Upload
others
View
1
Download
0
Embed Size (px)
Citation preview
7/6/2017
1
PART I: BASICS OF VALUE-BASED PAYMENTAdele Allison, Director of Provider Innovation StrategiesJuly 26, 2017
2
DISCLAIMERThe enclosed materials are highly sensitive, proprietary and confidential. Please use every effort to safeguard the confidentiality of these materials. Please do not copy, distribute, use, share or otherwise provide access to these materials to any person inside or outside DST Systems, Inc. without prior written approval.
This proprietary, confidential presentation is for general informational purposes only and does not constitute an agreement. By making this presentation available to you, we are not granting any express or implied rights or licenses under any intellectual property right.
If we permit your printing, copying or transmitting of content in this presentation, it is under a non-exclusive, non-transferable, limited license, and you must include or refer to the copyright notice contained in this document. You may not create derivative works of this presentation or its content without our prior written permission. Any reference in this presentation to another entity or its products or services is provided for convenience only and does not constitute an offer to sell, or the solicitation of an offer to buy, any products or services offered by such entity, nor does such reference constitute our endorsement, referral, or recommendation.
Our trademarks and service marks and those of third parties used in this presentation are the property of their respective owners.
© 2016 DST Systems, Inc. All rights reserved.
7/6/2017
2
3
AUDIENCE ENGAGEMENT
• Take out your smartphone
• Login to Pollev.com/adele
• On word clouds, please text answers in single responses (e.g., SingleResponses)
4
• Value-Based Payment (VBP)• MACRA Final Rule• Merit-based Incentive Payment System• Advanced APMs• Questions
AGENDA
7/6/2017
3
5
Claims Data
Voluntary Clinical Reporting
Pay-for-Reporting
Pay for Higher “Value” Value = f (Quality + Efficiency)
MACRA – 2 Payment PathsAlternative Payment Model or MIPS
FEDERAL REFORM
Reform Paradigm Shifts• Delivery → Prevention, Health and Patient-
Centeredness
• Payment → Redesign Compensated
• Data → Distribute and Move Information
Affordable Quality Health Care
6
“REPEAL OBAMACARE”
• President Donald Trump – FY2018 Proposed Budget –May 23, 2017
$69B in HHS discretionary authority
No direct Medicare cuts, but “streamline” appeals
Funding hits: State Medicaid funding (-$610B over 10 years), CHIP (-$19.7B over 10 years), NIH (-$5.7B and AHRQ would be rolled in), FDA (-$854B), CDC (-$222M), ONC (-$22M)
• Payment Innovations will continue
− Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) → Bipartisan, Bicameral
− Mandates traditional Medicare provider payment reform
− However, less prescriptive from federal government
7/6/2017
4
7
MACRA
• Enacted April, 2015
• Bipartisan, Bicameral Medicare Cost Containment law
• Mandates 2 Medicare VBP Provider Payment Paths:
‒ Merit-based Incentive Payment System (MIPS) – Payment differentially based on measures of Quality & Value
‒ Advanced Alternative Payment Models (APMs) – Risk-based contracting with Providers for defined services
• Performance begins 2017 for statutory effective date Jan. 2019
8
1. Condition-Specific Population-Based Payment
2. Comprehensive Population-Based Payment
3. Integrated Finance & Delivery System
1. Alternative Payment Models (APMs) with Upside Gainsharing
2. APM with Upside Sharing & Downside Risk
1. Pay for Infrastructure & Operations
2. Pay-for-Reporting
3. Pay-for-Performance
4. Performance Rewards and Penalties
4 CATEGORIES OF VALUE-BASED PAYMENT (VBP)
Category 4Population-Based Payment (PBP)
Category 3Alternative Payment Built on FFS Architecture
Category 2FFS Linked to Quality & Value
Category 1FFS No Link to Quality & Value
Starting Point
Advancing Provider Alignment Creates Data and Operational ComplexitiesSource: HHS Health Care Payment Learning & Action Network, Financial Benchmarking White Paper, Feb. 2016
7/6/2017
5
9
PREDOMINANT PAYMENT REFORM MODELS
• Medical Home Incentives
• Care Management Fees
• Value-Based Payment Modifier (VBPM)
• Pay-for-Performance/Incentives
• Shared-Savings with PCMH / ACOs
• Accountable Care Organizations
• Bundled Payments
• Episode-Based Payment (e.g., OCM)
• Full/Partial Capitation + Performance
FFS
+ Q
ualit
y M
easu
res
Ris
k-B
earin
g
Category 2
Category 3
Category 4
Transform
ation from
Productivity M
gmt. to H
ealth-Value M
gmt.
10
MACRA 2018 PROPOSED RULE
• 2018 proposed rule released June 20th
• Industry hoping for repeat transition year –
• CMS Rule theme → “Reduce the Burden”
• However, increased “low volume” threshold → 40% reduction in eligible clinicians
• CMS Fact Sheet: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Proposed-rule-fact-sheet.pdf
7/6/2017
6
11
QPP HIGH-LEVEL 2018 PROPOSALQPP Area Flexibility Policy
Merit‐based Incentive Payment System (MIPS)
Strengthening Referral Paths “Virtual Group” option
Low‐Volume Thresholds Exemption if Medicare Part B volume is ≤ $90,000 or fewer than ≤ 200 patients (2018);
possibly adding # of billed services/items by 2019
EHR Allow 2014 CEHRT, Encourage 2015 CEHRT
Bonus Points Complex Patients, 2015 Edition CEHRT
Quality Scoring Incorporate performance improvement in calculation
Facility‐based Clinicians Facility‐based scoring option
Small Practice Clinicians Hardship exception under Advancing Care Information
Bonus point to the final score
3‐Points under quality performance when data completeness not met
Advanced Alternative Payment Model (A‐APM)
Nominal Amount of Risk Standard Extend the 2 year rate – 8% of Medicare A & B – for an additional 2 years until 2020
Slow the increasing of risk amount for Medical Homes
All‐Payer Combination Option Additional details set forth for PY2019
APM Scoring Standard Reduced burden for MIPS APM participants
12
• Value-Based Payment (VBP)
• 2017 MACRA Final Rule• Merit-based Incentive Payment System• Advanced APMs• Questions
AGENDA
7/6/2017
7
13
MACRA BY THE NUMBERS• 95 – Pages long
• 31 – “Reasonable Cost Reimbursement”
• 18 – Risk
• 27 – EHR or Technology to Manage, Measure and Report
• 8 – Meaningful Use
• 38 – Quality Measures
• 19 – Resource Use or Efficiency
• 171 – “Measures” or “Measurement”
• 103 – Data
14
PREDOMINANT PAYMENT REFORM MODELS
FFS
+ Q
ualit
y M
easu
res
Ris
k-B
earin
g
Category 2
Category 3
Category 4
MA
CR
AQ
uality Payment Program
(QPP)
Merit-Based Incentive Payment System (MIPS)(2017 Perform, 2019 Payment)
Advanced APM (A-APM)
• Medical Home Incentives
• Care Management Fees
• Value-Based Payment Modifier (VBM)
• Pay-for-Performance/Incentives
• Shared-Savings with PCMH / ACOs
• Accountable Care Organizations
• Bundled Payments
• Episodes of Care Groupers
• Full/Partial Capitation + Performance
7/6/2017
8
15
FINAL RULE – 2017 TRANSITION YEAR
CMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Released to Office of Federal Register, October 14, 2016
MIPS – Penalty Avoidance
MIPS – Delayed Start
MIPS – Ready to Go
Advanced Alternative Payment Model
Submit by Mar. 31, 2018− 90 days of data between
Jan. 1 and Oct. 2, 2017− 1 Quality Measure,− 1 Clinical Practice
Improvement Activity, or− 5 required Advancing
Care Information measuresR
equi
rem
ents
Submit by Mar. 31, 2018− 90 days of data between
Jan. 1 and Oct. 2, 2017− > 1 Quality Measure,− > 1 improvement activity,
and/or − > 5 required Advancing
Care Information measures
Submit by Mar. 31, 2018− “Full Year” of data− 6 Quality Measures (1
outcome) – MIPS APM Groups report 15;
− 4 improvement activities; or 2 for small, rural, HPSA or non-patient facing
−Required or up to 9 of advancing care information measures
Significant portion of Medicare patients or payments− Qualified Participant (QP)
determination “snapshot” and inclusive
− Driven by patient or pay thresholds
Opt
ions
APMs
MIPS APMs
Advanced APMs
16
• Value-Based Payment (VBP)• MACRA Final Rule• Merit-based Incentive Payment System• Advanced APMs• Questions
AGENDA
7/6/2017
9
17
MIPS COMPOSITE PERFORMANCE SCORE
CMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Released to Office of Federal Register, October 14, 2016.
Performance Year /
Application Year
Quality MeasuresResource Use
or CostImprovement Activities
Advancing Care Information
DescriptionReplaces CMS Physician Quality Reporting System (PQRS)
Replaces ACA Value‐based Payment Modifier
New category of measurement; Medical Homes and NCQA PCSR receive full credit; 93 activities available
Replaces CMS EHR Incentive Programs f/k/a Meaningful Use;
Reporting Methods
Claims, CSV, Web Interface (for group reporting), EHR, Qualified Clinical Data Registry (QCDR)
ClaimsAttestation, QCDR, Qualified Registry, EHR Vendor
Attestation, QCDR, Qualified Registry, EHR Vendor, Web Interface (groups only)
2017 / 2019 60% 0%* 15% 25%
2018 / 2020 50% 10% 15% 25%
2019 / 2021 30% 30% 15% 25%*Measured for feedback only in 2017
18
MIPS – CPS PAYMENT ADJUSTMENTS• Positive / Negative adjustments are CMS budget neutral• Scoring → “Points” earned under each category, 0-100 points• Eligible Clinicians (ECs) → perform all or none of categories• ECs performing none → Composite Performance Score (CPS) of zero
and subject to maximum negative adjustmentFinal Score Points MIPS Adjustment
0.0 – 0.75 Negative 4 percent
0.76 – 2.9 Negative MIPS payment adjustment > ‐4.0% and < 0.0% on a linear sliding scale
3.0 0.0% adjustment
3.1 – 69.9Positive MIPS payment adjustment > 0.0% to 4.0% x a scaling factor to preserve budget neutrality,
on a linear sliding scale
70.0 – 100Positive MIPS payment adjustment of 4.0% AND additional MIPS bonus for “exceptional
performance” of 0.5 percent to 10.0% on a linear sliding scale x scaling facture
CMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Table 31, Released to Office of Federal Register, October 14, 2016
2017
7/6/2017
10
19
MIPS ESTIMATED IMPACT YEAR 2019
Clinician Specialty or Type
Total MIPS Eligible TIN
/ NPIs
Total Allowed Charges
Estimated Aggregate +/-Adjustment
Per TIN / NPI Average MIPS
Negative Adjustment (Up To)
ALL SPECIALITIES 676,722 $78,454,000,000 ± $321,000,000 - $5,846.00
Cardiology 24,657 $5,172,000,000 ± $17,000,000 - $9,317.00Family Medicine 71,073 $5,802,000,000 ± $26,000,000 - $4,631.00General Surgery 18,118 $1,734,000,000 ± $8,000,000 - $5,134.00Geriatrics 3,044 $371,000,000 ± $2,000,000 - $7,717.00Internal Medicine 80,871 $9,320,000,000 ± $39,000,000 - $5,741.00Nurse Practitioner 51,004 $1,763,000,000 ± $11,000,000 - $7,379.00
Ob/Gyn 18,578 $487,000,000 ± $2,000,000 - $2,447.00Physician Assistant 42,402 $1,284,000,000 ± $6,000,000 - $8,589.00CMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Table 61, Released to Office of Federal Register, October 14, 2016
20
• Value-Based Payment (VBP)• MACRA Final Rule• Merit-based Incentive Payment System
• Advanced APMs• Questions
AGENDA
7/6/2017
11
21
27%
51%
22%
25% in APMs (Categories 3 & 4)
Commercial
Medicare Advantage
Managed Medicaid
PRIVATE APM ADOPTION & GROWTH
Sources: HHS Health Care Payment Learning and Action Network, 2016 Fall Summit, APM Measurement, October 25, 2016
• 2016 Public and Private National Health Plan Survey
• Participants→ > 128 million Americans, ~ 44% of Market− Commercial → 26 health plans, 90 million lives, 44% of market
− Medicare Advantage → 23 health plans, 10 million lives, 58% of MA market
− Managed Medicaid → 28 health plans and 2 states, 28 million lives, 39% of Medicaid
2015
62%15%
23%Legacy Payments(Category 1)
FFS linked to Quality(Category 2)
APMs (Category3 & 4)
2016
22
CMS APM vs. A-APM
CMS Alternative Payment Model (APM)
CMS Advanced Alternative Payment Model (A‐APM)
There is a difference!
7/6/2017
12
23
2-PART QUALIFIER FOR A-APMs
Nominal Risk Standard
Volume Threshold
24
VOLUME THRESHOLD
• Non-advanced APM− Volume threshold < 25% of Part B
payments; or < 20% of Medicare patients
• Advanced APM− Volume threshold ≥ 25% of Part B
payments; or ≥ 20% of Medicare patients
7/6/2017
13
25
FINANCIAL REWARDS
• Non-advanced APM or MIPS APM− APM-specific Rewards
− MIPS Opt-In – Collective Scoring
• Clinicians Scored Individually• Scores averaged across APM• Average score applied to all APM clinicians subject to MIPS
− MIPS Opt-Out – No Scoring
• Advanced APM− APM-specific Rewards− Lump sum incentive of 5% of Medicare payments− Qualified Participants (QPs) not subject to MIPS
• Not in APM− MIPS Rewards (or penalties)
Earning more than
fee schedule
1
2
3
26
JUST REMEMBER …
We’re all in this together –by ourselves!
‐ Lily Tomlin