Merit-Based Incentive Payment System (MIPS)

MACRA replaced three Medicare reporting programs with MIPS (Medicare Meaningful Use, the Physician Quality Reporting System, and the Value-Based Payment Modifier).

Under the combination of the previous programs, you would have faced a negative payment adjustment as high as 9% total in 2019, but the MACRA ended those programs, reduced the potential negative payment adjustments in the early years, and streamlined the overall requirements. While these three programs will end in 2018, if you have participated in these programs in the past, then you will have an advantage in MIPS because many of the requirements should be familiar.

To check if you need to submit data to MIPS, enter your 10-digit National Provider Identifier (NPI) number in the link below,

https://qpp.cms.gov/participation-lookup

MACRA defined four performance categories for MIPS, linked by their connection to quality and value of patient care.

Quality : Replaces the Physician Quality Reporting System (PQRS)

Most participants: Report up to 6 quality measures, including an outcome measure, for a minimum of 90 days.

Groups using the web interface: Report 15 quality measures for a full year. To submit data as a group through the CMS Web Interface, you must register your group between April 1, 2017 and June 30, 2017.

Groups in APMs qualifying for special scoring under MIPS, such as Shared Savings Track 1 APM or the Oncology Care Model one-sided risk APM: Report quality measures through your APM. You do not need to do anything additional for MIPS quality.

Advancing Care Information : Replaces the Medicare EHR Incentive Program, also known as Meaningful Use

Fulfill the required measures for a minimum of 90 days:

    Security Risk Analysis

    e-Prescribing

    Provide Patient Access

    Send Summary of Care

    Request/Accept Summary of Care

Choose to submit up to 9 measures for a minimum of 90 days for additional credit.

For bonus credit, you can:

    Report Public Health and Clinical Data Registry Reporting measures

    Use certified EHR technology to complete certain improvement activities in the improvement activities performance category

OR

You may not need to submit advancing care information if these measures do not apply to you.

Improvement Activities : New category

Most participants: Attest that you completed up to 4 improvement activities for a minimum of 90 days.

Groups with fewer than 15 participants or if you are in a rural or health professional shortage area: Attest that you completed up to 2 activities for a minimum of 90 days.

Participants in certified patient-centered medical homes, comparable specialty practices, or an APM designated as a Medical Home Model: You will automatically earn full credit.

Participants in certain APMs under the APM scoring standard, such as Shared Savings Program Track 1 or OCM: You will automatically receive points based on the requirements of participating in the APM. For all current APMs under the APM scoring standard, this assigned score will be full credit. For all future APMs under the APM scoring standard, the assigned score will be at least half credit.

Cost : Replaces Value-Based Modifier

No data submission required. Calculated from adjudicated claims.

Retrieved from https://qpp.cms.gov/

Quality Payment Program - MACRA

The Quality Payment Program that is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) improves Medicare by helping Providers focus on care quality and the one thing that matters most — making patients healthier. The Quality Payment Program is focused on moving the payment system to reward high-value, patient-centered care.

The Quality Payment Program has two tracks you can choose from:

1). Advanced Alternative Payment Models (APMs)

2). The Merit-based Incentive Payment System (MIPS).

Participate in the Advanced APM track:

If you receive 25% of Medicare covered professional services or see 20% of your Medicare patients through an Advanced APM in 2017, then you earn a 5% Medicare incentive payment in 2019.

You are eligible to participate in the MIPS track of the Quality Payment Program if you bill more than $30,000 to Medicare, and provide care to more than 100 Medicare patients per year, and you are a :  Physician, Physician Assistant, Nurse Practitioner, Clinical Nurse Specialist, Certified Registered Nurse Anesthetist. If 2017 is your first year participating in Medicare, then you are not required to participate in the Quality Payment Program in 2017.

Participate in the MIPS track:

If you choose the MIPS track of the Quality Payment Program,  you have four options.

1.Don't Participate
Not participating in the Quality Payment Program: If you don't send in any 2017 data, then you receive a negative 4% payment adjustment.

2.Submit Something
Test: If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity), you can avoid a downward payment adjustment.

3.Submit a Partial Year
Partial: If you submit 90 days of 2017 data to Medicare, you may earn a neutral or small positive payment adjustment.

4.Submit a Full Year
Full: If you submit a full year of 2017 data to Medicare, you may earn a moderate positive payment adjustment.

The size of your payment adjustment will depend both on how much data you submit and your  quality results.

Retrieved from https://qpp.cms.gov/

ICD 10 - Improving Clinical Documentation

ICD-10 is finally here and what most of us do not realize is that, it is just not enough that we are able to code in ICD-10 and get the claims billed out, we need to ensure that the documentation is specific and supportive of the ICD-10 diagnoses billed.

We need to make sure that our clinical services are documented in greater detail, so that the documentation supports a more specific ICD-10 code. Physicians / staff  involved in creating the documentation need to become more accustomed to the specific, detailed clinical documentation needed to assign ICD-10 codes.

For example, laterality is expanded in ICD-10-CM. Therefore, clinical documentation for diagnoses should include information about which side of the body is affected (i.e., right, left, or bilateral).

Some of the Clinical parameters that we need to document as per the diagnosis/condition, in order to be able to code in ICD-10-CM are,

        Clinical Documentation Parameters:

• Onset - when did it start
• Manifestation - Paralysis, Loss of Consciousness
• Comorbidities
• Etiology/Causation - Infectious agent, Physical agent, Internal failure, Congenital
• External Causes - Motor vehicle, Injury, Assault, Accidental, Work related, Intentional Self harm
• Complication
• Detailed Anatomical Location - Proximal, Distal, Medial, Lateral, Central, Peripheral, Superior, Inferior, Anterior, Posterior
• Functional Impairment
• Biological & Chemical Agents
• Phase/Stage
• Lateralization /Localization - Rt side, Lt side, Bilateral or Unilateral
• Severity - Mild, Moderate or Severe
• Time Parameters - Intermittent, Recurring, Postoperative, Postdelivery
• Encounter type - Initial, Subsequent
• Healing Level - Routine healing, Delayed healing, Non-Union, Malunion e.t.c

Below are some examples of the specific information that would have to captured and documented to accurately code the following common diagnoses in ICD-10:

        Diabetes Mellitus:

• Type of diabetes
• Body system affected
• Complication or manifestation
• Long-term insulin use

        Fractures:

• Site
• Laterality     
• Type - open, closed
• Encounter type - Initial, Subsequent   
• Healing Level - Routine healing, Delayed healing, Non-Union, Malunion e.t.c

        Injuries:

• Place of occurrence
• External cause - Cause of injury, how the injury happened
• Activity code - what the patient was doing at the time of the injury ?
• External cause status - Injury related to military, work or others

It will be important to make your documentation as detailed as possible, since ICD-10-CM gives more specific choices for coding diagnoses. This information is likely already being shared by the patient during the encounter, it is a matter of capturing all the pertinent information so that we can choose the most appropriate ICD-10 Dx. Proper documentation helps to reduce denials and increase compliance.

New Patient or Established Patient ?

Who is a New Patient ? When do we bill a New Patient ? When does a Patient become an Established Patient ? These are some of the questions that confuse some practices when billing New/Established patients.

There are instances when a patient is seen by a Physician in the Hospital and in the Office and many Practices are not clear as to how to bill the patient visit. 

Determining whether a Patient visit is to be billed as a New Patient visit or an Established Patient visit has significant implications from a Clinical, Financial, Billing and Coding standpoint.

"A New Patient visit is an evaluation and management service provided to a patient who has not received any face-to-face service from any physician of the same specialty who belongs to the same group practice for at least three years".

Conversely an "Established Patient visit is an evaluation and management service provided to a patient who has already received any face-to-face service from any physician of the same specialty who belongs to the same group practice in the last three years".

An established patient is one who has received professional services from the physician/qualified health care professional or another physician/ qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past three years - See more at: http://www.aap.org/en-us/professional-resources/practice-support/Coding-at-the-AAP/Pages/New-Vs-Established-Patient.aspx#sthash.O0LGrQSh.dpuf

New Patient visits

1. Patient John Doe comes to see Dr A in his practice after a period of 4 years.

2. Patient John Doe was seen by another physician belonging to a different specialty in the same multispecialty practice, but Patient John comes to see Dr A for the first time.

Established Patient visits

1. Patient John Doe comes to see Dr A in his practice for the first time, Dr A has never seen Patient John before but Dr B another physician in Dr A's practice has seen patient John last year.

2. Patient John Doe was seen by Dr A in the hospital a month ago, he comes to see Dr A in his practice for the first time. Since Dr A has seen patient John within the last 3 years, the office visit becomes an Established visit.

E&M and other Procedures

In a Patient encounter we might perform procedures apart from the regular E&M procedure, in such instances payors would deny the E&M procedure but would pay the additional procedure alone.

Let us take an example of an encounter where a Trigger Point Injection (CPT 20553) is given and an E&M procedure (99213)  is also performed.

The procedure 20553 has an Evaluation component built into its reimbursement, this is the reason why payors may deny the payment for the E&M procedure. So the Payors are right in denying the E&M procedure if the E&M procedure is not distinct and not separately identifiable from the other procedure performed.
 
But We are definitely allowed to bill a Procedure (20553)  and a distinct E&M service (99213) on the same visit, as long as the E&M service is separate and distinct from the procedure, and the same is documented in the progress notes. A distinct E&M service refers to an evaluation where the service is significant and separately identifiable from the other procedure.

An example would be :  

20553        Trigger point Inj                                 
99213 - 25  E&M service for  HTN, DM, CAD   
 
Here the E&M service is separate and distinct from the Procedure 20553, the E&M service needs to be submitted with modifier 25 to indicate that it is separate from the other procedure performed. If the E&M service is submitted without the 25 modifier, it would be denied.