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 QPP 2018 Action Plan to provide you with the necessary information, steps and organization to get you from preparation to data submission. First things first:
- Create a Team: Educate yourself
- Take Action
Confirm you are a MIPS eligible clinician (EC). Kareo has the technology to confirm you will be subject to MIPS in 2018. 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?
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 are willing to meet weekly to check 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 your MIPS Advancing Care 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, Advancing Care Information (ACI), and Improvement Activities (IA)
- Discuss and establish your performance goals
- Determine your reporting period: 90 days or a full year for ACI and IA (Quality must be reported for a full year)
The following checklist will help you prepare for MIPS 2018. APM clinicians must work with the Advanced APM program they participate in, and follow and meet their established requirements.
- 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 Performance and Bonus measures for Advancing Care Information
- 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 for Immunization Registry Submission (if applicable)
- Register with UpDocs for Direct Messaging
- Enroll with eLabs
- Run MIPS reports bi-weekly and review in team meetings
- Modify your workflow as needed
- Select your Submission mechanisms: Qualified Registry, Qualified Clinical Data Registry, Claims Based
- Run your final MIPS Reports: Quality and Advancing Care Information
- Using your selected submission method, submit 2018 MIPS data to CMS between by March 31, 2019
- *Save a copy of your final Quality and Advancing Care Information in your MIPS 2018 Audit binder
- Prepare for MIPS 2019
*As with any other CMS incentive program, all data and reports submitted for attestation must be kept for a minimum of six years in case of an audit.
Now that you have confirmed your eligibility for MIPS 2018, created your team and have an action plan, it is time to get started!
First, create a MIPS 2018 audit binder or folder. It is best to keep a hardcopy as well as an electronic version of this folder. Your binder should include a minimum of four sections; one for each MIPS category: Quality, Advancing Care Information, Improvement Activities and Cost. The purpose of your audit binder is to be audit proof. Keep all things MIPS 2018 in it including:
- Copies of your Quality reports
- Copies of your Advancing Care Information reports
- Any documentation to support any Improvement Activities selected (reports cannot be run for Improvement Activities)
- 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:
It is important that the entire team has a general understanding of what is required in MIPS 2018; as well as a clear understanding of the consequences of not meeting the requirements. Before you select your measures for each category, you must determine your submission method as well as your reporting period for ACI and IA. Quality must be reported for the full 2018 calendar year. Things to keep in mind:
- Submission Methods: QCDR, Registry, Claims (only for quality)
- Your reporting period for Advancing Care Information and Improvement Activities
- If your submission method is via QCDR or registry, you must select measures that are supported by Kareo Clinical
At this point, you are ready to make your measure selections for each category. This might also be a good time to review the MIPS Quality Dashboard and MIPS Advancing Care Information 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.
Advancing Care Information
A clinician’s goal for the ACI 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. As in the Quality report, each measure is a link that can be clicked on to see the step-by-step guide. It is easy to forget or miss a required step. For this reason, ensure that each team member reviews the step-by-step guides for the ACI measures too.
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. For groups with 15 or fewer clinicians, non-patient facing clinicians, and/or clinicians located in a rural area, medium-weighted activities are worth 20 points and high-weighted activities are worth 40 points. To achieve the maximum score of 40 points, a MIPS eligible clinician may select either of these combinations:
- 1 high-weighted activity
- 2 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 6 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 cannot run a report to prove you met a selected Improvement Activity.
The Cost category was eliminated for the 2017 Transition year. However, it was added back for 2018 and was given a weight of 10% of the overall MIPS score. This category does not require any 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 also the best time to define an action plan and work on improving measures that do not have an ideal score. Ask the following questions during your team meetings:
- How can the score for measure XYZ improve?
- Who is the clinician or staff member who usually documents for that measure?
- Should the identified person revisit the guide for a specific measure they are responsible for 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 scores?
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 2nd to March 31st, 2019. It is crucial that you:
- Run your final Quality report for the full 2018 calendar year
- Run your final Advancing Care Information report for the reporting period of your choice
- Select and reach out to your submission registry
- Place copies of your reports in your MIPS 2018 audit binder
- Submit your MIPS 2018 data to CMS by March 31, 2019
Congratulations, you did it!