MACRA's Quality Payment Program (QPP) for 2018 can be intimidating, however don’t panic! Kareo EHR is here to help you on this journey to Year 2 of the incentive program payment. We’ve created the Quality Payment Program (QPP) 2018 MIPS Action Plan to provide you with the necessary information, steps and organization to get you from preparation to data submission. Let’s get started:
Check your MIPS participation status by entering your individual NPI at https://qpp.cms.gov/participation-lookup. However, you may confirm yourself by answering the following questions:
- Do you have $90K or more in Medicare Part B allowed charges?
- Do you have over 200 Medicare Part B patients?
If you are subject to MIPS, you could be eligible for an exemption. Below are some of the exemptions you might want to look into:
- You are part of an Advanced APM such as an ACO, Patient Centered Medical Homes and Bundled Payment Models
- You are newly enrolled in Medicare
- You are in your first year as a practicing clinician
- Extreme and uncontrollable circumstances
- Practice in a Small practice
Reach out to the QPP support line to learn more about any of the exemptions listed above and to find out if you qualify. You should determine if you are fully exempted from MIPS or only for the Promoting Interoperability (PI) category. In most cases, the deadline to submit an application to CMS to reweight the PI performance category to 0 percent is December 31, 2018.
Create a Team
Achieving the requirements for MIPS 2018 takes the cooperation of the entire practice, so enlist the help of the key staff members who can meet at least biweekly to check your progress and make the necessary workflow adjustments to increase your performance. The ideal team should include the eligible clinician(s), office manager, and clinical assistant. It is important to discuss roles and responsibilities, and expectations must be established.
Educate yourself and your team. Establish recurring weekly or bi-weekly meetings to learn as a team about the QPP options, requirements and important deadlines. A few key responsibilities must be assigned:
- Designate the team member who will be responsible for running the Promoting Interoperability (PI) and Quality Reports
- Decide who will be responsible for staying informed and gathering details on any upcoming webinars, newsletters, blogs, announcements sent by Kareo, or updates from CMS. This staff member should share this information in your next team meeting
- Review and select your measures for Quality, Promoting Interoperability (PI), and Improvement Activities (IA)
- Discuss and establish your performance goals
- Determine your reporting period: 90 days or a full year for PI and IA (Quality must be reported for a full year)
Let the following checklist serve as a reminder of the tasks that must be completed to help you be better prepared for MIPS 2018.
- Confirm clinician eligibility
- Determine QPP track: MIPS or APM
- Create a Team and establish roles and responsibilities, and recurring team meetings
- Create a MIPS 2018 Audit Binder
- Visit the QPP website and understand MIPS options, requirements and deadlines
- Determine your Participation option: Report as an Individual Clinician or as part of a group
- Select 6 of the supported Quality measures
- Select Bonus and Performance measures for PI (Bonus measures are required)
- Go to https://qpp.cms.gov/mips/improvement-activities and Select 2-4 Improvement Activities
- Perform a Security Risk Analysis
- Setup the Patient Portal
- Register with your state to begin the process for Immunization Registry Submission (if applicable), then open a support case with Kareo
- Register with UpDocs for Direct Messaging (unless the exclusion applies to you)
- Enroll with eLabs
- Make sure you are able to submit electronic prescriptions (open a support case with Kareo for help)
- Select your Submission mechanisms: Qualified Registry, Qualified Clinical Data Registry, Claims Based for the Quality category and or manual submission for PI and IA
- Run MIPS reports bi-weekly and review in team meetings
- Modify your workflow as needed and improving your scores
- Run and Save a copy of your final Quality and PI reports in your MIPS 2018 Audit binder
- Submit your data to CMS during the submission period Jan 1 to March 31, 2019
- Prepare for MIPS 2019
Now that you have confirmed your eligibility for MIPS 2018 and reviewed the checklist, it is time to get started! Start with creating your audit binder. It is best to keep a hardcopy as well as an electronic version of this folder. Your binder should include:
- Copies of your Quality and PI reports
- Any documentation to support any Improvement Activities selected
- A copy of your Security Risk Analysis (this one of the most important items you must keep in your binder)
- Any screenshots you took within Kareo EHR-Clinical to support any given objective
Next, refine the teams’ knowledge on MIPS 2018. The following websites are your best resources:
Determine your submission method as well as your reporting period for PI and IA. Quality must be reported for the full 2018 calendar year. At this point, you are ready to make your measure selections for each category. Things to keep in mind:
- Submission Method for Quality: QCDR, Registry, Claims (only for quality)
- Your reporting period and submission method for PI and Improvement Activities
- If your submission method is via registry, you must select measures that are supported by Kareo Clinical AND the selected registry
- If your submission method for Quality is claims, you may select from the measures listed on the QPP website
This might also be a good time to review the MIPS Quality and PI Dashboard guides found at https://helpme.kareo.com/CMS_Incentive_Programs.
Select up to six measures, including at least one Outcome Measure or one High Priority Measure. Kareo provides built-in guides for each selected measure directly from the dashboards. Each team member should carefully read and understand the steps required to achieve a good score on each measure.
A clinician’s goal for the PI category is to reach the Target Score of 100 points. The target score can be achieved by earning points in the three subcategories:
- Base Measures
- Performance Measures
- Bonus Measures
Please note: Base Measures are required and you cannot use points from the performance or bonus measures unless you meet the base measures. Each measure is a link that can be clicked on to see the step-by-step guide.
Clinicians are rewarded for care focused on care coordination, beneficiary engagement, and patient safety. Eligible clinicians may submit their improvement activities by attestation via the CMS Quality Payment Program website, a qualified clinical data registry, a qualified registry, or when possible, from their electronic health record (EHR) system. Please note, at this time, Kareo does NOT submit data directly to CMS on your behalf. There are two kinds of activities: high-weighted and medium-weighted activities. To achieve the maximum score of 40 points (20 points for small practices), a MIPS eligible clinician may select either of these combinations:
- High-weighted activities
- Medium-weighted activities
The list of Improvement Activities can be found at https://qpp.cms.gov/mips/improvement-activities. Eligible clinicians are encouraged to retain documentation for six years as required by the CMS document retention policy. Keeping this documentation in your MIPS 2018 audit binder will give you peace of mind should you be selected for an audit. Remember, you can most likely not run a report to prove you met a selected Improvement Activity.
The Cost category is new in 2018 and was given a weight of 10% of the overall MIPS score. This category does not require any additional data submission from the eligible clinician. CMS will automatically calculate the clinician’s score based on Medicare Part B claims submitted. For more information about the MIPS Cost category, visit https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.html.
Monitor Your Progress
Your team should review reports in your recurring MIPS meetings. This is the time to celebrate your year-to-date achievements and the best time to define or modify your action plan and work on improving measures that do not have an ideal score. Ask the following questions during your team meetings:
- How can we improve the score on measure XYZ?
- Should the team member responsible for the documentation of any given measure revisit the guide to ensure they are not accidently omitting a crucial step?
- Are there any other workflow adjustments the team can make to help improve the overall score?
It is important that reports are run and reviewed REGULARLY and that all items on Your MIPS 2018 Checklist are completed prior to your attestation period. Some of these items can significantly impact your scores.
Attestation Submission Period
Finally, prepare for your attestation and submission of data. The attestation submission period for the 2018 Reporting Year is January 1st to March 31st, 2019. It is crucial that you:
- Unless you reported quality via claims, run your final Quality report for the full 2018 calendar year
- Run your final PI report for the 2018 reporting period of your choice
- Gather the supporting documentation for your Improvement Activities
- Select and reach out to your submission registry. Reach out to us for the Kareo discount code if you select Covisint as your registry
- Place copies of your reports in your MIPS 2018 audit binder. Keep for a minimum of 6 years
- Submit your MIPS 2018 data to CMS by March 31, 2019
Congratulations, you did it!