Overview of the 2020 Quality Payment Program Final Rule Webinar

November 19, 2019

Hello, everyone. Thank you for joining today's overview of the 2020 Quality

Payment Program Final Rule webinar. During this webinar, CMS will provide an

overview of the final rule for the 2020 performance period of the Quality

Payment Program. After the webinar, CMS will take as many questions as time

allows. Now I will turn it over to Kati Moore, Health Insurance Specialist.

Please go ahead.

Great. Thanks, Stephanie. And good afternoon to everyone. Thank you so much

for joining us today as we're going to go through our 2000 -- 2020 Quality

Payment Program Final Rule overview that we released our final rule on

November 1st. We're really excited to have so many people on the call today.

We have a lot of great information, so we're going to keep moving through

our slides and definitely use the chat function if you have questions

throughout the presentation we have. A lot of our subject matter experts in

the room and on online to help answer questions as we're going through. And

we'll definitely have a Q&A session at the end. So you'll definitely get

opportunities to speak with us some more at the end.

So thank you all for being here. And with that, I have the pleasure of

introducing Dr. Reena Duseja, who's our Chief Medical Officer for Quality

Measurement in the Quality Measurement and Value-Based Incentives Group

within CCSQ, the Center for Clinical Standards and Quality. So thanks,

Reena.

Thanks, Kati. It's wonderful to be here today to talk with all of you. I

wanted to just provide some framing points about where we are with the 2020

final rule in terms of our approach and how we're thinking about the

direction of MIPS. And then after that, I'll turn it back to Kati, I think,

to go through some more of the details of the actual specifics in the rule.

So first, I just want to give some thoughts around the Quality Payment

Program. We know that the Quality Payment Program is an opportunity to

really take a comprehensive approach in how we think about payments instead

of basing our payment on how you bill, right? We're really looking at the

dimension of quality through a set of evidence-based measures that were

primarily actually developed by, you know, clinicians and measure stewards

to really drive toward improving the care that they're delivering to their

patients.

As a reminder, the categories within MIPS include Quality, Cost, Improving

Activities, and Promoting Interoperability. And what the program is trying

to do is encourage improvements in clinical practice and these efforts are

increased by, advances in technology that allow for you to exchange needed

information. And in addition, we have special provisions to participate in

certain new models of care that provide an alternative to fee-for-service.

So we are working toward implementing policies that you see in the rule this

year, that reward high quality treatment of patients. So really continuing

the shift toward value-based care and advanced alternative payment models.

And the goal, again, is to foster competition, choice, quality,

affordability, as well as innovation in this space. So for the 2020

performance year, we are maintaining many of the requirements from the 2019

performance year. But we also are providing some very needed updates to both

the MIPS and Advanced APM tracks. And that's really to really direct us to

continue to reduce burden but also responding to the feedback that we have

heard from the clinicians and stakeholders and also to allow us to align

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with what's required by statute. This rule does introduce and finalize this

new participation framework for MIPS in what we're calling the MIPS Value

Pathways, or MVP, which will begin in 2021.

This participation framework will unite, actually, the four categories that

I mentioned earlier and connect the measures and activities across the

categories. This, we believe, will help streamline reporting requirements,

reduce reporting burden, and again, enhance the overall cohesiveness to the

program. In addition, the MIPS Value Pathways will remove barriers to help

encourage participation in Advanced Alternative Payment Models. So this --

the goal of moving toward MVPs is also -- is an ability also to help

providers ease from the transition between the two tracks of the Quality

Payment Program. These changes will create really what we believe a more

practical and cohesive program for each clinician regardless of their

specialty or practice size, to participate within the program and really

drive toward value. Now we do recognize in what we heard from the proposed

rule and through the comments with stakeholder concerns about the MVPs’ timeline. So we are committed to a smooth transition that does not immediate

eliminate -- immediately eliminate the current MIPS framework. But we want

to engage with stakeholders to go to co-develop the MVPs. And this will

align with our goal of moving away from the siloed performance category

activities and measures toward a set of options that are meaningful to

patient care for clinicians and actable to their scope of practice.

We also know that this is really a significant shift in the way that

clinicians have potentially participated in MIPS. Therefore, I'm going to

express our commitment to work closely with the clinicians, patients,

societies, and third parties, and others to establish these Pathways. We

want to continue to develop the future state of MIPS together with all of

you to ensure that we're reducing burden, driving value through a meaningful

participation and most importantly improving outcomes for patients, so we

intend to develop these in collaboration through dialogue and additional

feedback. So you can look at the updated MVPs webpage on the QPP website.

That should be going live this week. This will include an overview video of

the MVPs and also we'll highlight future engagement opportunities.

So in conclusion, just want to reiterate we're committed to continue to

build a MIPS program that achieves our objectives in achieving high value

care in conjunction with and partnership with you. So we look forward to

that partnership as we continue to help transforming MIPS over the next

several years to ensure that we're reducing burden, we're driving value

through meaningful participation and most importantly improving outcomes for

our patients that we're taking care of. And with that, Kati, I'll hand it

back to you.

Great. Well, thanks, Reena. So next slide, please. Oh, we have skipped. One

more ahead. So we're just going to go through our agenda for today. So we'll

just go through a couple really high-level refresher slides that give you an

overview. The Merit-based Incentive Payment System or MIPS. Then we'll go

into some more details specifically about our MIPS Value Pathways that Dr.

Duseja just touched on. And then we will go through final rule of the 2020

performance period. We'll go through what policy changes we're going to see

for MIPS specifically. We'll have a couple slides on public reporting and

Physician Compare. Then we'll go over to our colleagues at CMMI to talk

through all -- our Alternative Payment Model changes for 2020. And then we

will ride it off with help and support and resources that are available and

we'll start our Q&A session. Next slide, please.

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One more. All right. So, just briefly here, we wanted to just do a quick

overview of MIPS for 2020. So, MIPS, the Merit-based Incentive Payment

System. We -- so we have -- Dr. Duseja said, we have four performance

categories in MIPS. We have Quality, Cost, Improvement Activities, and

Promoting Interoperability. And you'll get to hear more later in the

presentation, a lot more details on each of those specific performance

categories and changes that you'll see in the 2020 performance year. And

right here underneath, it just shows what -- how much each of those

performance categories are weighted for 2020. So 45% for Quality, 15% for

Cost, 15% for Improvement Activities, and 25% for Promoting

Interoperability, which adds up to our hundred percent total final score for

MIPS. And we have a later slide that goes into more detail about how that

final score percentage compares to your performance threshold and how that

eventually determines your payment adjustment for 2022. Next slide, please.

And these are just some refresher terms that we'll use throughout the

presentation just for folks that may be new to our Quality Payment Program.

And this is one of your first webinars that you're hearing us all speak

about the program, when we talk about TIN, your identification number, NPI,

National Provider Identifier. And then we use -- a lot of times we use our

TIN, NPI combination. And then the chart just shows you when we talk about

different years of the program. We typically talk about the performance year

just so people can know what year we're talking about as we're currently in

2019 performance period, which corresponds to year three of the program, and

the 2021 payment adjustment year. And then a lot of what you hear from today

is all about our 2020 performance period policies or year four that

correspond to our 2022 payment year. Next slide, please.

All right. And this is just a high-level timeline of how the program works.

So we start with the 2020 performance year, which we're going to go through

the policies for that today. And that begins on January 1st, 2020. And then

so you'll collect all your data throughout the performance year. And then

the following year in 2021 is when you submit data to CMS and then that

summer following the date of submission period, you'll receive a lot of

different feedback -- performance feedback from CMS including your payment

adjustment information and then payment adjustments start January 1st, 2022.

Next slide.

All right. So I'm going to hand it over to Molly MacHarris who’s going to get us started talking about our MIPS Value Pathways.

Okay. Great. Thank you, Kati. And thank you again everyone for being here

today. So I first wanted to talk about our MIPS Value Pathways which was Dr.

Duseja talked about earlier that is a new participation framework which will

be -- begin being available in 2021. So again not in this most upcoming year

but it would be available in year five beginning in calendar year 2021.

We've received a fair number of questions on the start date of that, so I

just want to be really clear there. So again, the MIPS Value Pathways, the

earliest those would be available for clinicians to participate in would be

in calendar year 2021. But let me back up for a minute and touch on a little

bit of detail of the problem we're trying to solve for with the MIPS Value

Pathways. So what we've been hearing from clinicians on is that while the

MIPS program is an improvement from the legacy programs of PQRS, the

Physician Value Modifier, and the Medicare EHR Incentive Program, the

structure that we have within the MIPS program still is producing a lot of

confusion for clinicians. There's too much choice and complexity when it

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comes to selecting measures and activities, the measures and activities

across the four performance categories may not always be meaningful to a

clinician specialty. And for patients, it's really hard for them to look at

the information and be able to make informed decisions when selecting their

clinician.

So while we have been making improvements within the MIPS program and slowly

increasing the requirements as required by law, for the past few years, we

do think it's appropriate to take a new approach to the program, which

moving on to the next slide, as we've already mentioned a couple times here

today is our new MIPS Value Pathways or MVPs which again this participation

framework would begin in calendar year 2021.

So what the MVPs will do is we envision the MVPs will help remove barriers

to APM participation and movement into APMs. As Dr. Duseja mentioned

earlier, we also envision what the MVPs -- there will be less siloes across

the four performance categories and instead under this new participation

framework, we will really be able to focus on value by promoting quality and

cost measures and improving activities while maintaining a foundational

layer of promoting interoperability as well as population health

administrative claims measures. So let's go ahead and move on to the next

slide.

First, some additional detail of some of the things we heard through the

comments process. With this new framework, we also intend to provide

enhanced data and feedback to clinicians. We also envision we would be able

to analyze existing Medicare information to be able to provide more

information to improve health outcomes. And as you'll see on the next

upcoming slide from our diagrams, we do also envision as we move to MVPs, we

can reduce the number of required measures and activities across the four

performance categories. I also do want to note that we heard really loud and

clear from commenters concerns on the implementation timeline and for us not

to move too far into MVPs too fast. So that's something we are very much

keeping in mind. And we also heard really loud and clear that stakeholders

you want to work with us as we develop these MVPs, and that's something we

also want to work with you on as well. We do believe that as we work to

build off the MVPs, we feel it's really critical to have stakeholder input.

Before I move on to a couple of our diagrams, I did just want to flag that

we have built out on our website qpp.cms.gov an MVPs section. So for those

of you who have not yet had a chance to go there, I highly encourage you go

ahead and do that. Again, it's at qpp.cms.gov and we have a MIPS Value

Pathways portion of that website. We also have added a brief video that

provides an overview of what the MIPS Value Pathways could look like as we

work to implement them in 2021.

So let's go ahead and move on to slide 12 to go over a diagram we've

created. So for those of you who were able to listen in to the proposed rule

engagement sessions, this diagram will look very familiar. But as you can

notice in the middle column, we have indicated that the MIPS Value Pathways

will begin in calendar year 2021. So just to briefly walk us through this

diagram, I won't spend too much time here since we have a lot of content to

cover, what we have on the left-hand side is the current structure of MIPS.

So again, we've been hearing pretty consistently from stakeholders is

there's too much choice, too many measures and activities. And as you can

see from looking at those four performance categories, the number of

measures and activities that a clinician could be required to participate in

could be upwards to 20 measures and activities. As we look to move to MVPs,

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moving to the middle column, you can start seeing closer alignment between

Quality, Improvement Activities and Cost. And we also do envision that when

we move to the MVPs where the requirements of clinicians have to comply with

across the performance categories as they become more aligned the number of

measures and activities can be reduced.

And then moving to the most right-hand side of the slide as you go to the

future state, we see an even closer alignment between Quality, Cost and

Improvement Activities while still maintaining that foundational layer of

Promoting Interoperability, population health metrics but also expanding out

to expanded performance feedback and patient reported outcomes. Let's go

ahead and move on to the next slide.

So just a brief example that we had put together of what an MVP could look

like for surgeons. Again, this is just an example, so I will just focus on

the call out box here. As you can see on the call out box, what an MVP could

look like for general surgeons, we have a few quality measures in here, a

few Improvement Activities and a few cost measures that we feel would be

applicable to surgeons. And then on the following example on the next slide,

we've also crafted an example of what an MVP could look like, for example,

an endocrinologist who is focused on their patients with diabetic care.

Again, these are examples of what MVPs could look like. We very much intend

to work with stakeholders as we work to build these MVPs out which again the

earliest that MVPs would be available for participation would be in calendar

year 2021. So that's everything I have on MVPs. Happy to take questions on

this if any of you have them during the Q&A period, but let's go ahead and

move along to the next slide so I can start talking through the specific

final policies for the 2020 year. So next slide again.

So for eligibility, overall, no changes were made to eligibility for this

year. So for 2020, again, our fourth year of the program, we have the same

eligible clinician types that existed in 2019, so physicians, PAs, NPs,

clinical nurse specialists, CRNAs. We also of course expanded our eligible

clinician types last year to include physical therapists, occupational

therapists, speech language pathologists, et cetera. So no changes from 2019

to 2020.

And then moving on to the next slide, we have no changes to our low-volume

threshold. So the low-volume threshold values are still set at the same

numbers as they were for 2019. So again, they are set at $90,000 in annual

billing providing services to 200 patients or rendering 200 services. To be

eligible, you would need to exceed all three of those values. If you fall

below all three, you are excluded.

And then if we move to the next slide, I can briefly explain our opt-in

policy which, again, no changes were made to our opt-in policy. So again,

for the 2020 year, if you meet one or more of those low-volume threshold

criteria but not all three, you would have the opportunity to opt-in to the

program if you would like to do so. So for example, if you bill a hundred

thousand annually, you render 500 services but you only see 100 patients.

That means that you would be opt-in eligible because you didn't exceed all

three of those values. You exceeded two of those so you would have the

choice to opt-in. If you decide to opt-in, you would be considered a MIPS

eligible clinician and that would include all of the opportunities that come

with that which includes the ability to achieve a positive payment

adjustment but it also includes the risks of potentially having that

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negative payment adjustment if you don't have your final score above the

performance threshold.

Let's move on to slide 19 to go -- so the last piece I wanted to touch on

for eligibility is where can you go to check your eligibility status. So we

do of course still have our participation look-up tool. You can enter your

NPI and we're able to provide information on your eligibility status. If you

have not yet used this tool, I highly encourage you to do so. We provide

this update or this ability for you to look up whether or not you're

eligible and whether or not you have any special statuses per year. So

again, I highly encourage all folks to go ahead and take a look at that.

Okay. That's everything for eligibility. Let's go ahead and move on to the

next slide and I'll start talking through some of the performance category

changes. Let's move on to the next slide again.

Okay. Great. So just to briefly touch on the four performance categories,

and we will go into all of these in more detail but just as a teaser of what

you will be hearing in coming slides. So for Quality the major changes we

made there where we did finalize our proposal to increase data completeness

to 70%. We did remove a number of our proposed measures, we had marked for

removal. But as part of further implementation of our meaningful measures

initiative we also finalized our policy to have a different benchmarking

approaches for certain measures that potentially can incentivize

inappropriate treatment. And we also finalized seven new specialties set.

For Cost we finalized our proposal to add in 10 new episode-based cost

measures and we revised the two global measures, the Medicare Spending for

Beneficiary, and Total Per Capita Cost Measures attribution methodology. For

Improvement Activities we did finalize our proposal to increase the group

threshold to 50%. The one piece I want to note there is that we finalized

that where clinicians would need to achieve that 50% threshold for any

continuous 90-day performance period during the calendar year. We also made

some updates to Improvement Activities inventory and we concluded the

studies that was available under Improvement Activities. And for Promoting

Interoperability, we kept the Query of PDMP measures optional, we remove the

Verify Opioid Treatment Agreement measure and reduced the threshold for a

group to be considered hospital-based to 75%. Again, we will be going over

more of these details or these updates and more details in coming slides.

Let's move on to the next slide for performance category rate.

So again no changes from where these rates are set for 2019. We did not

finalize our proposal to modify the Quality and Cost rates. So for 2020

Quality again will count for 45 points for your final score, Cost will count

for 15 points for your final score, and Improvement Activities and Promoting

Interoperability will both count for 15 and 25 points. Okay. Let's move to

the next slide and start talking through the Quality performance category.

Okay. Great. Thank you. So starting with the basic, so Quality still counts

for 45 points for your final score. As I mentioned during our highlight, we

did reduce the total number of measures available from last year 2019. I

think they were around 250 measures, now we have 218 measures. Again we have

continued to implement the Meaningful Measures Initiative which is really

focusing on ensuring we have measures within our program that are meaningful

to clinicians and provide value to patient. We still have our performance

criteria for quality that if you want to achieve a maximum points under

Quality you would need to select six measures. One of those measures would

need to be an outcome measure. If an outcome measure isn't available you

would need to select another high priority measure. The other examples of

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high priority measures are listed on the slide here. If less than six

measures apply, you would need to report on each measure that applies to

you. And if you find it too difficult to select your six measures from our

set of 218 measures that are available within our shopping cart we also have

created specialty sets which does a little bit more work for you where you

can just go and search by your specialties for the specialty set of

measures.

Moving on to the next slide just again some refresher basics, we do continue

to have bonus points available in the fourth year. We have bonus points

available if you report on additional outcome or patient-experience measures

after the first required outcome measure. We also have bonus points for

recording on additional high priority measures. We also have bonus points if

you use your -- if you submit data to us in an end to end fashion. And we

also continue to have our small practice bonus that is available for any

clinicians that are part of a small practice. Again you're small practice if

you have 15 or fewer clinicians and you would just need a report on one

quality measure to be eligible for that small practice bonus. For data

completeness as I mentioned previously we did increase our data completeness

threshold to 70% for all of our collection type. If on any given measure

data your data completeness threshold falls below 70%, the maximum number of

points you can achieve on that measure is one* out of ten points unless you

are part of a small practice and then you could achieve three out of ten

points. So again highly encourage all of you to report the measures on

really all of your patients so you can ensure you achieve that 70% data

completeness threshold. Moving on to the next slide.

A few updates for our measure set. Again as I mentioned a couple of times

here we have continued to implement the Meaningful Measures Framework which

is focusing on -- improving our standard of care and process measures and

ensuring the measures within our measurement set are really those that are

most meaningful and applicable to clinicians. We also have finalized some

specialty sets.

On the next slide we also, as I mentioned a couple of times here, have

finalized our increased data completeness requirements to 70%.

Moving on to the next slide we also finalized some additional measure

removable criteria specifically we would remove measures that do not meet

case minimum volume and recording volumes and that could not be benchmarked

for two consecutive years. We also would consider removing quality measures

if we determine that that measure is not available for reporting for all

clinicians including third parties.

And then moving on to the next slide, the last piece I wanted to touch on

for quality is as I've mentioned again at the highlight, we did finalize our

proposal to apply flat percentage benchmark for measures where we determine

that achieving 100% performance on the measure could result in inappropriate

treatment for certain patients. So the two measures we've identified that

this would be applying for in the 2020 year is measure number one,

Hemoglobin A1c Poor Control and measure number 236, Controlling High Blood

Pressure. So again for both of those measures at the top of that file that

would switch from being broken out based out of our reduced files and

instead at a flat percentage benchmark. And that is everything I have for

Quality, so moving on to the next slide I'm going to go ahead and turn the

presentation over to my colleague Joel Andress to talk about costs. Joel.

*Correction: you would receive zero points for failing to meet data completeness requirements

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Thank you, Molly. Good afternoon everyone, my name is Joel Andress, I'm the

Cost measure lead here at CMS. Move to the next slide please.

As Molly has already indicated for 2020, the Cost performance category will

comprise of 15% of your MIPS final score which is the same as 2019. The

primary changes for the report here in the cost performance category center

around the Cost measures set, which has now includes a total of 20 cost

measures. As before the measures are calculated using clinician claims data,

this will incur no additional reporting burden on providers. Each type of

measure carries a case number that must be met or exceeded by you or your

group in order to be scored for that cost measure. Next slide, please.

As part of the final 2020 rule, we have finalized the addition of 10 new

episode-based cost measures. We've also incorporated substantial revisions

to the Total Per Capita Cost Measure and the MSPB Clinician Cost measure.

Next slide, please.

On this slide we provide a summary of the measure changes that have occurred

from 2019 through 2020. In addition to the 10 new acute medical and surgical

episode-based cost measures, we provided the MSPB and the TPCC cost

measures. The case minimums for these measures remain unchanged from 2019,

so those remain case minimum of 20 for the Total Per Capita Cost Measure, 35

for the MSPB measure. 20 for acute medical inpatient episode-based cost

measures. 10 for surgical procedure of episode-based cost measures. Next

slide, please.

As part of the revisions to the TPCC and the MSPB we have updated their

measure attribution logic for 2020. TPCC attribution now requires a billing

of E&M services combined with either a primary care service or a second E&M

service from the same clinician group. These measures also exclude specific

clinician categories who deliver primarily non-primary care services to

ensure that they're not inappropriately attributed to this measure. The MSPB

attribution now establishes attribution differently for surgical and medical

patients. Attribution is specifically defined for individuals and groups

within the applicable measures, specifications that are available on our

site. For procedural episode-based cost measures, we attribute episodes to

each MIPS eligible clinician who renders into their service. And for acute,

in-patient medical condition episodes, we attribute patients to each MIPS

eligible clinician who bills an E&M claim line during the trigger

hospitalization under a 10, if that 10 renders at least 30% of the in-

patient E&M claim lines during that hospitalization. These attribution

methods for the episode-based cost measures are unchanged from 2019. Next

slide, please.

And now I will hand it over to Angela McLennan to discuss the Improvement

Activities performance category.

Thanks, Joel. Can we have the next slide, please? I'm Angela McLennan. I'm

the Improvement Activities lead, and I will go over the changes that we've

made to the performance category for 2020. You will see here the basics that

have remained the same. Improvement Activities still account for 15% of your

MIPS final score. We now have a total of a hundred and five Improvement

Activities as part of our inventory for calendar year 2020. The weight for

the Improvement Activities remain the same. A medium activity is worth 10

points while a high activity is worth 20 points. You will still select an

activity and attest that you completed it by selecting “yes.” And you must

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earn 40 points to receive the full Improvement Activities category score. If

you are under the category of what we call special statuses such as small

practices, non-patient-facing clinicians and/or clinicians located in rural

or health professional shortage areas, you would be able to receive double

weighting for your Improvement Activities and you would have to report on no

more than two activities to receive the highest score. Next slide, please.

So some changes that we made for 2020, we added two new Improvement

Activities while modifying seven existing Improvement Activities, and we

removed 15 existing Improvement Activities from the Improvement Activities

inventory. Next slide, please.

And here we have a little overview of some of the other changes that we've

made for 2020. We did issue a clarification on the definition of rural areas

and we increased the participation threshold for groups and concluded the

CMS study. Next slide, please.

We also made some clarifications under the Patient-Centered Medical Home

Criteria. We basically just made it more clear what that designation would

look like, what a certified - accreditation would look like for a Certified

Patient-Centered Medical Home. We've taken out the examples that we included

before because we didn't want to seem as though that we're limiting any

other accrediting organizations and we're hoping that this will streamline

things and make it a little easier for folks to understand. Next slide,

please.

We also finalized the policy for removal of Improvement Activities. Previous

years, we did not have a formal policy for this. And activity will be

considered for removal based on certain criteria listed here such as if it's

duplicative of another activity, if the activity does not align with current

clinical guidelines or practice, if there had been no adaptations of

activity for three consecutive years, or if the activity is obsolete. Those

are just a few. Next slide, please.

We've also increased the participation threshold for groups to receive

credit under the Improvement Activities category. Now, a group of virtual

group can impact on Improvement Activity when at least 50% of the clinicians

in the group or in a virtual group perform the same activity during any

continuous 90-day period within the same performance year. Next slide,

please.

And that concludes my little overview of the Improvement Activities, and

I'll now turn it over to Elizabeth Holland to go over Promoting

Interoperability.

Thank you, Angela. Next slide, please.

So, talking about Promoting Interoperability, it is 25% of your MIPS final

score. You must use 2015 Edition Certified EHR Technology. We are continuing

the performance-based scoring at the individual measure level and we

continue to have four objectives. Next slide, please.

So, for 2020 we provided to have a very light footprint for the Promoting

Interoperability performance category in that last year we did a total

overhaul of this performance category, so this year that's why there are

very few changes. We are continuing the Query of Prescription Drug

Monitoring Programs or PDMP measure as an optional measure and available for

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bonus points. And we did remove the Verify Opioid Treatment Agreement

measure. Next slide, please.

We did make a change to our definition of how we define a group to be

hospital-based. Our threshold used to be 100% of the clinicians in the group

needed to be hospital-based, and our new threshold effective in 2020 is that

more than 75% of the NPIs in the group must meet the definition of Hospital-

Based MIPS eligible clinician. Next slide, please.

So there are very few changes to our objectives and measures. As I

mentioned, the Query of PDMP will remain a yes/no. And we made that change

for 2019 and we will continue it to 2020. We will be redistributing the

points associated with the Support Electronic Referral Loops by Sending

Health Information measure to the Provide Patient Access To Their Health

Information measure if an exclusion is claimed. There are exclusions for

many of the measures that if they're applicable and claimed, the points

associated with the measure will be redistributed to another measure. We

also acknowledge that there are certain circumstances that may exist for

eligible clinicians or groups where they may be prevented from reporting on

the Promoting Interoperability performance category. And in those cases,

they can apply for a Hardship Exception. We are currently accepting Hardship

Exceptions for 2019 through December 31st of 2019. So now I'm going to turn

it over to Dr. Daniel Green and he's going to talk about Third Party

Intermediaries.

Thanks, Elizabeth. Next slide, please. And one more, please. Great. So, CMS

is focusing on improving our partnerships with our third party

intermediaries to try to help reduce clinician reporting burden, and we also

want to try to improve the services and expand the services that are

available to clinicians. So the idea is, if a clinician so chooses, they

could go to one vendor for, like, a one-stop shop to meet all the

requirements of the MIPS program. So starting in 2020 with the 2020

performance period, we are requiring a Qualified Clinical Data Registries or

QCDRs to work together to harmonize similar QCDR measures in an effort to

reduce the overall number of measures, but -- and also to allow for better

comparison among clinicians reporting on similar measure contexts. Starting

in 2021, third party intermediaries, again, such as QCDRs and Registries,

will be required to enhance their services by supporting all MIPS

performance categories that require data submission. They'll also be

required to provide enhanced performance feedback which will allow

clinicians to view their performance on a given measure, and also compare it

with others reporting the same measure. Additionally, we will be requiring

QCDR measures to be fully developed and tested prior to self-nominations, so

this will be a new requirement in 2021. Next slide, please.

So, hopefully you're able to follow along with the slides. In the 2019

performance period, QCDRs and Registries were not required to support

multiple performance categories. In fact, we only require that they report -

- be able to report Quality and if they so chose to report Improvement

Activities and Promoting Interoperability, obviously better still. But

they're only required to support one. But starting in 2021, they will be

required to provide services for the whole performance year and the

applicable submission periods. So, if they have to stop providing services

during the year, they will need to support a transition to an alternate

submission method or third party intermediary. What we don't want to happen

is we don't want clinicians to be left kind of high and dry expecting to

use, let's say, Registry or QCDRA, only to find out, let's say, in June,

10

perhaps after they've already reported, you know, five or six months’ worth of data, that that entity will not be able to report their data. So if that

comes to pass for whatever reason, we would want and require that the QCDR

or Registry that's going out of business or not supporting the data anymore

to be able to provide a smooth transition to another vendor on behalf of

that ending conjunction with that clinician. Again, Registries and QCDRs

will need to support the reporting of measures and activities in the

Quality, Improvement Activity, and Promoting Interoperability performance

categories. A third party intermediary, AKA a QCDR or Registry, may be

excepted from the requirement if their MIPS eligible clinicians, groups, or

virtual groups fall under the reweighting policies. So if for example there

were no Quality measures and then subsequently were going to have their

categories reweighted, they would not necessarily have to support that

category. Next slide, please.

So, our feedback policy for 2019, as you probably know, Registries and QCDRs

are required to provide timely feedback, at least four times per year, on

all of the MIPS Performance Categories that you're supporting for a

particular clinician or crew. Starting in 2021, the feedback will still be

required four times per year, but, again, we'll need to have information on

how your participants are performing compared to their colleagues who are

reporting the same quality action. QCDRs and Registries will also be

required to attest during the self-nomination process that they can provide

this feedback four times per year. And again, for whatever reason, your --

the QCDR or Registry cannot provide the required four feedbacks per year, we

would ask the vendor to notify CMS straight away. Again, as you know, part

of the program, while we measure and give feedback to clinicians on the

Quality and Cost, and Improvement Activities, as well as Promoting

Interoperability, clinicians only have an opportunity to improve if they

know about that data during the performance year, and if they're not doing

as well on a particular metric, it gives them the opportunity to try to do

better on it for the remainder of the year. Waiting a year and a half to get

that information obviously goes against the goals of the program. All right.

So let's -- next slide, please.

Let's talk about the QCDR measure requirements. So in 2019, we did require

that measures be beyond the measurement -- measure concept phase of

development for self-nomination. Starting in 2020, we created some new

guidelines to help QCDRs better understand which measures are likely to be

rejected during their annual self-nomination process. So, instances where

there are multiple or similar QCDR measures that are self-nomination, we may

provisionally approve both those measures for one year with the condition

that the QCDRs address certain areas of duplication with their -- with the

other QCDRs reporting the same measure basically to harmonize the measure so

that for the subsequent year, the measure will hopefully have input from all

of the people wanting to report it, or have -- who have submitted a similar

measure concept, and they will harmonize the measures. We will not allow

duplicative QCDR measures, we will not approve all of them beyond the one

year provisional approval, and that's only to allow folks time to harmonize

with similar measures. We also are not looking for measures that split a

single clinical practice or action into several measures that focus -- and

especially if they focus on rare events, but even -- that split one action

into multiple measures. So if there were a measure, for example, on hand

pain, we would not expect that the measure be split out to the index finger,

the middle finger, the fourth finger, and the pinky. It would be hand pain.

11

Similarly, we will not approve measures that occur -- that have -- that

surround rare or never events. We had a measure submitted once about fires

in the operating room, we would all agree that that's a bad thing. However,

in the QCDR's experience, there were only three fires in 21 years. That's

not good enough to discern one institution's Quality performance as compared

to another, it's more of a happenstance. So those are measures, for example,

that we would not approve. We're also looking for measures to be -- have a

little bit more -- that drive quality more than just simple checkbox

measures with no actionable quality measure. If there is a measure in the

program for two years or more, and it has failed to reach benchmarking

thresholds due to folks not reporting the measure, that measure also may be

eliminated or not approved in the subsequent year. Obviously, if the science

changes behind the measure, we would expect the measure to keep up with it,

or if the measure is considered low-bar, or not robust enough. Again, those

are the other examples where we might reject a measure. And then finally,

measures that have -- that are -- have attribution issues or whether quality

action is not under the purview, or direct control, if you will, of the

specific clinician or group, those measures also may be rejected. So

incidents measures, for example, are tough measures to get through the

program. Next slide, please.

So again, starting in 2021, the QCDRs have to identify a linkage between

their QCDR measures at the time of self-nomination to a cost measure,

Improvement Activity, or CMS-developed MVP as possible. The measures have to

be fully developed, as I mentioned earlier, and completed testing, and ready

for implementation at the time of self-nomination. So we'd want a QCDR to

submit a measure for self-nomination, we approve it, and then they're now

ready to collect data on it January of the subsequent year. So we are

looking for QCDRs to collect data on QCDR measures prior to submission in an

effort to make sure, again, it is collectible and useable. Excuse me. If CMS

determines that a QCDR measure is not available to MIPS eligible clinicians,

groups, and virtual groups reporting through other QCDRs, we may not approve

the measure. So in other words, the measure would be to be made available to

other QCDRs for their use, and you may need to enter into a license

agreement, and we are certainly not policing that, except for the fact that

you do have the license agreement, but the details of that would be subject

to the agreement between the two parties. Again, just as a reminder, if the

measure doesn't meet the case minimum and recording volumes for benchmarking

for two consecutive years, it may be eliminated. In certain instances, we

may allow for a plan to be submitted in terms of how the QCDR plans to try

to improve reporting of that measure and we will consider that for possible

continuation, depending on the contents of the plan. Next slide, please.

So rejections for QCDR measures in 2020, we did finalize guidelines, again,

to try to help QCDRs understand when a measure will likely be rejected and,

of course, this would include where there are duplicative measures in the

program, or when there's been a measure that was in the MIPS program that's

been removed or even PQRS for that matter. That would be an instance where

we would likely reject the measure. Existing QCDR measures that are topped

out, again, will likely be rejected or removed. If you collect data in the

future, as you have more people report on that measure, and it turns out

that it's not topped out in the future, again, with additional clinicians,

we will consider it when you provide that data again in the future. So QCDR

measures that are process-based or have no actionable quality action are

going to be likely be rejected and any measures that have potential for

unintended consequence to patient care, again, would be something we would

consider with [audio cut out,2 seconds] And, again, if you split a measure

12

into multiple or several measures when one measure would suffice would also

be a problem. I think that is it for my part. Thank you, Molly. I'm not sure

if the next part is yours or not.

Yes. That goes back to me, okay. And next slide, please. Okay. Just a few

other items on MIPS and then we're going to touch on Physician Compare, and

then we're going to discuss APMs, and then we'll open it up to the Q&A. So

as folks can see on the slide here, the performance threshold, we did

finalize our proposed performance threshold for you for 45 points. Again, as

a reminder, the performance threshold is the number that you want your final

score to be at or above. If your final score is at or above the performance

threshold, that means that you would not be getting a negative payment

adjustment and that means you would be getting a positive or a neutral

adjustment. I also wanted to note, as reflected on the slide here, beginning

in 2020, and for all future years of MIPS, the total amount of payment we

can distribute is up to nine percent, subject to a scaling factor. So let's

move on to the next slide, and I can explain that in a little bit more

detail.

So as folks can see on this slide here, moving up the table on the right-

hand side, so the 2020 side of things. If your final scores are anywhere

above 45 points, you will be getting a positive adjustment. If your final

score is at or above 85 points, not only would you be getting the payment

adjustment that is subject to budget neutrality, you also would be eligible

for that exceptional performer bonus. Remember that exceptional performer

bonus is only available for the first six years, and we have five hundred

million we can allocate annually. So, that will go away after performance

period 2022, if my math is correct. So then still going down that table, if

we look towards the bottom rows, so you can see that if your final score is

anywhere below 44.99 points, we, unfortunately, would have to give you a

negative payment adjustment. And you can see that if your final score is

anywhere between 11.25 points or lower, your payment adjustment would be a

negative nine percent. Again, by law, we have to provide clinicians whose

finals scores are on the lowest quartile the maximum negative adjustment. I

also wanted to note that we did also finalize the 2021 performance threshold

and exceptional performer bonus as 60 points and 85 points, so that is

something folks can track to as they participate in this upcoming year. So

let's move on to the next slide and then the next slide again just to

briefly touch on a few other MIPS items.

So we did also finalize a new reweighting policy that is actually applicable

for the 2018 performance period or the 2020 payment year. So as folks know,

we have a number of reweighting policies specific to the Promoting

Interoperability performance category. We also allow for reweighting if

there are extreme and uncontrollable circumstances due to natural disasters,

such as, you know, wildfires, and flooding, and tornados. We also finalized

in this year's rule the ability for us to reweight clinician's performance

categories if we determine that data that have been submitted is inaccurate,

unusable, or otherwise compromised due to circumstances outside of the

control of the clinician or their agent. We did finalize this policy, again,

effective for the 2020 payment year, so if folks are interested in

leveraging the policy for any instances that would've impacted their

submissions for the 2018 performance period, please let us know of that by

the end of this calendar year.

13

And then moving onto the next and last slide for MIPS, we also clarified our

targeted review timeline that it's 60 days following the release of our

performance feedback.

And moving on to the next slide to talk about Physician Compare, I'm going

to turn the presentation back over to Angela McLennan. Angela?

Hi, Angela again to go over Physician Compare for you. If we could have the

next slide, please. We have some minor updates in 2020 for Physician

Compare, one deals with the final release of aggregate performance data.

This includes minimum and maximum MIPS performance category and final

scores, and will be available on Physician Compare beginning with the 2018

performance period data, available in late 2019 as technically feasible.

Next slide, please.

Also for 2020, we have the policy for Final Facility-based Clinician

Indicator. You publicly report -- publicly report an indicator if a MIPS

eligible clinician is scored using facility based measurement as technically

feasible and appropriate. Link from Physician Compare to Hospital Compare

where facility-based measure information that applies would be available

beginning with 2019 performance information to be available in late 2020.

Next slide, please. And with that, I would like to turn it over to Brittany

to discuss the Alternative Payment Models.

Thank you. So I'll start with just a little bit of background on APMs,

Alternative Payment Models are payment approaches that are developed in

partnership with our clinician communities and provide added incentives for

clinicians to provide high-quality and cost-efficient care. These APMs can

apply to specific clinical conditions, care episodes, or population, and

they may offer significant opportunities for eligible clinicians who are not

immediately able or prepared to take on the additional risk and -- financial

risk and requirements of Advanced APM participation. Next slide.

So, I'm just waiting for the slide to be -- next -- there we go. What are

the benefits of participating in Advanced APMs? For payment years 2019 to

2024, clinicians who meet these requirements are going to be excluded for

MIPS payment adjustments and will receive a five percent lump sum payment

incentive on all their Part B professional services furnished during the

calendar year immediately prior to the payment year. So this five percent

lump sum bonus is actually in addition to any other rewards or incentives

that may be offered through the APM participation itself, and it just

creates an action incentive to encourage a sufficient degree of

participation in our Advanced APMs. Next slide.

To be an Advanced APM, the payment model must meet three criteria, which are

requiring participants to use cert -- EHR technology, providing payment for

covered professional services based on quality measures that are comparable

to those used in the MIPS quality performance category, and either, be --

they must be either a Medical Home mMdel that's been expanded under CMS

Innovation Center Authority, or they have to require participants to bear a

more than nominal amount of financial risk. Next slide, please.

Here are a few terms you may hear thrown around in regards to the APM

participation. Generally, when we're talking about APMs, we refer to the APM

Entity which is the group of clinicians who have come together to join one

of these entities. Not all APMs use APM entities, in which case we will

usually refer to the affiliated practitioner. Next slide.

14

There's also the concept of MIPS APMs which are not mutually exclusive with

Advanced APMs. Many Advanced APMs are MIPS APMs, many MIPS APMS are Advanced

APMS, and through participation in a MIPS APM, if you do not achieve or not

eligible for QP status, there are certain scoring benefits within MIPS for

participation in that APM. Next slide.

So here's an overview of some final little changes related to APM in 2020.

Next slide.

So for the APM Scoring Standard, which has to do with those entities that

are scored in MIPS APMs, CMS will be allowing APM entities participating in

APM the option of reporting for the MIPS Quality performance category

through MIPS on behalf of their eligible clinicians. And the goal of this is

to offer flexibility in which measures you're being scored on, and to

improve meaningful measurements and ensure that participants are being

scored on measures that have something to do with their actual practice. CMS

has also created a MIPS APM quality reporting credit for APM participants

scored under the APM Scoring Standard where the quality data that are used

for the APM are not able to be repurposed for MIPS. Meaning that they may be

required to report Quality to the two programs separately, but an

acknowledgement of that burden, we are giving a credit of equal to 50% of

the total MIPS Quality performance category weights. Next slide, please.

So in the Advanced APM part of the house, we offer current [indistinct]

Medical Home Models. In 2019, Medical Home Models were limited to Medicare

APMs that meet this handful of criteria primarily providing primary care and

having empanelment of each patient to a primary care clinician and then four

of the list of other criteria. Next slide, please.

In 2020, we have expanded the definition of Medical Home Models to include

Aligned Other Payer Medical -- Aligned Other Payer Medical Home Models, and

this includes Pther Payer arrangements other than Medicaid arrangements. So

they're being operated by another payer other than CMS, but they have

aligned themselves with a CMS Multi-Payer Model. That is a Medical Home

Model through a written expression of alignment or cooperation with CMS and

all of this means that if you happen to be participating in an Aligned Other

Payer APM that meets the Medical Home Model definition, the billing that

happens through that Other Payer arrangement will help go towards your QP

calculation.

Next slide, please. So there's also been a clarification on the definition

of expected expenditures in a way which we're going to be calculating it

just to help ensure that we are achieving our goals of ensuring that all

Advanced APM payment arrangements have a marginal risk rate of at least 30%

with applicable exceptions for large losses according to CMS regulation.

Next slide, please.

And here again, we just have a quick summary of the changes that you'll be

seeing in the 2020 final rule regarding APMs -- specifically under the APM

Scoring Standards. So, that does it for -- that should do it for APM in the

2020 final rule and I will pass it back to Kati.

Great. Thanks, Brittany. All right. We just have I think one more quick

slide and then we'll open up for Q&A. All right. One more please. All right.

Just this slide real quick, just highlight some available resources for

small and solo practices, we still have a no-cost technical assistance that

15

is available for you all to really encourage you to reach out this

information on the slide and on qpp.cms.gov website. And then these are

really great resource to help walk you through participation in the program,

help you understand eligibility, and how to participate successfully as

possible in the program. We also -- again, we've talked about it throughout

the presentation, but qpp.cms.gov, we have a lot of our really good

resources available in the QPP Resource Library. And then throughout the

website, we have a number of different tools that'll help you understand

eligibility or how to submit data to the program. In all areas of the

program, we have a lot of information.

And then we also have our Webinar Library that's available. So, all of our

presentations -- I know some folks have asked if these slides were going to

be available, and the answer is absolutely yes. We will have them available

along with the slides, the transcript of today's presentation as well as the

recording. So, we usually typically get that posted in the next week or two

after this presentation, so be on the lookout for that. And then we have our

Quality Payment Program, our service center that has really great agents

that are ready, waiting for your calls and emails to help you answer your

questions. And then we also have the Center for Medicare and Medicaid

Innovation Learning System. And there's links on this slide to all of that

information. I think that is -- we've talked long enough and that is all the

information we have to share today. So with that, I'm going to turn it back

over to our Ketchum team on the phone to walk you all through how to answer

or how to ask your questions today.

Great. Thanks, Kati. So, as Kati said, we're now going to begin the Q&A

portion of the webinar. You can ask questions via the chat or on the phone.

So if you'd like to ask your question over the phone, please dial 1-866-452-

7887. And then if you're prompted, please provide our conference ID, which

is 244-2508. And then you can press 1 -- *1 to be added to the queue. And

then, just as a reminder, we may not be able to answer all of the questions

submitted to the Q&A box today, so, if your question is not answered, please

contact the Quality Payment Program Service Center at QPP -- at -- sorry,

qpp@cms.hhs.gov. So, to start out, we have a few questions on the MVPs.

Number one is, are the MVPs designed to be an additional option for MIPS or

will it replace the current model?

Hey, Lauren, this is Molly, I can answer that. So what we envision for MVPs

and, again, based off of the feedback we've received from stakeholders to

date, we envision that there will need to be a transition period where we

maintain our normal MIPS program and our traditional ways of participating

as we work to build out MVPs internally along with stakeholders. So, again,

MVP, the earliest that participation action will be available would be in

year five, which is 2021. And we envision that for that year and potentially

other years as well, we're still working through much of this with

stakeholders, that there would be the MIPS option as well as the MVP option.

I hope that helped clarify.

Thanks, Molly. Next question on the MVPs are, with the MVPs, are you

required to do all of the Promoting Interoperability measures?

Sure. This is Molly again. So, as we've -- as I mentioned during the

presentation today, we envision MVPs, at least for the initial years, that

they would have a foundational element of Promoting Interoperability, which

would be agnostic to, again, an MVPs. So, meaning that the Promoting

Interoperability requirement would remain consistent regardless of the MVPs

16

that a clinician would be participating in. We -- our vision also for that

foundational layer includes the population health administrative claims

measures. With that being said, these are items that we are continuing to

work through when we're engaging, and we want to continue to engage with

stakeholders as we work to develop it out. So, we're looking forward to

those future conversations as we work to build out the MVP for future role-

making. Thank you.

Great. Thank you. Can you also clarify how to opt-in, please?

Opt-in.

Sure. So for opt-in to the program under the low-volume threshold -- so,

from 2019 year, I believe we actually are -- and so let me explain overall

how to do this and then I'll let Kati give a little bit more specifics of

some additional educational materials we'll be getting out soon. So,

overall, the way that clinicians will opt-in is really by the act of

submitting data to us. So, for those of you who have gone to the lookup tool

to look at your eligibility status, you will see next to your identifiers

whether or not you could be opt-in eligible. Also, I just wanted to quickly,

as in a side flag for folks, because I saw a number of questions in the chat

on when updated eligibility information will be available both for the

remainder of 2019 as well as 2020. For the updated eligibility information

for 2019, that should be up in that tool no later than the end of this

month. and then the 2020 eligibility should start being available no later

than the end of this calendar year, so no later than the end of next month.

But getting back to the question itself, how do you opt-in, so essentially

if you have that special status next to your name as being opt-in eligible,

you simply would need to submit data to us. When you go to actually submit

data to us, there would be some indicators on whether or not if you are opt-

in eligible, you want to opt-in and you want to be become a MIPS eligible

clinician, or if you want to volunteer to submit data. If you're working

with your third party, you'll just want to make sure that they are aware of

decision so they can also communicate that to us. But I'll pause there to

see if Kati wants to add in anything more.

Yes. So, we have available right now on our QPP Resource Library, we have --

for 2019, we have our opt-in and voluntary reporting election toolkit. So,

in that, we have some information on if you're an APM entity and you want to

opt-in, the process and policies around that. And then we have a guide as

well as a factsheet, and the guide is really an operational tool that has

screenshots and walks you through specifically how you log into QPP and walk

through the process of opting in. So, everything you need is in the QPP

Resource Library if you're interested in that option.

Okay. Great. Thank you for clarifying. Next question asks, for data

completeness in 2020, I thought that large practices get zero points if they

don't meet the seventy percent data completeness. Can you just clarify what

happens to those who don't meet data completeness requirements?

Yes. This is Molly again. Thank you for asking that question. And I

apologize, I believe I misspoke to this and there was an error on the slide,

and I believe I answered the question correctly -- wrong on this in the

chat. So to clarify, I took a closer look at the role while we were talking

through here. So, yes, if you are not a small practice, and if you fail data

completeness, you receive zero points on that given measure. Again, if you

are a small practice, and you would have to have that small practice special

17

status designation of being part of a small practice that has 15 or fewer

clinicians, if you fail Data Completeness, you can get three points. But for

everyone else for that given measures, you fail data completeness, you would

get zero points. We will look to determine whether or not Data Completeness

was achieved on a measure by measure basis, so it is very possible for you

to fail Data Completeness on any given measure, but then exceed it on other

measures. So, apologies for the inconsistency there. We'll get that

clarified in our transcript, but again, it's zero points if you fail data

completeness and you're not a small practice. Thank you.

Great. Thank you. All right. Our next question is for the Improvement

Activity scene to clarify the regulation about the 50% threshold. Basically

asking, do at least 50% of providers need to perform the IA activity in the

same 90-day period? Can they perform the same IA in different 90-day periods

and can you please clarify the regulation?

They can get it during any 90-day period within the performance year as long

as it's the same Improvement Activity.

Great. Thank you. All right. Stephanie, are there any questions on the phone

line?

We do. We have a question from Bryan Gale.

Hello. For Data Completeness in 2020, is there an actual numeric minimum

number of cases that have to be submitted?

So, for our Data Completeness policy, it's at 70%, but we do also look to

ensure that 20 cases occurred, so we also look for 20 cases for the measure

as well.

And the other question is, what options are there for clinicians who want to

get involved in developing MVPs?

Sure. So, great question. As I mentioned here today, we just finalized the

framework effective for 2021. So, we intend to work with stakeholders in the

coming weeks and months to have additional opportunities for engagement with

us to develop MVPs. So, what I would encourage you and anyone else on the

phone who would like to work with us on developing an MVP, whether that's,

you know, full level working with us on developing MVPs versus you may have

clinicians or parts of your organization who may want to engage in user

testing with us on MVPs. I'd recommend to you today to ensure you're signed

up for our qpp.cms.gov's listserv because that is where we will be sending

all of the update and request for engagement with us. So please make sure

you are signed up for that. Thank you.

Thank you.

Our next question is from Jennifer Gasperini.

Hi, Jennifer Gasperini with the National Association of ACOs. Can you please

confirm that slide 70 and 74 policies do not apply to clinicians and ACOs?

We're getting a lot of questions about that.

Yes. I was just responding to that question in the chat. The APM Quality

Reporting Credit is not available for participants in SSP ACOs because SSP

Quality Reporting and MIPS Quality Reporting are one and the same thing.

18

However, the other rules on those slides has to do with the way in which

individuals or groups can report to MIPS for quality performance category

and there will be an AMP entity rolled up in all of that. Those rules would

still be applicable in the case where an SSP ACO failed to complete

reporting. And in that case, we would then look for reporting at other

levels to create an ACO level quality score rather than assigning a zero as

we had done in the past.

Thanks. It would be really helpful if you clarified that on the educational

materials. I know we're getting lots of questions about those policies.

Thanks for addressing.

Thank you.

Yeah.

All right. Great. So going back to questions from chat box. Next question

asks, is there a bonus points cap?

Sorry, Lauren. Could you repeat the question? You cut off.

Sorry. Yeah. Just asking, is there a cap on the bonus points available?

Sure. So another Quality performance category, there are caps on the bonus

points available. Typically, it is 10% of the available denominator. So for

the majority of clinicians, that would be their quality performance category

denominator is around sixty points, so typically, that would be around six

points. But it can differ on a case-by-case basis depending upon the

specific clinician circumstances. Thank you.

Great. Thank you. Next question asks, will Web Interface continue to be

available for groups of over 25?

Sorry. Can you repeat the question, please?

Of course. It asks, will Web Interface continue to be available for groups

of over 25?

Yes, it will be. The Web Interface collection type is still available for

the 2020 performance period.

All right. Thanks. Next question asks, if we are a Qualified Registry that

supports Quality measures of the QR that supports all of the categories of

an EHR, does the finalized requirement for 2021 mean that we will be

required to also support PI and IA as a QR or does our EHR support for PI

and IA suffice?

Sorry. I was talking to the mute button. And it really was responsive to my

answer, too. But you would need to be able to support -- the Registry would

need to be able to support all three activities.

Okay. Thank you. All right. Next, just in general, what help is available

for practices that are just now starting to report for the 2020 performance

year?

Okay.

19

Great. Thanks for that question, Lauren. So I would encourage -- first step,

if you're brand new to the program and trying to figure out what this

program is all about and what you need to do to participate, I would

encourage you to first go to our qpp.cms.gov website. And if you go to the

Resource Library, there's a number of general resource materials right at

the top of the page. And these are specific to, right now, 2019

participation. But if you are looking for 2020 materials, we are starting to

-- as we've just finalized our rule, we're starting to populate a lot of

different 2020 resources. We'll have some quick start guides available that

are really good first kind of intro documents to get you started in the

program. And if you're a small practice, I would -- or a small -- or solo

practice, I would encourage you to reach out to our technical assistance

that's available. They can really help you get started. And that information

is also on our website, how to contact them, or you can always contact our

QPP Service Center and they'll connect you to the right networks depending

on where you are in the country. And then if you go to our QPP Webinar

Library, we also have some more recordings of past webinars and things, help

you get started in the program. Thanks.

Great. Thank you. All right. Stephanie, do we have any more questions on the

phone line?

We do have a question from Sheila Banyai.

Hello. Thank you. You've already answered my question.

All right. That's okay. Stephanie, are there any more?

We do have one additional question. Questioner, please state your name.

This is David Kanter.

Go ahead with your question.

Yeah. In an MVP environment where presumably there are reduced quality

metric requirements, I'm trying to get a feel for the difference between a

QCDR versus a Qualified Registry. Would the representation of QCDR metrics

be as valid in an MVP environment as they are now or would those be viewed

differently than MIPS measures in an MVP context?

Sure. This is Molly. So we do believe that there is a role for a QCDR

measures as we move to the MVP framework as you saw within this year's final

rule and as Dr. Green talked about here today, we finalized the number of

policies to really ensure that the QCDR measures that we have available for

clinicians who are participating under MIPS are at the same level and at the

same testing standards as the measures that we finalize through the MIPS

measurement set that go through notice-and-comment rulemaking. So, again, we

do envision that there is a role for QCDR measures and QCDRs as well as

registries themselves as we move to the MVP framework, so that's something

that we look to continue to work with stakeholders on building that out on

exactly the specifics of that. You may recall we requested comments on this

topic in particular in the RFI last year. So I would encourage you today

that if -- again, if you have not signed up for our QPP listserv to go ahead

and do so because as I answered to the other comment or person who was

asking the question, that would be our main mechanism for future engagement

for building up the MVPs. I hope that helps. Thank you.

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It does. Can I add another question, please?

I think we have time for just one. Go ahead.

Realizing that there's a testing period now required a QCDR metrics along

with harmonization, reconciliation with other QCDR, did you see any problems

with QCDRs collaborating on measure development and testing those together,

realizing that eventually, you know, one QCDR has to be the measure steward?

But do you see any problems with measure development collaboration among

various QCDRs?

We would actually encourage measure -- or sorry, QCDR collaborations. We

think that'll lead to even a more robust measure potentially.

Great. Thank you.

Thank you.

All right. Thanks, everybody, for that. It looks like that's all the time

that we have for today. So we'll go ahead and close the Q&A. And Kati, I'll

pass it back to you to conclude.

Great. Thanks, Lauren. And thanks, everybody, for joining today and for

joining in the discussion. We really appreciate you participating. And just

a reminder, all of our slides, transcripts, and recording will be up on our

Webinar Library in the next couple of weeks. So thank you all and we'll talk

to you soon.

Thank you. This concludes today's conference. You may now disconnect.

Speakers hold the line.

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