0% of the MIPS final score. A MIPS EC’s performance score may be reweighted for the following reasons for CMS to reweight the category to 0% and assign the 25% to the Quality category to maintain the potential for participants to earn up to 100 points in the MIPS Final Score:

1. They apply for reweighting, citing one of three specified reasons:

• Insufficient Internet Connectivity
• Extreme and Uncontrollable Circumstances
• Lack of Control over the Availability of CEHRT

These ECs must submit an application for CMS to reweight the Advancing Care Information performance category to 0%. More information about the application will be available in 2017.

2. They are one of the following MIPS eligible clinicians that qualify for an automatic reweighting:

• Hospital-based MIPS clinicians
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Clinicians who lack face-to-face interactions with patients

These ECs can still choose to report if they would like, and if data is submitted, CMS will score their performance and weight their Advancing Care Information performance accordingly.

Some providers may be eligible for BOTH the Medicaid EHR Incentive Program and Medicare QPP. While participation in the Medicaid EHR Incentive Program is optional, providers considered Eligible Clinicians under Medicare QPP would need to participate in order to avoid a negative payment adjustment (or to maximize positive payment adjustment). Requirements and reporting are different for both programs, so if a provider is considering participation in both, it will be important to dig into the details of both programs.

Clinicians not included in the list of ECs won’t be subject to a positive or negative Medicare Part B payment adjustment in 2019 under MIPS. No further action is required unless your TIN decides to participate as a group and is above one of the low volume thresholds. Clinicians who are not included in MIPS now, may choose to voluntarily submit data individually to Medicare to learn, to obtain feedback on quality measures, and to prepare in the event MIPS is expanded in the future. Clinicians who submit data voluntarily will not be subject to a positive or negative payment adjustment.

Clinicians practicing in RHCs or FQHCs who provide services that are billed exclusively under the RHC or FQHC payment methodologies are not required to participate in MIPS (they may voluntarily report on measures and activities under MIPS) and are not subject to a payment adjustment. However, if these clinicians provide other services and bill for those services under the Physician Fee Schedule (PFS), they would be required to participate in MIPS and such other services would be subject to a payment adjustment.

1. MIPS Exemption for New Medicare-enrolled Eligible Clinicians: Clinicians who enroll in Medicare for the first time during a MIPS performance period are exempt from reporting on measures and activities for MIPS until the following performance period. In order to be considered a new Medicare-enrolled eligible clinician, clinicians cannot have previously submitted claims to Medicare under any other enrollment as an individual or through a group. Generally, the performance period is two years prior to the year in which payments are adjusted. During the performance period of a calendar year, CMS will make eligibility determinations using data from PECOS on a quarterly basis (if technically feasible) to identify new Medicare-enrolled eligible clinicians who will be exempt from MIPS participation for the applicable performance period.

• MIPS Exemption for Clinicians and Groups Below the Low-volume Threshold: Clinicians who bill less than or equal to $30,000 in Medicare Part B allowed charges OR provide care for 100 or fewer Part B-enrolled Medicare beneficiaries in a designated period are exempt from MIPS. CMS will conduct low-volume status determinations prior to the start of the performance period and during the performance period using claims data.  CMS is scheduled to mail letters to providers who meet the low volume threshold for 2017 MIPS exemption and indicated they will provide a website to look up that information.

For the 2017 MIPS performance period and the 2019 MIPS payment year, CMS will make low-volume status determinations based on satisfying either low-volume threshold in either one of the following evaluation periods:

• Historical claims data: September 1, 2015 – August 31, 2016
• Performance period claims data: September 1, 2016 – August 31, 2017

2018 Performance Period Determinations For the 2018 MIPS performance period and the 2020 MIPS payment year, CMS will make low-volume status determinations based on satisfying either low-volume threshold in either one of the following evaluation periods:

• Historical claims data: September 1, 2016 – August 31, 2017
• Performance period claims data: September 1, 2017 – August 31, 2018

Low-volume Threshold for Individual Participation: The low-volume threshold is calculated for each individual clinician (as identified by a National Provider Identifier (NPI) associated with a practice as identified by a Tax Identification Number (TIN) regarding billed Medicare Part B allowed charges and the number of Medicare Part B beneficiaries. For a clinician (NPI) who is associated with multiple practices (TINs), the low-volume threshold will be calculated for each practice associated with the clinician (TIN/NPI). A clinician associated with multiple practices is required to participate in MIPS for each practice association (TIN/NPI) unless the clinician does not exceed the low-volume threshold for a particular practice.

Low-volume Threshold for Group Participation: For a group electing to report at the group level (TIN), the low-volume threshold will be calculated for the group as a collective entity. If a group (as a whole) is determined to exceed the low-volume threshold, then the group would be required to participate in MIPS. If a group (as a whole) does not exceed the low-volume threshold, then the group is exempt from MIPS participation.

Low-volume Threshold for MIPS Eligible Clinicians Practicing in MIPS APMs: Similar to the low-volume threshold applying at the group level, the low-volume threshold applies to MIPS clinicians practicing as part of an APM Entity group in a MIPS APM. For an APM Entity group, the low-volume threshold will be calculated for the APM Entity group as a collective entity. If the APM Entity group (as a whole) is determined to exceed the low volume threshold, then the APM Entity group would be required to participate in MIPS. APM Entity groups that do not exceed the low-volume threshold are exempt from MIPS participation for that performance period. The exclusion will not affect eligible clinicians participating in an Advanced APM that met the Qualifying Participant determination.

MIPS Exemption for Clinicians Participating in Advanced APMs: Clinicians who participate sufficiently in Advanced APMs and become Qualifying Participants are exempt from MIPS participation. Clinicians in an Advanced APM who become Partial Qualifying Participants may choose whether or not to report on MIPS measures and activities. If Partial Qualifying Participants do not choose to participate in MIPS, they are exempt from MIPS reporting and will not receive a MIPS payment adjustment.

Yes, MIPS has special rules for certain types of clinicians. The following explains the requirements for participating in MIPS.

Non-patient Facing MIPS Eligible Clinicians: Clinicians who bill 100 or fewer patient-facing encounters (including Medicare telehealth services) during the determination period are considered non-patient facing. Groups are considered non-patient facing if more than 75 percent of its clinicians have 100 or fewer patient-facing encounters (including Medicare telehealth services). Non-patient facing clinicians and groups are required to participate in MIPS and have alternative reporting requirements for the performance categories, which account for cases where there are limited applicable measures and activities available to these clinicians.

MIPS APM Participants: MIPS eligible clinicians, who do not meet the threshold for sufficient payments or patients through an Advanced APM in order to become QPs, and who practice in a MIPS APM under the APM Scoring Standard are in MIPS and have special reporting and scoring rules. The reporting and scoring rules vary by the MIPS APM. MIPS APM eligible clinicians must be listed on the MIPS APM participant list on at least one of the three participant list snapshot dates – March 31, June 30, or August 31 to be scored under the APM scoring standard. If the eligible clinician is not on the MIPS APM participant list on at least one of the three snapshot dates, then they should report to MIPS as an individual or group.

Small Practices, Rural Area, and HPSA Clinicians: The following types of ECs/groups are only required to achieve 20 points instead of 40 points under the improvement activities performance category, in which the 20 points could be achieved by one high or two medium improvement activities:

• MIPS eligible clinicians in practices with 15 or fewer clinicians and solo practitioners
• Clinicians in designated rural areas
• Clinicians working in designated Health Professional Shortage Areas (HPSA)

• Improved beneficiary outcomes and engage patients through patient-centered Advanced APM and Merit-based Incentive Payment System (MIPS) policies
• Enhanced clinician experience through flexible and transparent program design and interactions with easy-to-use program tools
• Increased availability and adoption of robust Advanced APMs
• Promoting the program understanding and maximize participation through customized communication, education, outreach, and support that meet the needs of the diversity of physician practices and patients, especially the unique needs of small practices
• Improved data and information sharing to provide accurate, timely, and actionable feedback to clinicians and other stakeholders
• Ensuring operational excellence in program implementation and ongoing development

In addition to the QPP website, email updates, webinars, fact sheets and other educational tools, CMS has funded organizations to support both Small, Rural and Underserved (SUR) and large practices. Visit the QPP website to learn more about eligibility, services provided, and access the maps of coverage regions for these QPP technical support organizations.

• Small, Rural and Underserved Practices organization map: https://qpp.cms.gov/docs/QPP_Support_for_Small_Practices.pdf
• Large practices QIN/QIO organization map: http://qioprogram.org/contact-zones?map=qin