2017 MIPS Quality Measures for use in LTPAC Medicine

RodBairdBy Rod Baird
Twitter: @rod99309

This article is our annual overview of CMS approved Individual Quality Measures (QM) for use by medical groups practicing in Nursing Facilities, Homecare, Assisted Living, and related places of service. It includes an exhaustive list of all measures based on CPT® codes – which are the only link to build a crosswalk to LTPAC settings.

Currently, there are no QMs intentionally developed for use in Nursing Facilities, so groups electing to fully participate in MIPS by use of individual QMs, must find 6 Measures that include CPT® codes they commonly employ. Some measures that include the Nursing Home family of CPT® Codes (i.e. 99304-99310) specify actions or clinical objectives inconsistent with typical LTPAC goals of care. We’ve tried to simplify the task of identifying QMs that fit well with your medical practice. The information is extracted from multiple CMS lists and documents and merged into a single table. The list includes the CPT® families associated with the measure, the quality domain, and allowable reporting options.

Click here to view the spreadsheet listing every QM associated with LTPAC Medicine.

In 2016, numerous Medical Groups, regardless of location, elected to report PQRS via Registry reporting of a selected Measures Group (Dementia, Heart Failure, etc.). That option is no longer available under MIPS. The only readily available reporting options are use of the GPRO Web Interface, or reporting 6 individual QMs.

Medical Groups working in the SNF/NF setting also should note that some measures that include 99304-99310, exclude discharge measures (99315-316) and the Annual H&P – 99318. This seems to illustrate a significant lack of site specific knowledge on the part of the Measures’ Developers.

More LTPAC Medical Groups are using the Medicare Annual Wellness Visit (AWV) (CPT® G0438/G0439) in POS 32. Many Medical Groups are experimenting with its use as part of a Chronic Care Management (CCM) program (99490). gEHRiMed includes QM associated with the AWV.

For the benefit of behavioral health groups covering the various LTPAC settings, the list includes two codes for Psychiatric Diagnostic Evaluation – 90971 & 90972. Based on an analysis of CMS Published Part B data, individuals providing behavioral health services in LTPAC use a combination of those, and traditional E&M codes.

For individuals and groups electing to use individual measures, there are several caveats:

  1. There are at least 6 Measures that apply to each of the CPT® Code Sets we classify.
    • a. To be eligible for a MIPS incentive payment you must report:
      • i. 6 measures,
      • ii. Including at least one Outcome measure; or a high priority measure if an Outcome measure is not applicable.
    • For POS 31/32, the only Outcome Measure available is #001 Diabetes HbA1c – poor control. This measure may be problematic in the LTC population – your benchmarks (performance scores) are marked against some very high performing ambulatory and specialty practices.
      • iii. For a single continuous 90-day period per measure,
      • iv. On 50% of your patients eligible for each of those 6 measures,
      • v. With a minimum of 20 patients in the measure’s denominator to qualify for performance scoring (i.e. receiving more than the 3 base points for reporting)
    • b. Some of the measures that apply can only be reported when a particular diagnosis and patient status are present (e.g. measure 387 – Annual Hepatitis C Virus Screening for Patients who are Active Injection Drug Users). Be thoughtful when selecting measures!
  2. There are multiple avenues to submit your measures (claims, EHR, Registry, QCDR, etc.). We still believe Registry is the most viable option for groups electing to report by use of individual measures.
    • a. A Registry gives the group a measure of control/review prior to data submission. That creates an opportunity to correct errors which often arise when Practitioners misread a poorly worded Quality Activity.
    • b. All 2017 QMs are reportable by Registry – which eliminates the need to consider the measures’ approved submission methods.
    • c. If you elect to report using ‘claims’ – pay particular attention to the measures’ allowable reporting method. Only a subset of 2017 QMs are approved for Claims Reporting

A final thought – BENCHMARKS MATTER! The only criteria for satisfying base reporting and avoiding a penalty is to successfully submit 1 measure on a single patient. If you are successful at reporting on 6 measures, what happens with the data you reported? That data is the foundation for measuring your Group’s performance under MIPS. Your 2017 MIPS scores will also be posted on CMS’s Physician Compare Website.

CMS recently posted the Quality Benchmarks for the 2018 Value Modifier and the 2016 Annual Quality and Resource Use Reports (QRUR). Providers are encouraged to check their performance vs. the benchmarks.

For 2017, CMS provided more elaborate details on Benchmarking – the methodology used in awarding ‘performance’ points, which build your total MIPS Score. Physicians are ‘graded’ in comparison to the performance reported in the prior year through PQRS by other medical professionals. For 2017, you should consider selecting Quality Measures that yield a high probability of demonstrating above average performance.

Regards, and Happy New Year!

This article was originally published on gEHRiMed and is republished here with permission.