Request a Demo: (888) 783-5280 | JRaymond@ReportingMD.com
Request a Demo: (888) 783-5280 | JRaymond@ReportingMD.com

Meet our guest client, EyeCare Service Partners

 
 
 
 
 
 
and welcome to the 2023 proposed quality payment program
changes overview webinar um i’m your moderator today i’m jessica raymond i’m the director of marketing
here at reporting md so again welcome
first we’ll just go over the agenda we’ll do a little bit of housekeeping then i will go ahead and introduce our
speakers and then we’ll get into the 2023 proposal final ruling webinar
itself touching on recap of 2022 traditional mips key dates
traditional mips proposals for 2023 mips value pathways
alternative payment models changes we’ll get into our client use case and
then we’ll finish with a q a
as far as the q a is concerned anyone that cares to ask any questions throughout the webinar please submit by
the chat box everyone will be muted and then i’m about to include some important links in the chat window and that’s
including qpp eligibility lookup cms proposed
rulemaking comment link and then a link to all the acronyms as well so i’ll make sure to get that into the chat for you
and then as far as our speakers for today we have molly mynahan who’s the vice president of operations innovation
here reporting md molly brings over 15 years of data research analysis and reporting
including spending the last 10 years with reporting md we’re also lucky to have teresa
bissonnette who’s the chief compliance and quality officer i’m with our client eye care service
partners teresa brings over 10 years of quality improvement including the last five
spent at eye care service partners
and then oh god and then yeah teresa if you want to go
ahead and touch on icare service partners sure thank you so much so i care service
partners commonly referred to as esp was founded in 2014 when
varsity healthcare partners acquired the cats and i group in maryland
and then we were recapitalized in 2017 by harvest partners and they continue as
our private equity firm to this day we’re 60 private equity owned and then 40
physician owned we are the largest national provider of vertically integrated eye care which
means we look to acquire practices that can take care of the eye across the
lifetime of an eye which entails an optical shock a medical clinic and then a surgery
center we have practices in south and central florida the mid-atlantic illinois colorado and
then northern and southern california and we manage all of those locations through our corporate office in dallas
texas okay thank you and then i will pass this
on to molly to get the webinar started hi everybody uh thanks teresa that was
great and we’re gonna come back to teresa later in the webinar so i’m excited to hear more about about her
team and about about their work um so we’re gonna start out quickly with a recap of 2022
traditional mips key dates um just to get everybody kind of in line with what’s recently been released and
what they should be kind of worried about right now um so here’s the timeline of important
events in the coming months um also gives you an idea of like what the whole year looks like
from a quality payment program standpoint and i’m going to get into what that means uh
on the next slide but uh cms basically or typically releases the prior year final performance um for
mips um and some of the advanced apms into the quality payment program portal
with incentives around mid-august so um and and i will note that cms did just
release the incentive rates for the mips year of 2021 so i
encourage you to log into the quality payment program portal and check everything in there and i’ll get into
why that’s important in a minute um so
once cms also did something a little bit different this year where they kind of released initial final feedback results
um but right now whatever is showing in the qpp portal is what cms regards as
your final score um and so you should log in to qpp check that look
at your quality look at each of the categories and make sure that everything you submitted or expected to have
submitted for your organization or organizations or clinicians
is exactly what’s showing there you don’t want to have any surprises i know
the administrative claims measures are something that nobody has really control over if you
end up having uh if you end up having enough cases to be eligible to get scored on the administrative claims
measures they just kind of show up and they can kind of throw things off a bit so that can be a surprise not a lot that
you can do in terms of a targeted review for those showing up but it’s just you
want to make sure that there aren’t any other surprises in the qpp uh so the targeted review is your
opportunity to tell cms if they did get something wrong and that window is typically open for
you know a couple months after the final feedback is released right now you have that targeted
targeted review window is open right now from now until october 21st um so i encourage you
to get in if there’s something wrong submit a targeted review to have cms um
take a second look uh so next cms releases the next year proposed
rule in july each year um the final rule is typically released
in november um sometimes early december and we will um certainly hold another
webinar to review the finalized changes at that time once the final rule is released
um so october um excuse me sorry october 2nd is the
last day to start a 90-day window um and that’s typically what a lot of people
use when they’re reporting the mips pi um and ia categories for the current
performance years some some report on the full year uh you have to report on a minimum of 90 days and your last
opportunity for 90 days starts on october 2nd in december uh cms will have finalized
the 20 um 22 mips eligibility and any updated special statuses
and what i mean by that is that there are two eligibility windows
for mips reporting the first window to determine eligibility is from october
uh of 2020 so for the 2022 performance year it’s from october 1 of 2020 to september
30th of 2021 and that also includes a 30-day claims run-out the second window because two
windows are used to define eligibility the second window is from october 1st of 2021
to september 30th of 2022 so at the end of september of 2022
cms is going to start pulling together the final eligibility and they will typically release that you
know november-ish um to give you an idea of what your um
what your true eligibility is for your clinicians or for your practices depending on if you’re reporting mips
individually or as a group um the special statuses that that can change as a result of that are um you
know if you’re considered small hospital based ambulatory surgical center based
non-patient facing those are some of the things that can change as a result of those windows
december 31st is the final date in which practices and clinicians can apply for
an exceptional perform an exceptional heart exceptional hardship those hardship applications have to be
submitted by december 31st of this year um and that’s done through this the qpp
portal there are two exception applications for 2022
one is the pi uh promoting interoperability exception application that’s been available in previous years
uh and that would essentially if you got that and it was approved it would reweight your pi category to the other
mips categories um the second is the extremely uncontrollable circumstances application this is still an option for
those that continue to be impacted from the pandemic and that exception will allow you to
have any or all of the mips categories reweighted to zero percent
um so you can move some of the category weights around uh or you can just have
all categories weighted to zero if um you want to get scored on mips for 2022 you do need to report on and get
scored on at least two performance categories so that’s the minimum number of categories
you have to get scored on in order to get a mips score so you can re-weight two categories and then have
two that you get scored on and and that’s what will determine your mips score
so finally january 1 through march 31st is the submission window every year for
mips and for some other programs as well and then essentially the timeline’s
timeline starts all over again
so i know um there was one of the questions that we received prior to the webinar it’s kind of like what is this
about give me some background um and so before i get into the rest of the
presentation i just want to take a second to give that to you and really to discuss
the contents here and what you’re going to learn um cms releases that proposed rule for the
physician fee schedule around july of each year that proposed rule goes through fee schedule updates
um any any updates to the fee schedule as well as rule changes that impact different value-based care pro reporting
programs um most of the rule impacts um revolve around the quality payment
program or i refer to it as the qpp and that encompasses traditional mips advanced
apms um and when i say apms i say i’m saying alternative payment models so all
different kinds of alternative payment models as well as mips value pathways which is new
and that’s going to be starting in 2023 and i’m going to certainly go through
that probably more in-depth than most topics today in this um this proposal
webinar so if you are negatively impacted by any of these proposals that i cover
some of them are proposals that were released in this rule some of them are things that are just finalized as a part
of the macro legislation and there’s nothing that can be changed but you can always go in and submit a comment whether you
attach your name and organization to that comment or whether you submit anonymously it’s totally up to you it’s
very simple very easy um i believe that jess is going to be adding the link to
where you can go in and submit those comments into the chat window but i will
it is a very simple process i’ve already submitted a couple of different comments this year um so i encourage you to do so
i um i expect i’ll kind of call out a couple of things that i would expect people to not be thrilled about with the
proposals i hope that gives you an idea of the background where this what this webinar
is really about so here we’re showing the um the standard category weights
and the mips payment adjustment rates for mips years 2018 to 2023
one major thing to note which is not a proposal it was finalized um
is that there is no exceptional performance adjustment in 2023
see the 2023 will only have the budget neutral payment adjustment um beyond that
the quality category is worth 30 percent ia is worth 15 pi’s worth 25 and cost is worth 30
this is your standard scoring scenario if you get an exception
or an application you can you know some of these numbers can change a little bit and um
but for the most part this is your standard scoring scenario
so breaking into the proposed updates for quality uh this is just for traditional mips
quality under standard scoring is thirty 30 um it has to be reported on
for an uh an entire 12 month period calendar year and under quality you have to report on
six measures at least one of them must be an outcome or high priority measure
and following suit with cms’s commitment to improving health equity across rural
as well as underserved communities they’re proposing to expand the classification of a high priority
measure to include health equity related quality measures so that’s good news it just means you know um
that they’re going to be making more measures that are out there that are really focused on health equity um high
priority measures so that that’s always nice to have more options
ems is proposing big changes to the inventory the quality measure inventory
um adding with the proposed edition of nine quality measures i’ll show you those in a minute
um the removal of 15 substantive changes to 75 quality
measures as well as this is one of those things that i would consider
submitting comment on cms is proposing to remove both the influenza immunization measure 110
and the pneumococcal immunization measure 111 from traditional mips reporting it would those two measures
would only be offered under the mvp’s pathway um mvps is starting in 2023.
um a lot of our practices report on 110 and 111.
if you uh you know want to voice your concern about cms proposing to remove
those from traditional mixed reporting um i suggest you submit a comment
um so the last piece for quality is just the data completeness is staying at 70
for 2023 um and that just requires at least 70 of the
eligible events for every measure quality measure that you report on is achieved in the 12-month reporting
window there is a proposal however to have that increase to 75 in 2024 and
2025. so next let’s take a look at the measures that are proposed for removal
again you can see i noted at the top in addition measures 110 and 111 would be moving to
mvps only but these are the measures that are proposed for removal
um and we’re going to be certainly letting all of our clients know which of these
measures that are proposed for removal would impact them if any of these are measures that you
rely on having every year to report on i certainly suggest you submit a comment
um and i think that we are going to be releasing the webinar recording of this so you’ll also be able to see
this list in that as well and then these are the ones proposed for
edition certainly some um some dermatology measures
um screening for social drivers of health that’s one of those health equity measures that i was talking about before
it is a high priority measures as measure as well kidney disease
and then they are adding in the adult immunization status measure as well
not a ton of changes to cover here for cost for 2023 it remains 30
12 month reporting window um it is calculated through administrative claims there’s no submission that’s done
for for cost cms takes the data and they or the the claims and they they calculate that if practices don’t have
enough cases to be scored um on enough cases to meet the threshold to be scored on any of the cost measures they won’t
be scored on cost and points will then be redistributed to the other categories uh the only highlighted cost proposal
has to do with a statutory requirement that cms has to account for
improvement in the assessment of uh the performance under cost so basically cms
needs to come up with a way to reward or show practices that they’re improving their costs
to do so cms is proposing to establish a max cost improvement score of one percent point
out of 100 starting with the 2022 performance period so that’ll be as part of this year
actually so for ia no critical changes for ia for
2023 90 day reporting window it’s worth 15 of the mips score under standard
scoring um small non-patient facing rural health professional shortage area
practices continue to get they earn double scores for each of the improvement activities that they
complete which is great um just a quick reminder that in order to receive a score for ia for completing an
ia you have to have at least 50 of the clinicians in the practice complete the ia during
the performance period and cms is proposing to remove six
add four and modify five existing ias so
for excuse me proposed for removal are these improvement activities
and propose for addition are these four
interesting new improvement activities this year so for the promoting interoperability
category it’s worth 25 it remains a at least a 90-day reporting
window so you have to report at least 90 days up to the year cms is proposing to discontinue
automatic re-weighting of the pi category for a couple of different clinician types so this is important
um nurse practitioners pas crnas clinical nurse specialists
cms is proposing to discontinue the fact that you were automatically reweighted for the pi category so again
if you want to submit a comment um please feel free to do so cms is
proposing to continue offering the automatic re-weighting for the other clinicians and organization types for
2023 um that were added in later on as well as maintain the
application-based rewaiting options so for the objective proposals um
for the different objectives for the pi category uh starting with the public health and clinical data exchange objective
cms is proposing to modify the levels of engagement for measures to combine
um if you’re looking at the measure spec this would make a little bit more sense but essentially there are three options
in 2022 um but it’s basically saying that they would combine option one and
two to include both complete registration to submit data and testing and validation into a
single option um so those make up two of the three um kind of options for
saying that you’re completing a you know for example immunization registry submission um
so for 2023 the proposal is that that you would have to complete registration and test and validate um
in order to get credit for that they’re also proposing to require
submission of the level of engagement in addition to the yes no so you can’t just say yep i do it you have to say you know
yeah it has to be within the parameters of the measure so what degree do you do you do it
so for the query of prescription drug monitoring program cms is proposing to make
that a required measure in 2023 instead of a bonus measure right now it gets you an additional bonus
points of an additional 10 bonus points um but next year cms is proposing to have it be
mandatory or required um it would then be worth 10 points again
it would also include exclusions that you could choose from if the measure isn’t applicable to uh to your specialty
they’re also proposing to expand the scope of the measure to include schedule
three and four drugs in addition to schedule two which is what it is right now
for the hie or health information exchange objective last year cms
added in the bi-directional option to that objective a lot of people actually took advantage of that for 2020
one and um for 2023 they’re proposing to add a third option for participating
for the hie objective so essentially you could report the bidirectional you could report the two older sending and
receiving hie measures or you could choose this third option which is participation in the trusted exchange
framework and common agreement which may be the worst name but it’s also known as tefka
it outlines a tesca outlines a common set of principles terms and conditions
to support the development of a common agreement that would help enable nationwide exchange of electronic health
information and that would be across all the different health information networks
so that is an additional way to get credit for the health information exchange objective
proposed um and then i like this one because it just kind of maps out quickly the scoring for the pi category and i’ve
highlighted um the measures that are proposed or proposed to have changes um so here you
can see the query of prescription drug monitoring program that becomes a
mandatory measure the two hie older measures sending and
receive receiving referral um information those go down from being 1
to 20 points each to 1 to 15. there’s still the high the
bi-directional exchange option that’s worth 30 points uh and then participation in tesca is
another option for the hie objective that’s also worth 30 points so you would basically you would select either the
two option 1 option 2 or option 3 in order to fulfill the hie objective
and then provide provider to patient exchange is now worth would be proposed to be
worth 125 points the um required immunization registry
reporting would be worth 25 points
so key takeaways for traditional mips
uh to avoid a mips penalty from performance year uh 2023 you need to
reach a 75 mip score it’s the same for 2022
they’re not changing that it would be 75 there’s no longer an exceptional performance bonus in 2023
and performance on quality measures continues to be a critical uh piece of the puzzle for mips success
especially now that the bonus points for outcome and high priority are not were removed after the 2021 reporting year
so i think this is also another one of the questions um that came in before the
webinar um about the incentive um and the possible incentive that would be for
2023. again just a reminder this is all based on the proposals um
so the possible mips roi for 2023 based on the proposed rulemaking so if
everything in the 2023 proposed rule were finalized as it relates to the
quality payment program um the mips incentive could reach up to an estimated
6.91 with a perfect score of 100. um i’m just waiting for it to get above
five so 6.91 would be great um the reason this would actually be possible
is based on there being no sweeping covet exemption offered in 2023
um i’m sure that a lot of you are you know want some kind of assurance if that
is going to be offered or not going to be offered unfortunately i wish i could give that to you but um you know based
on the language that i’m seeing in the proposed rule and other indicators um it it seems that cms is
pretty intent on offering um on not offering any complete sweepings
cobit exemption they would offer all the other hardship exemptions um you know if you
have a hurricane if you know in your area things like that um they would they would offer but all things seem to
indicate that there’s not going to be a covid a sweet sweeping cobot exemption
my guess is that if that it does change or if that if they do offer it it’s due
to the staffing shortages um you know we’re hearing that across the board uh with our practices staffing is an issue
it’s a major issue um so whether or not that would be the thing that would push them to have a
sweeping exemption for 2023 it remains to be seen but i’m not seeing
any language that indicates that they’re going to go in that direction in fact i’m seeing language that
indicates that they are buckling down and they’re going to have be pushing on these programs
um to reach what they had originally planned to reach for that with them so
back to the basics on the incentives and penalties there’s a penalty and there’s a budget neutral incentive both of which
are applied um to the claims two years after the performance so for 2023 the incentive adjustments or
the payment adjustments would be applied on all claims paid through throughout 2025.
the penalty is applied if a mips participant either doesn’t report or reports and reaches a mip score less
than 75 in 2023 the budget neutral incentive is where
incentives are paid based on the amount of penalties um from all the practices that didn’t meet the avoid penalty
performance threshold so if we use the cms scaling estimates a score between zero to 74.9 will result
in a penalty somewhere between negative 9 to negative 0.1
um the closer that you get to the 75 point avoid penalty threshold 75 that’s
a neutral payment adjustment and then 75.1 to 100 will result in a scaled
payment adjustment which we expect to be somewhere between 0 and 6.91 if all the all of the
proposals were finalized i hope that makes sense to everybody
um so the the 2023 alternative to mips is the mips
value pathways um hopefully i’m keeping this lively enough but uh this is it’s gonna get a little
a little slow in here so so do your best but this is really important these are new options um you know i think cms is
trying to do something to help organizations that are like what do we do i think one of the questions that we received before the webinar was like
what’s the most streamlined way to report and be successful it’s not a really easy answer but i know that mvp’s
is one of the things that cms is trying to do to just say like this is your specialty this is what you should this
is what you should do um it also helps them because they can then kind of create more
specialty specific benchmarking and so you can start to like see how your you
compare against your peers more so than you compare the against your entire the entire healthcare marketplace so
um with that i’m going to dig into mips mvps um i’m gonna admit like for the first
year or so mips value pathways was i was just trying to get a grip on exactly what it was
um but essentially this pathway is mvps is a framework
um it was supposed to start in 2021 it’s now finally started going to start in
2023 it is slated to be voluntary for 2023-2027
which means that starting or in 2028 mvps will if they should be replacing
traditional mips entirely um so like i said before it’s kind of it’s
a new framework it’s supposed to be closer offering you a more aligned set of
measure options more relevant to a clinician’s specialty and it aligns measures from all four of the
performance categories and it aims to provide more meaningful data
to clinicians and patients by comparing performance across you know like specialties like clinicians who report
on the same mvp um and that information would then be released through public reporting
so the current timeline is 2023 2024 2025 performance years and
the mvp participants are identified as individuals individual clinicians single
specialty groups multi-specialty groups subgroups i’ll get into that and apm entities that are assessed on an
mvp for mips performance categories and i’m going to get into what an mvp actually looks like
for 2026 multi-specialty groups will be required to form subgroups in order to
report mvps so if they want to report on mvps they’re going to have to a multi-specialty group will have to form
subgroups within their tin and choose mvps for each subgroup in
order to report um cms is aware that there are a lot of different mvps that they still need to
develop they’re looking for us to help with that process and um and we want to work with our clients
even more to come up with new mvps to propose to cms
uh reporting requirements for mvps for quality a participant will select four
quality measures right now they have to report on six under traditional mips one measure does need to be an outcome
measure or a high priority measure that’s very similar to mips traditional
mips um ia participants will select two medium-weighted improvement activities
or one high-weighted improvement activity or um they will participate in a
patient-centered medical home if the activity is available in the mvp
for cost participants will be calculated on the cost that’s all done through administrative claims
for the foundational layer which is mvp agnostic it includes one
population health measure reporting and the foundational layer also includes pi
so for pi participants will report on the same pi measures required under traditional mips unless they qualify for
re-weighting and then subgroups will submit pi data at the group level not the subgroup
level so when you’re and i am going to give an
example so if you are still confused on mvps just just hold on
but one important thing is the registration aspect so when you’re reporting mvps
the participant must register for the mvp that they plan to report on um they won’t be able to
adjust that or change that or get rid of that mvp um
after the registration window closes and that registration window is slated to be april 1 of 2023 to november 30th of
2023. uh to report on an mvp at the time of registration you need to identify the vp
you want to report on identify one population health measure included in the mvp
and then identify any outcomes based administrative claims measures on which the subgroup
or plans to report on so you can see the two options for the
population health measures that are currently available on the screen here
so to participate as a subgroup which is again going to be the only way
multi-specialty practices can report on mvps starting in 2026
each subgroup will be required to identify the mvp they report on identify one population health measure
identify any outcomes outcomes-based measures um and then they need to identify the
clinicians in the subgroup by the tin npi um of each clinician that’s going to be
a part of that subgroup um i’m going to show you an another example later that’s going to kind of break this
out and then finally they need to provide a description of the composition of the subgroup
which may be selected from a list um that cms provides or offers or described
basically in a narrative so you think that these clinicians go together
because of x-reason so you describe that for that reason
in the 2023 proposed rule cms has proposed to change um the way that they
will identify or determine single specialty versus multi-specialty practices um
for this reason for for the multi-specialty practices that will have to report
mvps as subgroups in 2026 but they’re changing how they’re going to determine single versus multi specialty so
initially um they were going to use the pecos system now they’re proposing to define single
versus multi-specialty through medicare part b claims um and then additionally cms has proposed
that a clinician identified by nb and npi would only be allowed to register for one subgroup per 10. so if i
fill under a couple of different tim tins i would only be able to be a part of a subgroup um under
under each 10 so i would be in one subgroup a for 10 a i’d be in subgroup b for 10 b
um but i can’t be in subgroup a and b for 10 a if that makes sense
so here’s just kind of a i tried to just break down mvps um this is an example of how it would
work to report on the proposed advancing cancer care mvp
um in 2023 that is one of the proposed mvps so first i would register between april
and november um and i would select the advancing cancer care mvp during that registration
i would also choose the pop health measure i intend to to report on um and then or i sorry that i intend to
get scored on um i would also choose any outcome-based measure i plan to report
on uh for quality i don’t need to decide on which four
quality measures at the time of registration um i could just you know i the the key is picking the
measures that you plan to report on um this is just a sample of four measures that i chose from the different
measures that are offered under this mvp and i would then
once it came through to the submission period i would be submitting data on those poor quality measures
for the mvp for ia i don’t need to decide on which
activities at the time of registration i just pick the two submission is
um january to march 31st very much like quality uh for pi my practice will report
the pi is the same as i’ve done under traditional mips so that’s no different for cost it’s going to get
scored for this this mvp i just the only cost measure that is
included in this is the total per capita cost so i would get scored on that measure alone if i have enough cases for that measure
um and then for the pop health category i choose to report on the hospital-wide 30-day all-cause unplanned readmission
now sub group reporting example i think there’s a lot of confusion about um
subgroup reporting so i just wanted to kind of just give a quick idea of what this might look like so essentially
um you know you have your multi-specialty group um there are three specialties in there
let’s say you wanted to split them all up just by specialty alone you’d have your oncology your primary care and your
cardiology for oncology i might pick the advancing cancer care mvp
um and then within that mvp you know my oncologists are going to report on those four measures those two improvement
activities the whole practice is going to report pi
i’m going to get scored on the total per capita cost measure and i will have the
hospital risk uh sorry the
uh the other measure that we had just the 30-day hospital readmission
um for the pop health measure for the primary care subgroup um
we would report on the promoting wellness mvp pick those four measures improvement
activities uh pi total per capita cost and the hospital readmission
health measure and then cardiology and light pick the advancing care for
heart disease um mvp so that’s just a quick visual of how subgroup reporting
um is is going to work um and subgroup reporting is offered in 2023 but like i
said for multi-specialty practices specifically that want to report on mvps in 2026
this is what they would have to do they would have to sign up for subgroups um in order to report mvps
so here are a list of the finalized on the left mvps that were finalized in the in 2022’s rulemaking as well as the
newly proposed mvps in this rule um and
um there are a couple of different changes that cms made to the finalized ones
already but not nothing huge so but these are the new ones that are proposed for 2023
and then getting close you know it’s a lot of information
uh so this is about um sorry this is proposed changes to alternative payment models um for example medicare shared
savings program aco uh so the first notable proposal for advanced apms is proposal to remove the
2024 expiration of the percent minimum
on the generally applicable nominal risk standard for advanced apms and make that
eight percent permanent so essentially there was supposed eight percent minimum
was supposed to expire in 2024 the proposal is to make that eight percent um
permanent so what is that nominal risk standard um mean so an apm entity has to take on
more than nominal payment risk for years when the apm entities actual expenditures
under the medicare or other payer advanced apm exceed the its expense
expected expenditures by no more than nominal risk so for example the medicare
advanced apms cms is proposed to make permanent that rule um that the minimum
total amount of an apm entity puts at risk must be at least eight percent of
the average estimated total medicare parts a and the revenues of all
providers and suppliers participating in the apm entity and that eight percent would remain
permanent i hope that was clear clear as much
uh this is applicable to those participating in myths at the apm entity level this proposal would allow those
participating in mips at the apm entity level to report the pi category at the
apm entity level um initially they weren’t going to allow apm entities to report pi at the entity
level um they could still choose to report pi at the individual or tin level
but this is a proposed other option for participation for the pi category
and cms maintains the sun setting of web interface
reporting option for medicare share savings programs after 2024
i know mssp acos have been pushing back on cms about this change
but what this would be is that um you know for 2022 you cannot report mips
through with the web interface they sunseted that option um but
for mssp acos they are currently able to report on just medicare
beneficiaries through the web interface option
that’s set to sunset after 2024 in which case they’ll have to report on the ecqm
and or mips cqms that are available which also means that they will have to report on all payer patients in 2025
so that there’s no language to suggest that cms is backing down from that
um and i’ve been talking for so long i’m going to hand it over to teresa in one minute um
but i just want to go through this really quickly our strategic partnership it really does create value across
value-based care we’re going to be releasing a press release on the results of 2021
reporting using reporting md and the results are really great i’m really excited for that press
release to come out we believe that creating strategic partnerships with our clients is the
best way to create value across all of this this entire value based care spectrum um we’re really lucky to have
theresa one of our client champions on the call with us from icare service partners
um and so now teresa i am going to hand the mic over to you and i’m going to
move it to your slide thank you so much so for my client use case i thought it
would just kind of explain some of the mips challenges that esp has faced so since the inception of the mips
program we’ve reported anywhere from 17 to 25 unique tins each year
we have a small corporate quality staff which is to say i’m the only person in the quality department for esp at the
corporate level i am very fortunate that i have individuals at each location that
serve as a mips subject matter expert they manage the day-to-day of
myths but i’m the one solely managing all of the submissions for all of our tints
we have several options for submission across our organization many use our industries data registry
which is called iris some locations choose to submit through their emr
and then we have several locations in our illinois market that participate in apms and it used to be that i would do a
backup submission for the apms because i wasn’t quite sure and confident in what they were doing but over the last two
years i relinquish some control and now i allow the apm to be the sole submission for those which has helped
one of the largest issues that we have at esp is that we have multiple emrs and multiple pms across
esp we do not standardize onto one emr when we acquire and so that leaves us
with multiple to deal with where this is really um impactful
is even in our data registry all the mapping that has to get done has to be done
individually for those emrs we also have two locations that are on paper and then four tins that report as one
tin number but they have multiple emrs and pms underneath that tin next line
so that’s how we started a relationship with reporting md was because those
those tins that have multiple emrs and pms under them we needed a way to
aggregate their data so that we could have a successful submission each year we also have one of our locations on
paper that is using reporting md because the system is easier to use than doing a
manual report through our data registry so i thought i would just speak on kind of our relationship with reportingmd
so we have one-on-one attention from reportingmd there’s no doubt about that we have a dedicated point of contact but
i receive communication from multiple folks within reporting md checking in on
how we’re doing and if there’s anything that they can do to help one thing that i’m super thankful for is
reporting md’s keen eye on strategy so they will often reach out to us
and say hey maybe we should take this measure away or add this measure um and
or we should file for an exemption etc and that strategy can change year to year and they’re the ones that are
really bringing that to us um and helping us to decide how to move forward for a successful submission
we have frequent communication and progress reports so we have a real cadence of the meetings that we have
with each of our locations and after each of those meetings we get a really detailed progress report which is super
helpful to me if i’m not able to be on the meeting i hear from my subject matter experts at
each of my locations that the system is extremely easy to use and they appreciate how they’re able to use the
system i know for myself i only use the system a couple times a year when i’m doing the
submission but i find it fairly intuitive for the fact that i’m not in it every day
so on top of managing compliance and quality i oversaw all of our organization’s response plan to covet
which meant i could do nothing else for several months if not close to a year so at that time reporting md took it
upon themselves to reach out to our local staff and start working with them directly which i really appreciated
because it allowed me to focus on our copic response and know that mips still had some decent oversight and then
finally the most exciting thing is um our potential to explore an mvp for ophthalmology ophthalmology has always
struggled to be super successful in the mips program we just don’t have a lot of measures
that apply to us and then some measures get taken away some don’t have a lot of point capability it really has been a
struggle really since the inception of mips so for our ability to explore an npm
mfp that would be specific to ophthalmology is super exciting so
that’s our relationship with reporting md and we look forward to many years of continued partnership
thank you teresa that’s fantastic we we certainly appreciate you we’re really excited to
see your scores from mips for 2021 because they were great and fantastic and that really is a sign of you know
our strategic partnership and your and your team um specifically so very exciting and so with that i’m going
to go into the q a and hand the mic back to jess uh quickly
to kind of set us out um set us off perfect yeah thank you molly um yeah and
again just as a reminder you’re more than welcome to submit any questions via the chat option um i do
have a few that i can get started with from people that submitted um on their
rsvp all right somali we’ll start with um when will we learn if we can use the
covid or labor shortage hardships for 2023
again i um so that’s going to be really with the final rule it just it depends on what happens
with the comments that cms receives back like i said earlier i just don’t see any
language that it indicates that cms is going to do a sweeping covet exemption
option for 2023 um and and then also just
the staffing shortages would be really the thing that i would say would send cms um into that decision making if if
they were gonna make a sweeping exemption it would be due to staffing changes at this point
since um a lot of the pandemic is is under control to a certain extent
um but we will wait and see with when the final rule is released and
like i said that will be around november so we’ll probably be doing another webinar around november december with
those policies finalized
any update on mips measures impacting wound care so none of the
measures that are proposed for removal and addition are specific to wound care
um but i will say that our wound care practices
have reported on measures like pneumococcal and influenza i know that sounds a little bit strange but they have reported on those measures um in
the past and they do continue to report on them now and those are
proposed to only be offered through mvp reporting in 2023 not through
traditional mips so that’s that comment that i certainly suggest if you rely on those measures
and don’t plan to report an mvp you submit a comment to cms about that proposal
what is the proposed physician fee schedule update percentage
uh so that is that um bar chart that i showed or that line chart that i showed earlier
um you at like i said at 75 mips points it’s a
neutral adjustment um and what we expect um to see it with a 100 score
would be 6.91 incentive um in 2023
uh if all of the proposals were finalized