SCGhealth Blog


2018 SCG Health QCDR Measures Sneak Peak

Wednesday, April 11, 2018

By Audrey Landers

Last week the 2017 MIPS reporting period finally came to a close, which means it’s time to ramp up our 2018 enrollment! SCG Health has been approved as a Qualified Clinical Data Registry (QCDR) for the 2018 reporting year. To help you meet your reporting goals while providing high quality healthcare, we have created the following six measures which will be available for the 2018 reporting year:

SCG1: Evaluation of High Risk Pain Medications for MME
The United States is in the midst of an opioid epidemic and we believe physicians should be doing all they can to help bring it under control. This includes assessing and recording the dosage of those prescribed high-risk medications such as opiates, benzodiazepines, anti-spastics and NSAIDS. 

SCG2: Outcome Assessment for Patients Prescribed Ankle Orthosis for Ambulation and Functional Improvement
This outcome measure encourages quality care by allowing the patient’s recovery to affect the final score. The only way for performance to be met in this measure is to document a significant improvement in ankle function, or to confirm that there is no problem with function.

SCG3: outcome Assessment for Patients Prescribed Foot Orthosis for Ambulation and Functional Improvement
Similarly to SCG2, this outcome measure’s score relies on patient recovery. The only way for performance to be met in this measure is to document a significant improvement in foot function, or to confirm that there is no problem with function. 

SCG4: Prevention of Antibiotic or Herbal Supplement Impairment of Anesthesia
Many consumers may not be aware that herbal supplements, which are often marketed as being natural and healthy, can have negative interactions with other medications. Because of this, patients may not mention supplements when listing current medications or may be vague saying “I take a vitamin.” Physicians should have a checklist that includes discussing discussing prescribed medications, antibiotic medications and specific herbal supplements, possible complications from combinations of antibiotics or herbal supplements with anesthesia, and ensuring that the surgical team is included with anesthesia impairment prevention and management. 

SCG5: Improvement in Quality of Life from Partial Foot, Prosthetics
This measure was created to help physicians quantify how much a patient’s life has been improved by a prosthetic, with the score being based on patient questionnaires. Performance is met if a patient reports that their quality of life has improved or remains the same.

SCG6: Outcome of High Risk Pain Medications Prescribed in the Last Six Months
SCG Health created this measure to help physicians remain aware of the over prescription of dangerous medications such as opioids, benzodiazepines, anti-spastics, and NSAIDS. In order for performance to be met, a patient’s polypharmacy evaluation must result in some sort of prescription change, whether it be a reduction in the number of medications, a change to a different pain management medication or a change in dose or frequency.

If you don’t think you fit these measures, don’t fret! We’ve licensed 21 measures from seven other QCDRs that you may be able to use. Here’s a sneak peak of what other kinds of measures we have to offer:

  • MA3 Corneal Abrasion
  • ACS18 Patient Frailty Evaluation
  • AQI51 Assessment of Patients for Obstructive Sleep Apnea
  • CDR2 Diabetic Foot Ulcer (DFU) Healing or Closure
  • CODE7 Improved Functional Outcome Assessment for Knee Replacement
  • MEX1 Heel Pain Treatment Outcome for Adults
  • MSSIC1 Pre-Surgical Screening for Depression

A full list of all the great measures we are offering in 2018 can be found here.


MIPS Measure #236- Controlling High Blood Pressure

Monday, February 05, 2018

By Audrey Landers

High blood pressure contributes to nearly 1,000 deaths in America every day. This major health risk contributes heavily to heart attacks, strokes, heart failure and kidney disease. High blood pressure has almost no noticeable symptoms, which is why it is important for patients to get screened often. 

But what about once they are screened and first learn they have high blood pressure? The number one priority is to control it. Less than half of people with high blood pressure have it under control, but if they can manage it then their risk of stroke, heart disease, and even death can go down significantly.

When helping a patient control their blood pressure, you also have the opportunity to report the Merit-Based Incentive Payment System (MIPS) measure #236: Controlling High Blood Pressure.

MIPS measure #236 is a high-priority outcomes measure, meaning you can get bonus points for reporting it. The measure is defined as the percentage of patients between the ages of 18-85 whose high blood pressure was controlled during the measurement period. It should be reported at least once during the 12 month performance period for patients with high blood pressure.

It is important to note that only blood pressure reading taken by a clinician in your office will be accepted. You may not use patient reported readings, readings taken for diagnostic testing purposes, or readings taken the same day as a major surgical procedure. If you do not record a blood pressure reading then it will be assumed that the patient’s blood pressure is not under control.

This measure has a very high benchmark, requiring a minimum of 91.07% to get ten points when reporting through a QCDR.

Quality Data Code  Performance  Service Provided 
G8752
Performance Met 

Most recent systolic blood pressure
<140 mmHG 

G8753

AND

G8754
    Performance Not Met    
 
AND

Performance Met

Most recent systolic blood pressure
≥140 mmHg

AND

Most recent diastolic blood pressure
<90 mmHg 

G8755 Performance Not Met 

Most recent diastolic blood pressure 
≥90 mmHg 

G8756 Performance Not Met

   
   No documentation of blood pressure measurement    
no reason given 


For more information, you can view the entire measure here. This measure can also be reported through electronic clinical quality measures (eCQM) using CMS measure CMS165v5.


MIPS Measure#128- Help Your Patients Achieve Their New Year’s Resolutions

Wednesday, January 03, 2018

By Audrey Landers

Every Year in January people make New Year’s resolutions and every year the goal at the top of everyone’s list is to lose weight (It may even be your own resolution, I know it’s mine). It’s so common that this year media outlets have made a point of publishing lists of resolutions that have nothing to do with weight loss! The only thing more predictable than having weight loss as your New Year’s resolution is not sticking to it and forgetting about it by February, only for the whole cycle to start over again the next time you change calendars.

Photo from Pexels.com

Obesity is a national epidemic, and while no one wants to be told they have to lose weight, patients may be more receptive to your help during this time of the year. If you aren’t already, it’s also the perfect time to be reporting Merit-based Incentive Payment system (MIPS) measure #128: Preventive Care Screening- Body Mass Index (BMI) Screening and Follow-Up Plan.

MIPS measure #128 is the percentage of patients aged 18 years and older with a BMI documented during the current encounter or during the previous six months AND with a BMI outside of normal parameters, a follow-up plan is documented during the encounter or during the previous six months of the current encounter. Those with a higher than normal BMI and those with a lower than normal BMI would both be considered outside of normal parameters. You can get 9 points for this measure by reporting 50-68.89%.

This measure does allow for exceptions, which can include elderly patients for whom weight change would complicate other health conditions or patients in an urgent medical situation where treatment cannot be delayed.

 

Quality
Data
Code
 
Performance  Service Provided 
 G8420 Performance Met 

BMI is documented within normal parameters 
and 
no follow-up plan is required 

 G8417 Performance Met

BMI is documented above normal parameters 
and
a follow-up plan is documented 

 G8418 Performance Met 

BMI is documented below normal parameters 
and 
a follow-up plan is documented 

 G9716 Exception 

BMI is documented as being outside of normal limits
and
a follow-up plan is not completed for documented reasons
 
 G8421 Performance Not Met 

BMI not documented 
and 
no reason is given
 
 G8419 Performance Not Met 

BMI documented outside of normal parameters 
and
no follow-up plan is documented, no reason given 


For more information, you can view the entire measure here. This measure can also be reported through electronic clinical quality measures (eCQM) using CMS measure CMS69v5.




2018 PQRS Downward Payment Adjustments and You: How and Where to Appeal

Monday, October 02, 2017
By Audrey Landers, Intern

For the 2016 reporting period, many eligible professionals (EPs) were able to successfully report to the Physician Quality Payment System (PQRS) and avoid a downward payment adjustment. Unfortunately, that means that some EPs must still face a 2.0% reduction to all Medicare Part B Physician Fee Schedule (PFS) payments in 2018.

The Centers for Medicare & Medicaid Services (CMS) will be sending letters to the unlucky providers to notify them of the pay cut starting January 1, 2018. Two types of letters will be going out, those that apply to individual clinicians and those that apply to group practitioners.

If you believe that you adequately reported PQRS quality measures in 2016 and should not receive a downward payment adjustment, you can submit a request for informal review through two different venues. First, you can go through the CMS Enterprise secure portal. After logging in and completing the Multi-Factor Identification Process, simply select “Value Modifier Informal Review” from the PV-PQRS drop-down menu to begin submitting your request. Another option is to go through the Quality Reporting Communication Support Page. The link to the PQRS informal review page can be found under the “Communication Support Page” tab in the “Related Links” box. CMS has released a comprehensive guide to the informal review request process which can be found here.

Before making a request, you should review your 2016 PQRS Feedback Report and 2016 Annual Quality and Resource Use Reports (QRUR). Both of these reports were released on September 18, 2017. These reports can both be found in the CMS secure portal and require authorization to access. In order to gain access to these reports, you can register under one of four roles:

For group practitioners:

  • Security Official

  • Group Representative

For individual clinicians:

  • Individual Practitioner

  • Practitioner Representative

For more information on QRURs, you can check out our previous blog post discussing them.

Due to the 2018 Medicare Physician Fee Schedule Proposed Rule that was released on July 17, 2017, the PQRS reports and QRUR may be subject to change. The Proposed Rule suggests retroactively relaxing the Value Modifier Policy to allow more physicians to meet minimum requirements. The payment adjustments shown in the PQRS feedback reports are based on these proposals:

  • Reduce the automatic downward Value-Based Payment Modifier (Value Modifier) adjustment by half for practices that did not meet the minimum quality reporting requirements.

  • Hold all practices that met the minimum quality reporting requirements harmless from downward Value Modifier payment adjustments based on performance.

  • Reduce the maximum upward Value Modifier payment adjustment for performance for large practices to align with the adjustment for small and solo practices.

  • Reduce the number of measures that must be satisfactorily reported for the 2016 PQRS to avoid the 2018 downward payment adjustment from 9 measures across 3 National Quality Strategy domains to 6 measures with no domain requirement.

CMS will issue an update if these proposals are not finalized.

Your request for informal review must be made by December 1, 2017 at 8:00 PM Eastern Standard Time. Making a request for informal review can be a time-consuming and frustrating process so it is imperative that you get the ball rolling as soon as possible. When you request an informal review, you should be able to point to specific data in your 2016 PQRS feedback report and QRUR to show that you should not receive a downward payment adjustment. You need to do all the legwork for CMS to ensure that you have a fair shot at appeal.


CMS Flexibility on MACRA MIPS Requirements Means They’re Bending Over Backwards to Assure Participation

Tuesday, September 27, 2016

By: Ben Regalado, contributing writer

After considering a delay to the start of the new MACRA payment reform initiatives, CMS recently announced it has decided instead to allow providers to determine the speed that they will be able to implement the new requirements, lessening the potential penalties (and benefits) in exchange for breathing room to begin full participation.

Most physicians, it is believed, will opt for the Merit-based Incentive Payment System (MIPS) methodology over the riskier, though more integrated, Alternative Payment Models (APM) such as Accountable Care Organizations (ACOs) and Patient Centered Medical Homes (PCMH). (That is approaching a record for number of acronyms in a sentence.) Although unstated, it is believed that the new “flexibilities” were made to give consideration to smaller practices who still wish to remain independent.

Although final regulations are not expected until November 1, the MIPS program is on track to begin January 1, 2017, with the impact on payments to be up to +/- 4% in 2019. Those providers who are ready - most likely medium sized to large practices - can jump right in through one of the two original options:

1. Begin with complete reporting on January 1, 2017, participating fully and potentially reaping the full reward.
2. Participate through an Advanced APM.

The new “flexibility” is found with two additional options. These options are graduated to allow for providers to ease into MIPS at a pace best suited for them, while keeping the incentives (or penalties) higher for those who are ready to begin. In these new options:

3. Eligible providers may elect to simply report any data to avoid a negative payment adjustment. This transitional approach is basically a “test the waters” approach to assure systems and process are ready to go for 2018 and 2019, or

4. Eligible providers may choose to report measures over a “reduced” number of days, meaning data reporting begins after January 1, creating an opportunity to earn at least a small bonus payment.

As reported on this site before <http://www.scghealth.com/news/take-on-mips-and-pqrs-from-searfoss>, meeting MIPS threshholds should not be an issue so long as practices are ready with their processes to meet the four aspects of MACRA MIPS reporting. Per CMS <http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html>, the relative achievements within these four pieces of the puzzle will be given various weights (to change over time), which then will be used to calculate an overall “score”. This score will then determine the amount of increase or decrease in payments that providers could see.

For 2017, eligible providers participating fully will need to focus on these objectives:

A. Reporting and meeting performance thresholds on 6 of more than 200 Quality measures (formerly “PQRS”) - 50% of year 1 score.
B. Cost Control (based on claims data) - 10% of year 1 score.
C. Reporting on participation in some of the more than 90 Clinical Practice Improvement activities - 15% of year 1 score.
D. Reporting on activities related to Advancing Care Information (formerly “Meaningful Use”) - 25% of year 1 score.

To be clear once again - this is not a delay like ICD-10. To avoid penalties you should plan to report quality data beginning at some point in 2017. Continue to watch this site for more information once the final rule is released.


PQRS Contingency Planning

Thursday, January 14, 2016

By: Jennifer Searfoss, CEO

**EXTENDED REPORTING DEADLINE** The Medicare quality reporting program runs on a calendar year basis. So it might be a relief to know that you still have time to figure out if you have enough data into Medicare to meet and exceed last year's requirements. The Physician Quality Reporting System (PQRS) has several options to get data to the Centers for Medicare & Medicaid Services (CMS). And some of these options are still open, but you need to get moving!

Photo credit: GraphicStock © 2016.

For groups that chose the free option of sending in data to CMS through claims-based reporting, you only could submit data on the first claim you sent in for that date of service. The federal health plan stated that you can't correct missed data by calling in a corrected claim. Its a once and done data submission option.

That means you may not have enough data submitted already. Or you may not have enough to meet the performance targets under the value-based modifier (VBM). There is still time to fix this!

PQRS requirements

  • Report on 50% of eligible encounters with traditional Medicare patients
  • Report on 9 measures*
  • Have performed the measure atleast once


VBM Requirements

  • PQRS performance rate must be in-line
    with the national average

* If you don't have data for nine measures, consider using the registry reporting option for measure groups. This allows you to report on a series of measures for 20 patients. Eleven of the patients must be traditional Medicare but the remaining nine could be commercial insurance, Medicaid or Medicare Advantage patients. Read more below.

Reporting options
For individual clinicians, including physicians and non-physician practitioners submitting claims to Medicare (including non-participating physicians), the alternative reporting options available after the end of the calendar year are through (1) a qualified registry or (2) electronic medical record (EMR) reporting.

Qualified registries are Medicare-acknowledged companies that aggregate data you send to them and forward it onto CMS in the Agency approved format. EMR reporting is either directly through your EMR vender OR can be handled separately through a data service vender where again the company formats the data and gets it to CMS.There is a fee, often for each clinician reporting, to use either of these methods.

Top option: Registries in our experience
So far, the majority of our Clients seeking solutions for gaps in data have chosen to go with registries. Why you might ask? Well, often there is a reason that we are coming up with solutions to fill data gaps. Sometimes its that physicians didn't hit the right button on the EMR for all nine measures to populate. Other times its that the measures that are most clinically appropriate for that physician are not clinical quality measures captured through the system. And then some times we have data that was submitted through the claims-based reporting method - but it wasn't for more than 50 percent of eligible encounters with Medicare patients so we need to go in and backfill with "performance not met" information. REMEMBER, the PQRS penalty in 2017 is for reporting not performance! So our focus is to get enough data to hit that 50% threshold which includes a mix of performance met and performance not met information.

Every PQRS Qualified Registry is different on when they require data to come into their system to meet the timeframe of getting it to CMS. The two companies SCG Health has worked with in the past have the following deadlines:

   PQRS Qualified Registry
Data Submission Deadline
 
   PQRS Pro (Healthmonix)
 March 18, 2016 at 11:59pm ET
 
   PQRS Wizard
 March 21, 2016 at 5:00pm ET  

 

Our advice from past submissions: DO NOT WAIT UNTIL THE DEADLINE to report data. We had one vender's system crash during the final hours of data submission. So, we strongly recommend that you sign up and pay for the service in early February and submit data at least one week prior to the deadline. For the list of 2015 PQRS Qualified Registries, check this out.

Assessing if you have enough data

What if you, for whatever reason, don't have data on nine measures? We strongly encourage you to check out the measure groups that also can be reported through the qualified registries. For measure groups, it is a defined set of measures that are reported on 20 or more patients. Eleven of the patients must be traditional Medicare. The remaining nine could be commercial insurance, Medicaid or Medicare Advantage patients.

There are a number of different measure groups, but the top ones we have Clients using are: Diabetes, Preventive Care, General Surgery and Total Knee Replacement. Here is the full list of 2015 measure groups.

Performance does matter; but not for PQRS

But lets say you have enough data but don't have strong performance numbers? Why does this matter if PQRS is on reporting and not performance? That's because of the Value Based Modifier (VBM), which is a separate penalty from PQRS and meaningful use, evaluates all clinicians attributed to the group tax identification number (TIN) for quality and cost. Primary care groups that do well in cost and quality can get a bonus payment for care coordination. For specialists, the goal is to be average and get a zero update. Groups considered low quality and high cost can receive up to a 4% penalty in 2017 based on 2015 performance. That's why performance matters.

Check out the 2013 performance targets. SCG Health has requested the 2014 performance targets from CMS.

If you don't know where to start with PQRS reporting, please give SCG Health a call.
This is what we specialize in!



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