Washington Update Part I - PowerPoint Presentation

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2. Washington Update Part I

3. FacultyAndy Rosenberg JDSenior AdvisorCME CoalitionThomas SullivanPresident/CEORockpointe Corp.Editor/Policy and MedicineJohn Ruggieio Associate Director, Genentech U.S. Medical Affairs, Learning & Clinical Integration

4. DisclosuresAndrew Rosenberg, Senior Advisor for the CME CoalitionThomas Sullivan, Principle in CME Provider (Potomac Center for Medical Education)John Ruggiero, Employee Commercial Supporter (Genentech)

5. Learning ObjectivesUnderstand Changes to the Quality Payment Program that involve CMEDiscuss variations to state laws and bills that effect CMEOther national issues that effect CME

6. MACRA QPP (MIPS) – Improvement Activities

7. Quality Payment Program Two Payment PathsAlternative Payment Models (APMs)Differential FFS based on measured performance (MIPS)

8. MIPS Providers for 2018Physicians MD, DO Dentist Podiatrist Optometrist Chiropractor • Physician Assistants • Nurse Practitioners • Clinical Nurse Specialists • Certified Registered Nurse AnesthetistsClinicians at or below the Low Volume Threshold (<$90K Medicare Billing or 200 patients)Eligible Clinicians newly enrolled with Medicare APM Qualified Participants (QPs) APM Partial QPs who choose not to report Temporary Excluded Credentials Certified Nurse Midwife Clinical Social Worker Clinical Psychologist Registered Dietician or Nutritionist Physical or Occupational Therapist Speech-Language Pathologist AudiologistCMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Released to Office of Federal Register, October 14, 2016. CMS, Medicare Program: CY 2018 Updates to the Quality Payment Program, Final Rule, Federal Register, October 23, 2017.ExemptionsApplicable Providers

9. Potential Impact of MIPS

10. MIPS Composite Performance ScoreCMS, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models, Final Rule, Released to Office of Federal Register, October 14, 2016. CMS, Medicare Program: CY 2018 Updates to the Quality Payment Program, Final Rule, Federal Register, October 23, 2017.Performance Year / Application YearQuality MeasuresResource Use or CostImprovement ActivitiesAdvancing Care InformationDescriptionReplaces CMS Physician Quality Reporting System (PQRS)Replaces ACA Value-based Payment ModifierNew category of measurement; Medical Homes and NCQA PCSR receive full credit; 93 activities availableReplaces CMS EHR Incentive Programs f/k/a Meaningful Use; Reporting MethodsClaims, CSV, Web Interface (for group reporting), EHR, Qualified Clinical Data Registry (QCDR)ClaimsAttestation, QCDR, Qualified Registry, EHR Vendor Attestation, QCDR, Qualified Registry, EHR Vendor, Web Interface (groups only)2017 / 201960%0%*15%25%2018 / 202050%10%15%25%2019 / 202130%30%15%25%*Measured for feedback only in 2017

11. Breakdown Quality (50%) 6 measures (1 outcome measure, readmissions) 450+ potential measuresCost (10%) Based on minimum of 20 caseAdvancing Care Information (25%) 90 days of data (CEHRT 2015 10% Bonus) Exemptions (non patient facing, hospital based, ASC based)Improvement Activities (15%) 112 Activities

12. MACRA and CMECME Working GroupCME Coalition, ACCME, ACEHP, AMA, AAFP, CMSS…Designed and submitted a proposed Improvement Activity for QI CMEHundreds of public commentsNew 2018 Improvement Activity Adopted by CMS in Final Rule November 2, 2017

13. Title: Completion of an Accredited Safety or Quality Improvement Program Activity Description: Completion of an accredited performance improvement continuing medical education program addresses performance or quality improvement according to the following criteria: The activity must address a quality or safety gap that is supported by a needs assessment or problem analysis, or must support the completion of such a needs assessment as part of the activity; The activity must have specific, measurable aim(s) for improvement; The activity must include interventions intended to result in improvement; The activity must include data collection and analysis of performance data to assess the impact of the interventions; and The accredited program must define meaningful clinician participation in their activity, describe the mechanism for identifying clinicians who meet the requirements, and provide participant completion information. 

14. Opportunity for EducationQI CME Improvement Activity Supports collection of dataContributes to Advancing Care Information Credit Combined with other Improvement ActivitiesData Registry, Claims data…..Can contribute to 40% of the composite performance score for earning more than fee schedule reimbursementCan also qualify for MOC Part 2 & 4Involves your local QI Department or Office We are teaching medical professionals how to utilize their own data for clinical quality improvement

15. What keeps Healthcare Systems up at night?Perspective based on direct interaction: John Ruggiero, PhD, MPA, CHCP, GenentechSources: Amerinet. Four things that keep healthcare executives up at night? 2017; Interviews and interactions with healthcare systems that collaborate across state boundariesWhere CE departments can make an impact:Discovery LearningCultural throughput through account management

16. Additional periphery?Perspective based on direct interaction: John Ruggiero, PhD, MPA, CHCP, Genentech

17. Other IssuesCME federal policy on the riseFDA REMSNew Jersey gift banOpen Payments statusShared Decision makingThe future of MIPS

18. CME on the Rise17 positive CME bills currently pending in CongressNone are anti-CMEAlthough the risk of conflation with marketing still high(in fact, some may be too “pro”!)The most pressing legislative priority in Congress: opioid prescriber education

19. FDA REMS / MIPSMACRA working group at it again… CME Coalition, Conjoint Committee, ACCME, ACEHP, AMA, AAFP, CMSS…Proposal to expand current IA around CDC opioid guidance to include REMSEven the playing fieldProposed IA submitted by Conjoint Committee for 2020Possibly soonerFDA and CMS both engaged

20. New Jersey “Gift Ban”Written by outgoing NJ GovernorLimits Payments (except education and research) to $10,000Exempts Educational Speaker paymentsLimits meals to $15.00Applies to Pharma Companies and their “Agents”

21. Definition of an Agent"Pharmaceutical manufacturer's agent" or "manufacturer's agent" means a person who, while employed by, or under contract with, a pharmaceutical manufacturer, engages in detailing, promotional activities, or other marketing of prescription drugs or biologics to any prescriber authorized to prescribe, dispense, or purchase prescription drugs, biologics, healthcare facility, or pharmacist, but shall not include a prescriber or pharmacist when acting within the ordinary scope of the practice for which he or she is licensed.

22. Dogs and CatsOpen Payments reporting status updateShared Decision Making and CMEThe future of MIPS

23. Additional Information CME Coalitionwww.cmecoalition.orgarosenberg@thornrun.comPolicy and Medicinewww.policymed.comtsullivan@rockpointe.com

24. Workshop: What Organizations Can do to Utilize the QI-CME Improvement Activity Under MACRA

25. Learning ObjectivesUsing the 5 criteria set forth by CMS to meet a Quality Payment Program's CE Opportunities, including the newly adopted QI CME Improvement ActivityUsing the case study presented on screen, how would providers design a QI CME Activity to meet the CMS MACRA definition?Using the case study presented on screen, what would supporters need to understand about MACRA-compliant QI CME to make the appropriate support decision and communicate the value to their stakeholders? 

26. Needs AssessmentCan be individual, systems based, or populationMay include a review of dataEMR, Claims, SurveysOther sources, literature….Should Identify Gaps in CareThe activity must address a quality or safety gap that is supported by a needs assessment or problem analysis, or must support the completion of such a needs assessment as part of the activity:

27. Measurable Aims for ImprovementSourced from Validated Measures(HEDIS, AHRQ, QPP, etc.) Aims identified by the facility, system or association efficiency, timeliness, safety, effectiveness, effectiveness, disparitiesThe activity must have specific, measurable aim(s) for improvement: 

28. Interventions Intended to Result in ImprovementHands on ClassesSkill ClassesDecision TreesWorkshopsCase StudiesEducation on utilizing your EHR using casesTool KitsCoursesThe activity must include interventions intended to result in improvement:

29. Data, Analysis and ImpactDoes not have to be high techCan use EMR, claims, data registry or other recordsCan be individual or systems basedFeedback given to the learner on their performance vs the groupThe activity must include data collection and analysis of performance data to assess the impact of the interventions:

30. Meaningful ParticipationLearner stays engaged throughout the processChallenges others to succeedCompetitionParticipates in Needs and MeasurementQuantified improvements in patient careNote: This step requires additional documentation from CE ProviderThe accredited program must define meaningful clinician participation in their activity, describe the mechanism for identifying clinicians who meet the requirements, and provide participant completion information:

31. QPP CME Improvement Activity Checklist?QuestionsDescriptionYesNoAddress a quality or safety gapSpecific, measurable aims for improvementIntervention(s)Data collection and analysisMeaningful participationTracking and completion information

32. Credit ChecklistCreditsDescriptionYESNOCE Credit (ACCME, ANCC, AAFP, AANP, AAPA….)QPP Quality MeasuresAdvancing Care InformationCME Improvement ActivityOther Improvement ActivityMOC Part IIMOC Part IV

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34. Online CoursesReview clinical data (health system) Create quality improvement plans based on goalsCreate online module(s) – based on goalsData extraction to determine impact on practice patterns

35. Live CoursesCreate course teaching how to utilize quality measureReview quality measureInclude patient decision making tool in coursePost conference survey physicians on use of toolOnly those who complete the survey and used the tool will qualify for MACRA credit

36. Check QPP Website forQuality measures that may applyAdvancing Care Information measures Other Improvement Activities that may be counted in addition to the CME activity

37. Questions to Ask About an Activity?Address a quality or safety gap?Specific, measurable aims for improvement?Interventions intended to result in improvement?Data collection and analysis?Meaningful participation?Tracking and completion information?

38. Tools Provided

39. Additional Questions

40. Links to Additional ResourcesQuality Payment Program (MIPS) https://qpp.cms.gov/CMS Resource Library https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Resource-library.htmlACCME http://www.accme.org/news-publications/accme-report-enewsletter/cme-providers-can-help-clinicians-earn-cms-performanceCME Coalition: http://www.cmecoalition.org/macra.htmlPolicy and Medicine: http://www.policymed.com/macra/ 2018 Quality Measures https://mdinteractive.com/2018-MIPS-Quality-Measures2018 Improvement Activities https://mdinteractive.com/2018-Improvement-Activities