2020 MIPS – Program Changes & New Measures
Hey everyone. Welcome to today’s webinar on 2020 MIPS program changes and new measures. My name is Nick Austin and I am the director of product management here at hands on technology. Today I am joined by Kendall Wolf, who’s been playing a critical role in our MIPS reporting process. Okay. Submitting for the MIPS program can be a large undertaking for any practice.
There is so much to know about the program. Despite PTs limited involvement today, we will be only presenting the changes in the program for 2020 this makes the assumption that you have either submitted in 2019. Or have at least attended the previous webinars on the program. If you are looking to report for the first time in 2020 we highly encourage you to watch the previous webinars, odd MEPS from the training center.
Before we jump into what is different in 2020 Kendall is going to go through how we’ll be wrapping up 2019 reporting year and what each clinic still needs to do. All yours, Kendall. Thank you, Nick. So in this portion of the webinar, we’re going to be briefly covering, what their office registry customers, 2019 restaurants you’ve customers specifically, can expect in the coming month.
So just a quick timeline of what we’re going to be going over. So, final imports of their office, registered customers, MIPS status, big going to be conducted in the beginning of January. Final review meeting will be taking place January through February, and submission of the MIPS data itself will take place during the month of March.
All right, so for final imports for onsite registry customers, you’re gonna receive an email at the beginning, beginning, end of December. just to go ahead and schedule those imports itself. And then in the beginning of January, all. Onsite and web customers myth data will be important into the registry,
right? So as far as the final review meeting goes, this is going to be, again, only for registry customers. It’s going to take place, during the end of January through February, the call itself. And then in the beginning of January, you’re going to see an email to go ahead and schedule that meeting.
That email is also going to contain your MIPS reports and an additional email. Will you be set with your improvement activity attestation form.
So as far as what are we going to actually be going over during this meeting, we’re going to be verifying your tin for your company and your NPS for all of your providers. We’re going to be reviewing your midst reports. so if you’re currently signed up to submit as a group, you will receive two reports, and if you’re currently signed up to submit as an individual, you would only see received one report when we’re make any corrections if needed.
After reviewing the report. And then we’ll also discuss your submission options, whether it’s in your best interest to submit as a group or an individual, and whether it’s a special designation that was given to you by QPP can impact how that can impact your score.
Alright. So just a quick refresher as far as what improvement activities are, as previously stated, you’re going to receive a form career. You’re going to be able to attest to your various improvement activities throughout the year. So basically improve an activities are activities centered around
Patient, ongoing care, shared decision making and safety and expanding access for patients. They have to be performed for more than 90 consecutive days during the reporting period, and they can be impacted and or influenced. if your clinic was granted IX special designation by CMS. Such as a small practice or real designation.
You can check if your practice has a specialist designation through the QPP participation lookup tool.
All right, so if your clinic does happen to have a special designation, you will need to submit on one high. We did activity or two medium weighted activities. All other clinics will need to summit on two high weighted activities or one high weighted activity and two mediumly day activities or ordered medium moving activities.
All right, so blower, a few examples of what we expect most clinics be submitting on them. As far as improvement activities go, you are nobody, I mean, limited to these specific activities. but we do highly suggest you go ahead and view the full list of improvement activities that qpp.cms.gov.
All right. So as far as the, attestation process itself for the improvement activities, the end of January, you’re gonna be at testing to your various improvement activities via like DocuSign document. It’s basically a fillable form that will be sent to you by email, will you’ll be able to fill out all of your pertinent information, such as your clinic information, such as 10 and NPS of providers.
if your practice has a special destination substance, a rule or small practice designation, and also what activities were performed during the performance period.
All right, so the mission of the data itself will take place during the month of March. So just quick wrap up everything. as far as what registry customers need to be on the lookout for, you’re going to need to go ahead and schedule your final review call during January. You’re going to need to attest to your improvement activities January through February, and you’re going to need to go ahead and attend that final review call January through February.
Mic. Go ahead and pass on the call to Nick and he’s going to cover what’s going to be coming up in 2020. Thanks, Kendall. Alright, so before we start diving into the 2020 reporting year, I want to first talk a little bit more about the scoring process for MIPS with respect to the quality category. A, this is to kind of set, uh, some, some things in place that you guys can better understand, uh, what the goals are for the 2020 reporting.
You. So QPP uses a benchmarking system to determine how many points to award. For the six quality measure requirement. The standard maximum points per measure is 10 however, there are things that can increase or decrease that maximum. Let’s start with the bonuses. From your six measures, you are required to report one high priority measure, be it outcomes or process.
Every subsequent high priority measure submitted gets you one bonus point if it’s a process measure and two, if it’s an outcomes measure in terms of potential decreases, these can come from non benchmark measures, which we’ll talk about in a few slides or topped out measures. A measured tops out when the data QPP receives is heavily tilted towards the high end.
In short, if everyone keeps scoring 100% on a measure, that measure will eventually get topped out. When it becomes extremely topped out or tippy topped out, as they call it, they will place a seven point cap on the motor. At the top, you’ll see benchmarking data for the BMI measure. It is not a high priority measure, so no bonus points are available and the decimals represent the percentage ranges that award the number of points for that measure.
So if your performance percentage is between 97.56 and 99.86 you will receive a base of seven points for that measure from file seven based on how far into that range you are, you will also receive some fractional points. For example, a performance percentage of 99.85 would probably result in a 7.9 to get the full 10 points.
For this measure, you have to submit with a performance percentage of 100%. If you were seeing any discrepancies in your registry status reports that Kendall’s been sending to you, it is important to follow up with her to get corrections made where possible. Everybody wants to try to get that 100% if you have correctly been reporting on it throughout the year.
Okay. Now let’s take a look at all the registry measures and their benchmarking data for 2019. Here, you will see that every measure except the two diabetes measures and the BMI measure are considered a high priority measure. This is great news and means bonus points will be available. However, current medications and both falls measures are topped out to the point that they had been given a seven point cap.
We’ll also notice that all of the photo measures and the functional outcome assessment measure have been given a maximum point score of three as none of them are currently benchmarked. Don’t freak out. This will be addressed in a few slides and there is good news to be to be shared
here. You will see the benchmarking data for relevant claims measures. Yes, benchmarking is done differently for claims than it is for registry. Here, the glaring difference is that every available measure is popped out to the point of capping each measure at seven points. The good news for claims submitters is that you are, if you are submitting claims, you are also a small practice, which means that you have bonus points coming your way.
That being said, if claims offers a limited ceiling on the program, it is worth considering registry as alternative option, even if you are still small enough to submit through claims.
Okay. Now let’s all talk about those. Uh, non benchmark measures to P States that any measure that does not have sufficient data to be benchmarked will incur a three point cap. None of the photo measures or the functional outcome assessment measure received a benchmark for the 2019 reporting year.
However, and this is really important, QPP also has the ability to benchmark a measure the same year it is submitted. If that measure is submitted enough times to create a same year benchmark with PTs being included in the program for the first year this past year, we anticipate the QPP should have no problem getting this measure benchmark with all PTs probably submitting on this measure.
So what does this mean when we submit your data to QPP? In February, March of next year, we will receive a score preview. This will tell us what they think your final MIPS score will be. Based on the data we have submitted so far, this score will look pretty ugly with none of these measures getting benchmarked.
However, once QPP has received all of the data, they are likely to get those benchmarks in and then update the score. Your score preview will most likely not reflect your actual ending MIPS score, especially if you’re submitting the photo data, which brings up the next point. We reached out to photo directly to get a response and their measures not receiving a benchmark yet.
Betty Stone over at photo said that based on the number of clinicians slash groups that we have submitting, we do expect to receive a period benchmark for the 2019 reporting year. We will not have any information on the benchmarking until CMS has collected and processed all of the data for the 2019 performance period.
They usually do not release the information until July of the year following the performance here. That would be July, 2020 for 2019 the initial scores received will be preliminary and will not include any benchmarking for the outcome measures. That would be a minimal score. The final score would include benchmarks for the outcome measures, if applicable.
So if you’re reporting on the photo measures, we will still get those measures submitted and once they get benchmarked, your score should see an improvement.
we already talked a little bit about the top DAP measures. All client claims measures were topped out in three registry measures were as well. There is no guarantee that this trend won’t continue if some of the easier measures get, uh, completed with at a hundred percent rate. The solution to this problem is measure availability.
The more measures PT have access to, the more choices that they will have to potentially optimize their score. The 2019 reporting year wasn’t ideal for PTs with a very limited available measures that in 2020 we are seeing this change already.
Okay. With that context, that of the importance of the availability of new measures. Let’s now move on to the 2020 reporting year and start with the overall changes that are relevant. The plus minus of 7% for a penalty slash benefit of the program has been increased to a plus minus of 9%. Remember that this 2% increase is going to continue year after year for the foreseeable future.
This program is only going to continue to ramp up. The next point is the low volume threshold or the numbers you need to reach before you are considered required to participate in MIPS. These thresholds did not change in 2020 and are still sat to 200 units, 200 distinct patients, and 90,000 in alouds.
Just like in previous years, a 2020 MIPS eligibility report is available, though should be considered very unofficial. Ultimately the provider participation we’ll look up tool from CMS must be used to confirm level of eligibility. Also, you can use your previous years. Uh, I as a idea on whether or not you’ll be meeting it for this year.
So if you are required for 2019 and your patient volume didn’t really change, you’re probably going to be required for. 2020 and the same goes in the inverse. Make sure to account for, you know, payer mix changes and for, changes in scheduling. If you’ve got one provider who is seeing a lot more Medicare patients than they did in the previous year, you should factor that into your equation as to whether or not people are going to be required.
Unfortunately, with, with everything that we’re using, all we have is the ability to estimate as best as we can, whether or not there’ll be required until QPP updates their provider participation lookup. All right, so next, change the data completeness threshold or how much data must be submitted on each measure?
Uh, this has been increased from 60% to 70%. This means that you have less time to start on the program than in previous years. The hard cutoff would have been, uh, or the hard cutoff would be mid April four for the 2020 reporting year, but, uh, to allow for seasonal potential differences, and differences in Medicare volume.
We are suggesting to everyone to commit to collecting the data no later than the last day of February, though. Ideally you are starting January 1st. We also saw the minimum MIPS score threshold change from 30 to 45 points for anyone trying to succeed in the program and maximize their score. They shouldn’t matter too much.
However, there were some that submitted the bare minimum to just try and get over that 30 point threshold to avoid any penalty. This will be significantly more difficult this year with that threshold increasing to 45. In 2019 you can get a minimum of three points per measure, and with improvement activities and small practice bonus, you could still end up North of the 30 point threshold.
Avoiding a penalty will not be the case in 2020 this also points to claims being much riskier. Submission option, submitting low performance percentages with claims, with missed visits, uh, might still mean a penalty in 2020. So a bit of negative news for the PTs is that the pain measure was removed entirely from the 2020 quality measures.
This was an easy one for PTs. So it is disappointing that to see this option removed. The good news is that in its place, QPP is allowing PTs to report on five new process measures.
We went ahead and added all five of these new process measures into dedicated documentation sections similar to what we did last year with BMI falls and diabetes. The measures are preventative care and screening, screening for depression and follow a plan. Elder maltreatment screen and follow a plan.
Preventative care and screening, tobacco use, screening and cessation, innovation or intervention, and two, uh, two measures for dementia, one for functional status assessment and the other for caregiver education and support. On the right here you’ll see a screenshot of what the new tree view looks like.
So before we go into each new measure and how to report on them, I wanted to show everyone that the current 2019 benchmarking data for the new measures on the registry side, only the tobacco measure is not currently benchmarked with none of the measures being topped out. I imagine that the tobacco measure will get benchmark by the time we were submitting this data in 2021.
But I nor anyone else can offer any guarantee on this. Regardless. This means that there are five new measures available for PTs with four of those fives offering, uh, and potentially the fifth offering, a maximum of 10 points each, which is great news. Aside from the fact that, uh, everyone will have to find a replacement for the pain measure.
It is worth considering these new measures as replacements for falls or current medications as they offer more potential return on your score. You will also have the option of reporting on as many of these as possible. So if you were to submit data on every single measure, QPP would just take the score from the best six measures based on their final MIPS score.
This is something that we are going to be seeing in 2019 when we’re submitting for a photo users. We’ll probably be submitting for all their process measures and all their photo measures, and then hoping the best score will just come from any six of those measures. So this is definitely an option, but the work involved in deploying additional measures beyond the sixth, needs to be considered in your decision.
So when you look at the claims benchmarking, you will notice two issues. Depression and elder maltreatment, uh, have already been dropped, uh, popped out capping these measures at seven points. Furthermore, the dementia measures are not even available. This is because the two, uh, these two dementia measures like the diabetes measure are registry only and cannot be submitted by claims.
So again, just to note, we’re going to be going through these new measures. The dementia measures are registry only cannot be done by claims. . Okay. One more thing I noticed said that a few times before we go into each measure. All of the information presented here today on each individual measure is coming directly from QPS measure specification documents, which are available publicly for everyone to access.
The link has been provided here where you can look up every measure and read through their specifications documents. If you were looking for the registry measure specification documents, they are labeled as MIPS clinical quality measures or MIPS CQS. While some things like the physician fee schedule can be pretty daunting to read, these specification documents are pretty straight forward.
If you were to ask me a question on a specific nuance of a particular measure, my first action every time would be to open the specification document and see if that nuance was commented on in some way. If not, you could take it further up the chain to QPP or to the measure steward, but you’ll probably be left with the same answer of just use your best judgment.
Luckily, the spec documents do go into a heavy level of detail to get most questions answered. All right. So now we’re going to go through each of the new measures, step-by-step, how to report on them, what they look like in their office, what are the exceptions defined by QPP through those spec documents?
We’re going to give you as much information as we possibly can on each measure. these slides are pretty detailed as we’re going through them. Uh, the goal of that was to provide you with this resource of this PowerPoint so that when you guys are going to report, you can always reference back. And confirm, uh, about anything about those measures.
So let’s start off with measure one 34 or a depression screening. Description for this measure is percentage of patients age 12 years and older, screened for depression on the date of the encounter using an age appropriate standardized depression screen tool. And if positive, a followup plan is documented on the date of the positive screen.
So this is for evils only. And the screening must be done once per measurement period. It could be done more, but you will only be counted for one since only required ones. A another thing to note for this measure is that patients with a diagnosed depression or bipolar disorder should not be screened.
All right. So the first thing in that description that it mentioned was a standardized depression screening tool. So this is how the spec documents define a standardized depression screening tool is a normalize and validated depression screening tools developed for patient population in which it is being utilized.
The name of the age appropriate standardized depression screening tool utilized must be documented in the medical record. So examples of depression, screen tools include but are not limited to. And then sort on the next slide here, you have, uh, the . Suggested tools that they listed on their side that it could include.
These are age specific, uh, this, it’s not limited to only these, but know that if you aren’t going to be using a, uh, depression screening tool outside of what they list as potential ones, just make sure that it’s standardized. if you ask the question of, is this tool acceptable, it’s going to be your best judgment.
If it’s not listed here, but it does have. Research behind it, and it is a standardized tool for. Screening depression, then it’ll work. you can’t just ask the patient whether or not they’re depressed. That would not work. You need to use a standardized tool and it needs to be, uh, age appropriate. Uh, they also offer perinatal screening tools, uh, for, uh, relevant patients in, in those cases as well.
All right, so the next definition for this is the followup plan. So we know how to screen the patients. We’re going to use an age specific standardized tool, and for patients that screen positive, you also need to perform a follow up plan. So their definition of a followup plan is a, it must include one or more of the following, additional evaluation or assessment for depression, suicide risk assessment.
Referral, pharmacological interventions or other interventions. obviously for PTs, the one most often used here is going to be referral and when hadn’t bolded it for ya. but you do need to document what that followup plan indicated, uh, within your documentation.
I also, uh, within each of these, we’re going to talk about exceptions. So what does those specification documents indicate would be an exception, uh, for that patient not being included in this measure at that time. within each measure, we’re going to list off what they define as. Not eligible patients.
And, uh, I know that there might be some circumstances that go beyond that, that you might be curious about. Unfortunately, if it’s, if it’s not listed here, it’s not in those specs documents, which means you probably going to have to use your best judgment on it. So for the depression screening exceptions, we talked before about how patients without, or with a.
A diagnosed depression or bipolar disorder should not be screened. The other reasons why a patient should not be screened, his patient refuses to participate. That’s the most common one that we see with a bunch of other measures. Uh, it would apply for this one as well. A patient has an urgent or emergent situation, probably not relevant to PTs.
The next one potentially could be. Situations where the patient’s functional capacity or motivation to improve may impact the accuracy of results of standardized depression assessment tools. Uh, for example, certain court appointed cases or cases of delirium. So if your patient is a level of impairment that.
Would impact those, uh, depression assessment tools, then, uh, they would be an exception as well. All right, so the, also, with each of these measures, we’re going to go through what it looks like, in their office. So here’s the screenshot of this particular section. And just like in the previous sections, what we’re doing for this is we’re giving you the dedicated questions, uh, that need to be answered.
And how you answer these questions, it will automatically assess for you. So in this first one, you come in here, it’s going to appear with each of these sections. Great out. And it’s going to ask you the first question of, does the patient have a preexisting diagnosis for depression or bipolar disorder?
this measure does not require you to document the specific diagnosis code in the case. So we’re simply leaving this one as a yes, no. So you’d go through and you fill out these questions. In this case, we answered no, that do not have a preexisting diagnosis, and then we answered yes. Uh, it was screened for depression.
The results were positive. Uh, an important part of this. The spec documents specifically indicate that you need to indicate the tool that was used to screen for depression. You don’t need to give the exact results of it outside of a positive or negative, but you do need to indicate the name of that screening tool.
In this case, we use the PHQ dash a and then we also have to indicate what our followup plan is. We’re giving you a checkbox list, a, if you were to indicate other interventions. Or follow up for the diagnosis or treatment of depression than we do offer you. Also a followup comments box if follow up comments doesn’t need to be used if you’re simply doing a referral.
And then once all this information gets filled out, you’re all done. It’ll assess. As long as you get that green check Mark, you know that you’re good for this measure and you’ve reported to successfully all of the validation for all of these measures works exactly the same way as they did for the previous measures in 2019 so if you want to lock the system down so that it requires a green check box.
Checkbox for you to proceed forward. That is all done from administrator. All inherits what you set up for 2019. Uh, so basically you’re just need to configure the screen and then you’re good to go.
Alright, next measure is the elder maltreatment screen prescription for this is percentage of patients age 65 65 years and older with a documented maltreatment screen using an elder maltreatment screening tool on the date of the encounter. And a documented follow up plan on the date of a positive screen.
This is also for evolves only, and again, the screen must be done at least once per measurement period.
All right, so more definitions for this. The screen for the elder maltreatment and what does this need to involve? So an elder maltreatment screen should include assessment and documentation of one or more of the following components. Physical abuse, emotional or psychological abuse, neglect, sexual abuse, abandonment, financial or material exploitation, and unwarranted control.
So, uh, they also note documentation of an elder maltreatment screen must include identification of the tool used. So just like we were talking for depression, you need to indicate what tool you use to do this screening. So examples of screening tools for elder maltreatment include but are not limited to elder abuse, suspicion index, vulnerability to abuse screening scale, uh, not going to pronounce that next one.
And these tools are sacrament psychometrically sound instruments with demonstrated reliability and validity indices. So again, have to use that standardized tool if you are going to be screening for elder maltreatment. the follow up plan for this is a little bit different than previous ones. In that if you screened somebody positive for elder maltreatment, you must provide a document or report to state or local adult protective services or the appropriate state agency.
the thing about this measure is that everyone’s probably already doing this. They’re just not screening for it. So if you notice a patient and that patient has an issue that you think is there that you think needs to be reported as a PT, you must report that, you’re legally. Obligated to report it already.
So this one, it’s already an existing process that you’re following. It’s just you’re not screening for it. So adding the screening is the kind of only change in this. What you do with the results of that screening are probably consistent with what you’ve already been doing.
All right, so now acceptance. A patient is not eligible if one or more of the following reasons is documented. Patient refuses to participate and has reasonable decisional capacity for self protection or patient is an urgent or emergent situation or time of the essence or times of the essence and delay treatment would jeopardize the patient’s health status.
So the first one does offer a little bit of ambiguity. You can use your best decision work with the patient to determine whether or not this is appropriate or not.
Uh, the screen for this is real simple. Uh, they’re not requiring too much documentation cause the followup is, is reporting it to APS. So first question is simple that can you elder maltreatment screen performed and you answer it, yes or no. and then the screening results, positive or negative. Here you have to indicate what screening tool was actually used, and then the followup plan documented.
Uh, again, this is just a simple yes or no, as to whether or not that was documented because the, the full report should probably be included in your documentation. You should import it as like a separate image note. But if you did need to actually report the state PS, all your needing indicate within this section is whether or not you did.
You’ll also notice here that we have these question marks. Uh, this is for additional descriptions. There are tool tips that have been added into these new sections where you can highlight over it and you’ll get a detailed information from those spec documents should help out with, uh, your PTs asking questions about what exactly this means.
Hopefully those are descriptive as enough to answer those questions here, you’ll see a completed screen. Again, really important that you indicate what tool it was that you used, for the screening.
All right. The next measure is a measure number two 26 and this is for tobacco use. Description is percentage of patients aged 18 years and older who are screened for tobacco use one or more times within 24 months and who received tobacco cessation intervention if identified. As a tobacco user. So this is required on evils and reevals and there’s something very different about this measure that we haven’t seen with any other measures before.
And it requires two instances of an eval or reeval completed within the performance here. In order to report on this measure. So this does pose a problem for anybody trying to submit on this measure. Because if you have a patient and you don’t typically do reevals cause you do them correctly and you only do them when a drastic changes needed and you’re only evaluating that patient once in a year, they don’t count.
even if you were to perform the screening and do everything for the measure that you need to, when it comes time for our calculation and Kendall’s MIPS reports that get sent out to people, it’s not going to score that measure for that patient unless there were two instances of an eval or reeval done within the year.
So when you do that screening, when you do this measure for the patient, if it’s on the first one or the second one, it doesn’t matter. It’s just you need two instances of it. This is going to pose a problem for this measure and might make it difficult. So it’s something you’re going to have to monitor carefully if you’re deciding to report on this measure.
and again, like I mentioned, the screening must be done at least once per performance period. but you must have two instances of the ethos or reevals.
All right. So some more definitions. Tobacco use if any, tobacco. So it’s not just cigarettes. Uh, any tobacco use is included. They defined tobacco cessation, innovation, intervention as a brief counseling and or pharmacotherapy, uh, for the purpose of this measure. Brief counseling, uh, for instance, uh, minimal and intensive, uh, advice, counseling interventions conducted both in person and over the phone.
Quality qualifies for the numerator, written self-help materials and complimentary alternative therapies do not qualify for the numerator. So the important thing to know here is unfortunately, you cannot complete your cessation innovative intervention by handing the patient a pamphlet. that is not enough.
It is not sufficient. Uh, you need to actually have that three minutes. Counseling with the patient. Otherwise it does not qualify.
Uh, when it comes to exceptions, they do outlist much. Uh, the only thing that they say for exceptions are limited life expectancy or other medical reason. Those would be the reasons why you wouldn’t do it for a patient. Uh, use your best judgment though. Make sure if the patient is considered an exception in your best judgment, that you document your reasoning behind it.
All right, so here’s what this looks like within their office. Uh, first it’s going to ask you, was this patient screened for tobacco use? if you go ahead and answer yes, then it’ll move to, is this patient a tobacco user, yes or no? and the way that this measure works, again, it’s kind of an exception compared to previous measures.
In here, it looks like this is three measures. It’s not, it’s one measure with three credits, three criteria that we have to submit for you, so you don’t have to worry too much about what each of the criteria are or any of the nuances of that. We’ll take care of all that from the scoring side for you. All you need to do is make sure to kind of answer the questions as best as you can.
So is the patient a tobacco user? That flows into the next question. Uh, did the patient receive tobacco cessation intervention intervention? Yes or no? if you were to answer no for, was the patient screened for tobacco? Or four, did the patient receive tobacco cessation intervention? It will open up those reasons boxes for you to then indicate why, uh, why the patient wasn’t screened or why no cessation intervention was offered to the patient.
So again. If you’re going to not do what the measure asks for, they ask for documentation explaining why you didn’t do it. those are considered exceptions. They’re not counted for you. They’re not counted against you. but you do need to document your reasons behind it. Here would be what a completed screen looks like.
This patient was screened, their tobacco user and the cessation intervention was provided to the patient and assessed correctly for all three.
All right. The last two measures are both related to dementia. So we kind of merchant together. I’ll, I’ll talk about them separately at some points, but I wanted to kind of go through each of these together cause they’re one, there’s ones that are off the screen for them. So start off with measure two 82 this is dementia.
Functional status assessment. It is a percentage of patients with dementia for whom an assessment of functional status was performed at least once in the last 12 months. And the second measure is measured to 88 or dementia education support of caregivers for patients with dementia. So this ones, they’re slight, they’re both dementia measures, one’s related to the patient, and their functional status is related to the support of the caregiver for that patient.
Uh, the second one is defined as percentage of patients with dementia who’s caregiver. Or caregivers were provided with education on dementia, disease management, and health behavior changes and were referred to additional resources for support in the last 12 bucks.
Okay. So for dementia reporting, both measures are required for all patients regardless of age. Both managers required, uh, or require a dementia diagnosis code in the case. So this works a lot. Like the. the diabetes measure in that you need a dementia diagnosis code in the case information to proceed on the measure.
Uh, no patients without it get counted in any way. So this is another really important thing when deciding whether or not you want to report on this measure. Because if you do not think you are going to be able to see 20 patients in the reporting year, uh. With dementia, then you will not be able to report on this measure.
it’s also for that reason that favors group reporting because if your group reporting, then that 20 patients thresholds is across your entire company. Whereas if you’re individually reporting, uh, the 20 patient threshold would need to be met by the individual. So very important when considering whether or not to do the dementia measure.
Uh, this is required for evils and reevals and again, the measure must be performed at least once per performance period.
So a dementia functional status definitions. So they define an assessment of functional status as functional status assessed by use of a validated tool, direct assessment of the patient, or by querying and knowledgeable informant. A direct assessment of functional status includes an evaluation of the patient’s ability to perform instrumental activities of daily living.
IDL, uh, examples include cleaning. Money management and medical management, transportation and cooking and basic activities of daily living, ADL, grooming, bathing, dressing, eating, toileting gate, and transferring documentation of why an assessment could not be completed due to an advanced stage of dementia, uh, in combination with a lack of knowledge will inform.
It would also meet the criteria, uh, for the restroom.
So, uh, continuing on with the definitions for this measure, the functional status, uh, can be assessed using one of the, a number of valuable, uh, valid and reliable instruments available for medical literature. Examples include but are not limited to. And you’ll see the examples here. This one, they do give you the option of not using any standardized tool.
We’ve included their suggestions here. but you know, can we actually go to the previous slide here? One thing I’m going to show you here is they say that you can assess the functional status through a direct assessment of the patient or by querying a knowledgeable informant. So you do not need to use a standardized tool for this.
This is given the nature of what you’re inquiring about. A tool might not always be a useful in this scenario. In terms of status exceptions, same thing as before, not much has listed. Uh, if the patient is severely impaired and caregiver knowledge is limited, uh, or other medical reason, those would be considered exceptions.
Again, this, there’s a little bit of ambiguity here. It’s left to be your discretion.
All right. So, uh, now let’s talk a little bit more about the other measure, which is the caregiver, uh, for dementia patients, uh, and the definition that they provided. So for, uh, education, they define this as requires learning and processing information about. Disease management and health behavior changes.
They should also include advising the caregivers that as a caregiver, he or she is at increased risk of serious illness, including circulatory and heart conditions and respiratory disease and hypertension, increased physician visits and use of prescription medications, emotional strain, anxiety and depression providers encouraged to review state’s specific guidelines to ensure education is being provided as required.
the additional resources that you can provide are defined as situations, specific tailored programs to assist the caregiver. And these include national organizations such as Alzheimer’s association, but also include local resources such as community, senior Senator, senior center, and religion based support groups.
So on these, again, they’re, they’re making this purposely ambiguous so that you can use your best judgment based off of local and state. Requirements and suggestions. so you should use your best judgment on this, but the idea is to supply the caregiver with education and additional resources to help them in their situation.
Uh, in terms of the caregiver exceptions, not much is listed outside of the obvious one in that a patient does not have a caregiver, or other medical reasons, same as before. Make sure to document. Here, you’ll see both of these measures be included in the same section. We assume that if you’re going to do one, you’re probably going to do the other.
That first part, you’ve got to click that box, check the diagnosis in the case, just like the diabetes one, you have to have a Dem dementia diagnosis in the case in order to proceed with the rest of the measure. But once you have selected, it will ask you, has an assessment of functional status been performed in the last 12 months?
If you answer yes, then it gives you a area for comments or if you answered no, it gives you a reason for patient in eligibility. You do not need to do your full functional status assessment. In that comments box, you can just point to your functional status section and that would be sufficient. we didn’t include this in the functional status section because there were some other nuances to it.
So we wanted this one as a separate section, but know that the two can go hand in hand. You do not need to duplicate your information. Next one is what the caregiver provided with education and referred to additional resources. Again. Same thing as, as before, you do not need to go into great detail as to what additional resources were provided.
Uh, we just give you a blank comment box there and if you have some standardized thing that you want to put in the comments stuff to you, but it’s not required to correctly assess this measure, this is the, the check or the, the warning that you’ll receive if you were to check, click that check diagnosis box and there is no diagnosis set in the case.
You get this, and they do have dementia. You do need to get that diagnosis. In the case, it’s gotta be an ICD 10 diagnosis. otherwise you can’t proceed on this measure. And then here you’ll see a completed version. I’m just giving brief comments on the functional status assessment and, uh, the caregiver education.
All right. So that’s it for the new measures. And I know there’s, we’ve been going a lot here and I’m sure you have a ton of questions that you want to get answered. real quick was one more thing to go over before we get to the questions. And that’s how we get started on reporting in 2020 what steps decently to take.
So there’s four steps, uh, deciding your submission status, getting the update, running the MIPS configuration wizard and completing the MIPS provider participation screen.
The first step for everyone is deciding your submission status. Will you be participating who will be participating? Will you be submitting via claims or registry? If you’re an existing registry customer, you have probably been contacted already by Andrew Rizzy, our sales rep, tasked with the registry.
Project renewals are quick, but if you’re looking to sign up to be a registry submitter for the first time this year, you will need to go through the full signup process. This can take some time. So it is very important to get your initial data submitted to us through their office.com/registry complete that form and get it submitted to us so that the signup process can begin.
For everyone else, please just start considering who you want to report and what you want to report on. You will want to know or want to try and know this before you received the update. One more thing to note about the registry. Sign up process for new potential registry customers. We want you to submit that as early as possible so that you can get configured correctly for the 2020 reporting year.
But the final process, if it happens to get completed in February, even March, it’s completely fine. the most important thing is that you’re collecting data. The signup process itself, uh, does not need to be completed by the end of the year. But first step. Submitting your data through their office.com set registry.
That’s the most important thing to do for any one looking to become a registry for the first time. The next step is getting the update. Unfortunately, we have limited time each year to get the software, uh, changed to account for all the changes in the program. I am happy to report that this year we’re able to get these changes done and are currently expecting to release the dots.
16 update before the end of the year. However, we will have to stage this release, placing a priority on customers we know are participating in the program. Our top priority in no particular order are therapists, registry, customers, webinar attendees and customers that have directly requested the update.
You, you’re in attendance today. We will be adding you to the list of customers needing an update before the end of the year. If we cannot match your registry or your webinar registration data to a known their office account, we might need to follow up with you directly for more information. So be on the lookout for that.
If you’re watching this webinar from the training center or uh, sorry, and your claims submitter, it is important to note, uh, that you will need to contact us directly to let us know you need an update. If you’re a claims submitter and you’re watching this from the training center, we, we just don’t know that you’re actually watching it and we don’t know which database to update, so make sure to let us know that information.
All. That being said, should you start a few weeks into 2020 it would also be fine. Remember that the data completeness threshold is 70% so if you missed all January, it wouldn’t impact your final MIPS score. We’re just hoping to get everybody started on January 1st this year.
Once you receive the update, you’ll be prompted once again to go into administrator and run the MIPS configuration wizard. The wizard will start with a single question. Are there any changes to your midst participation this year? This relates specifically to you submitting as claims or registry or not submitting at all?
If there are no changes, then you can simply proceed with updating your system to include the new measures and starting your provider participation. If there are changes, you’ll be prompted to describe those changes and you will, that will get emailed over to us directly. Any changes in your submission status will need to be handled on a case by case basis.
That may involve waiting on an update until January 1st. It’s very important to note that the change does not involve you submitting a new measures or different providers submitting this year. If that is the case, and it will be for most of you out there, simply answering, answering that there are no changes and proceeding with the update is the best path forward.
And the last step. After the wizard has been completed, uh, you’ll be prompted for the provider participation window where it lists out providers and the measures they’re going to be reporting on. So this is the same window that we had before. Uh, it’s the window where you’re indicating which providers are involved and at what levels are involved, which measures you want to be reporting on.
Uh, you can report on more than six measures. So if you want to, uh, validate for more than six, get more than six submitted. And then get the best scores from those that that’s completely up to you. It just depends on how much work you want to put into the program. Uh, this must be configured for 20, 20.
Before 2020 if you want to start submitting on January 1st. So in this screen, there’s a dropdown for a year. So the 2019 one is going to look slightly different than 20, 20, because there’s a lot more measures that are available for 2020. and know that you will not be able to, uh, submit on the pain measure for 2020.
That one is being removed from the program, so we do not even allow you to set up for it from that screen. Uh, if you wanted to, you could complete the. Uh, MIPS configuration wizard right after you get the update and then not actually make a decision on the provider participation. We could see this being the case for some customers who wants to download all the documentation changes, see it in their documentation, play around with it a little bit, get comfortable with it, and then make the decision as to which way they want to report on.
That’s completely fine. Just don’t forget to do it. if you’re not. Filling out that provider participation screen, uh, in for the 2020 year, then we are not validating your information. If your registry, we’re not saving it. So it’s a very, very important step. Make sure to complete that step. Every customer, even if your submit a registry last year, every single person that has to get that provider participation window configured correctly.
All right. So, uh, time says we only have seven more minutes for questions. Uh, but we’re going to stay here as long as we can to answer as many questions as we can. so feel free to get them submitted. Thank you everyone for attending today’s webinar. Hopefully you found it informative. get those questions submitted and Kanaly or do our best to get them all answered.
Thanks. All right. So, uh, the first question that we have is, uh, does that mean how it will submit as the stations or do we still to go through the CMS website to a test? So this is very important. If you’re a registry customer utilizing the third office registry, we will submit rat test stations for you.
You have to make them to us, which will be done through a DocuSign email that we send over to everybody so they can sign off and indicate which ones they’re actually testing to. Um. If you are a photo registry customer, you will have to work that out with photo. If you’re a claims submitter, you have to make your attestations through the QPP website.
We will not be able to make those submissions for you. You have to make them on your own and note that it is a process to go through that. you’re going to have to do it in that first quarter of 2020. But remember, if you’re playing submitters, you have to make those attestations. Don’t lose out on those points.
They’re easy points. so make sure to get that done.
Okay. Next question was on a similar subjects, uh, claims submitter improvement activities for law or for this current year. again, you’re doing it all through, uh, qpp.cms.gov. you have to basically register a harp account, which is kind of an involved process that may take a few days. but you have to go through signing up through that website to make that, at station for.
Your 10 or NPI, depending on how you’re spinning.
Next question. Do you know why? They set up a seven point cap for claim submission and a higher value for registry submission? So they didn’t arbitrarily do it. A claims versus registry, it’s just they have more data on claims submissions than they do registry submissions and the results of what they submitted or what was submitted for claims ended up creating a, the topped out measures quicker than they would for registry.
So that’s, that’s it. They’re, they’re not arbitrarily saying that, you know, registry should be allowed more points than claims. That’s just kind of how they ended up getting benchmarked. Uh. Please review which measures can be reported through claims. So claims submissions are still acceptable for every measure, uh, except diabetes.
The two diabetes measures, uh, the two new dementia measures and the photo measures. None of those can be claims. Everything else can be claims. Okay. Next question. As far as the dementia diagnosis, since they are not typically on the prescription, can we put it in the case as a PT diagnosis or does it have to be on the MD script?
So for this, I can’t necessarily tell you whether or not you can diagnose a dementia. The problem here is there, there’s nuances of that diagnosis code. There’s not one dementia diagnosis code. there’s many more. So just like this was kind of an issue for diabetes and kind of depends on your problem or your situation, how you receive these referrals, you’re going to need to get an ICD 10 code.
Whether that code comes from the script, from the doctor directly, if the patient knew it, I think that would find too, I, I, it just has to be in the case. they don’t specifically say. The problem is that you can’t diagnose it. And so that’s where this kind of disconnect happens with dementia. Same thing with diabetes.
Uh, it’s, it’s hopefully something that gets resolved at some point. but yes, it’s the same situation.
Next question, if you have new PT is how you set them up for 20, 20. Uh, set them up, uh, through that MIPS provider participation screen. Uh, so once you get to that screen, it’s gonna list out all of your existing ones who are participating in 2019. There’s an ad providers button they click on, and then you indicate which measures that are involved for.
Next question is final review meeting only for registry customers or claims customers too. It’s only for registry customers. It’s part of the registry service. Unfortunately, claims customers, there’s nothing to review on because you’ve already submitted your data for registry customers. We haven’t submit anything to Medicare yet.
They have no idea about anything. Uh, that all still needs to come. So the final review with our. Red street customers is to determine what data is to be submitted, how it is to be submitted, the advantage of submitting as a registry. if you’re submitting claims, everything you’ve submitted to them, it’s art.
They’ve already got it, and there’s nothing really, uh, to review on.
Mmm. Next question, will we be counting on contacting us to advise on whether or not we should be participating in MIPS in 2020 so we will not be contacting directly for this. But here’s kind of our rule of thumb on this. If you submit it in 2019, you should probably spend in 2020 if you didn’t submit in 2019 you have to take into consideration the large number of factors, right?
And what’s your payer mix for Medicare? Um. You know, are you still going to be reporting in two years or is your clinic still planning on being around in two years? you know, how much do you want to get out of this program? Do you want to try to offset some of those cuts that are coming from Medicare?
There’s a lot of questions to be asked. Um. As to whether or not you should be participating. If you’re unsure, maybe you’re brand new to using their office this year and didn’t really have this discussion last year or maybe something’s changed and you really want to take into consideration whether or not it’s appropriate to to go forward with this here, I actually would recommend just filling out your information on their office.com/registry getting that submitted over to us so that we can.
Follow up with you have a call to discuss. if it doesn’t work out, that’s fine. We can at least get you the information so that you can make a good decision on it. I mentioned before, this program is only increasing in importance. Year after year, the percentage is increased 2% again, now we’re up to 9%, so it’s only going to be more important every year to, uh, to participate.
Uh, next question. What is the normal amount of measures we must submit for 20, 20? Same thing as before. Uh, this is the, the six measures. It’s the same thing as it was before. It didn’t change in that sense. You submit under six, you’ll still get scored for what you do, submit, anything over six. And they’ll just take the best of the measures, uh, to score you based off of.
Next question. Will Tio have the eligibility report again? Yes, we do have, that report is available for, on demand. So if you are looking to get this information, please contact us and we will follow up with you if you’re mentioning it in the chat or in the, in the Q and. A. We will also do a followup with you to get you that information.
So yeah. Do you want to just mention it here? What can we can follow up with you? Again, it’s not perfect, but if you’re kind of reevaluating your stance with MIPS for 2020, uh, it’s definitely a additional point of information that might be helpful. Uh, when can we start the update? Uh, and wizard, those can be started, uh, as soon as you receive the update, which will probably, I believe we’re starting it.
Uh, and I think it’s the 23rd is when we are starting it. It’s coming up here. Uh. You know it’s going to be right up against the end of the year. Unfortunately, they give us a very limited timeframe to make all of these changes. A final rule only came down in beginning of November, and so we had to kind of throw this, this update together pretty fast to get it in everyone’s hands.
So we are pressed up right against the end of the year. We wish we would have you or allow you to have a lot more time to do it, but unfortunately these, these changes kind of come late. Uh, in terms, I apologize for not mentioning this. A question about OT and speech. So OT, uh, everything for PT that I mentioned reflects for OT as well.
Uh, all basically all of these were OT measures that then got included for PTs as well. So, all things are applying for OT, for speech. Very little information available. the way that these things get taken care of, uh, is through these measures, specifications, documents, and the final rule indicated that these new measures would be included in the PT and OT set, but speech is not part of that set.
So we actually don’t know what measures will be included for speech therapists until they released the measure specification documents, which might not come until literally. The last week of December. That’s kind of when they came down last year. So if for, if you’re a speech therapist looking to report, you have very limited measure availability before.
Am I continue into in 2020? We, I’m sorry. Unfortunately, we won’t know until, they released those federal investigation documents. We will be doing a followup email to everybody, like a blog article on what we obtained from that information. Um. But unfortunately, it’s all we have at this moment.
Uh, next question. Do we know if photo we’ll be integrating new measures, tools into their system? I. E. depression tools? I do not know, unfortunately. I know that they have a webinar if you’re on their mailing list. They’ve got a webinar, I think, coming next week where they’re going to be talking about some changes.
Uh, I’m signed up for it. So if you’re a photo user, I would make sure to sign that up or follow up with them to, uh, get more information on how they’re tackling any of these new things. Uh, next question. Do you recommend participating in photo to maximize chance for bonus? Uh, you know, this one. Last year was a little bit different than this year last year.
There’s, with such a limited measure availability, it was pretty tough to, uh, guarantee yourself a maximum score without participating in photo. this year because of those new measures that are available to you, it’s a adjustment call on your basis. I w I would say if. All you’re doing is using photo to meet the MIPS requirements, then it’s probably not worth it for you.
And they’d probably tell you the same thing. The reason you use photo is all the other great things that photo has to offer. you know, photo offers some, some really good tools, really good reporting on, uh, their measures and, and being able to track outcomes for your patients. And that’s why you want to use photo more than anything else.
Okay. So next question. Uh, so what does a perfect score look like now for claim submission with the cap on the different measures within, without bonuses, it’s tough to say with them without the bonuses exactly where it’s going to come out to be. yeah, luckily if on the claim side, everything is benchmarks, you figure three points deducted for each.
So you’re looking at a, uh, 48 out of 60. so you take that and then. That’s 85% of your score, but then you also have to factor in bonuses for small practice. So here’s what I would say, the maximum bonus for a claims submitter, my guess would be somewhere in the upper eighties, low nineties. Uh, if you do everything else right and you get all the other bonuses that you can get.
it’s, it’s not enough to get a penalty, but it’s also not enough to maximize what your score is. I know that that’s negative dues for some people. And, they were, we’re hoping to give out a hundred out of a hundred score. Unfortunately, the program just handcuffs, PTs, particularly in that first year and limits them on how much of a score that they can get.
And there’s only so much you can do, to succeed at it. So. Well, the good news about all of that is that 2020 definitely looks like a better reporting year with those additional options.
Uh, one more question just came in. What is the current cost of the registry and it’s staying the same for 2020? Yup. Uh, same costs. And you know, a lot of it kind of depends on how often your providers are actually treating. So we’ve got a lot of flexibility on kind of the time involved. With each provider.
but no costs are different. Most of the renewals, if you used it in 2019, renewals ended up being the same cost in a lot of instances, plus sorts of drastic provider difference. so yeah, looking at the same costs from our side. All right. That looks like it’s it for questions. Thank you again to everyone in attendance today.
Thank you Kendall, for assisting on today’s webinar. hopefully this was informative. Hope you guys embraced the new measures and we see a continued successful reporting. and again, thank you again for attending today’s webinar. We’ll be doing it again on Thursday in case you, uh, wanted somebody else to attend.
Feel free to let us know any additional followups that you guys have. Just email it over to us and we’ll be happy to address them as best as we can. Thanks and have a great day. Bye. .
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2020 Rehab Industry Preview
Tue, Sep 17, 2019 | 1:00 PM - 2:00 PM CST