2018 MIPS Quality Measures for use in LTPAC Medicine

February 22nd, 2018 by Rod Baird

For 2018, Quality Measures count towards 50% of the MIPS Score.  If reporting Quality is part of your MIPS strategy, this article is for you. It’s our annual overview of CMS-approved Individual Quality Measures 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 LT-PAC settings

For 2018, CMS faced two competing objectives – add rigor to MIPS, while making it less cumbersome.  Congress mandated the increased rigor, so Practitioners would heighten their focus on both Quality and Cost (spending).  CMS’s solution for reducing reporting loads was to create more reporting options (e.g. Individual, Small group, or Large group).  Unfortunately, the combination of increased rigor and options creates a huge number of possible strategies.  GPM created a webinar to explain the range of strategies based on Group Size and Performance Objectives – Click here to access the webinar.

Regardless of which MIPS reporting strategy you are employing, the selection of 2018’s Quality Measures is increasingly important – you must make two critical decisions when selecting Quality Measures:

  1. Is the Measure eligible to use with your normal CPT® codes? For example, Pneumococcal Vaccination Status for Older Adults is not eligible for use with Nursing Facility CPT® codes.

How are you going to report Quality Measures to CMS?  Many groups choose to use Claims Reporting to avoid Registry Fees – but if they used one or more of the 5 Dementia Measures, they’ll receive NO credit; those measures are not eligible for Claims Based Reporting. Currently, there are still 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 the CPT® codes they commonly employ, and are eligible for reporting by their chosen method.   Some measures that include the Nursing Home family of CPT® Codes (i.e. 99304-99310) specify actions or clinical objectives inconsistent with typical LT-PAC goals of care.  We’ve tried to simplify the task of identifying QMs that fit well with your medical practice; the following takes you to a spreadsheet listing every QM associated with LTPAC Medicine.

Download the 2018 MIPS Quality Measures for use in LTPAC Medicine

In 2017, many Medical Groups elected to satisfy MIPS reporting by submitting a few claims with attached Quality Measures. Even a single Part-B claim could earn the Individual Practitioner 3 MIPS Points, the threshold to avoid a <4%> Penalty.  For 2018, avoiding MIPS penalties is harder; Individuals or Groups must earn a minimum of 15 points to avoid penalties.

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.

Commendations to AMDA’s Alex Bardakh; he is working with NCQA (National Committee for Quality Assurance) – the Measure Steward for many preventative measures that overlooked CPT® codes 99304-99318 (e.g. Pneumococcal Vaccination Status for Older Adults).  If LT-PAC CPT® codes are added to some key measures, a more acceptable group of Quality Measures will be available for use.

More LT-PAC Medical Groups are using the Medicare’s Annual Wellness Visit (AWV) (CPT® G0438/G0439) in POS 32.  We’ve added the QMs associated with the AWV; those CPT® codes ‘unlock’ 20 additional Quality Measures.  If you perform AWVs on twenty or more patients, Large Groups will be able to use those AWV codes for MIPS reporting.

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

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.

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.
      1. You are required to select at least one Outcome or High Priority Measure; many are available.
      2. For full credit you must report on a minimum of:
        1. 6 measures,
        2. Including at least one Outcome or High Priority measure
        3. For the entire year,
        4. On 60% of your patients eligible for each of those 6 measures,
        5. With a minimum of 20 patients in the measure’s denominator.
      3. 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 group reporting.
      1. 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.
      2. All 2018 QMs are reportable by Registry – which eliminates the need to consider the measures’ approved submission methods.
      3. If you elect to report using ‘claims’ – pay attention to the measures’ allowable reporting method. Only a subset of 2018 QMs are approved for Claims Reporting

Once you are successful at reporting on 6 measures for the required number of patients, what happens with the data you reported?  It’s Benchmarked against historic performance levels for each measure. That data is the foundation for measuring your Group’s performance under MIPS.

A final thought – BENCHMARKS MATTER!

For 2017 & 2018, CMS provided 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. CMS recently published a table of benchmarks for 2018.  For 2018, you should consider selecting Quality Measures that yield a high probability of demonstrating above average performance. Your 2018 MIPS scores will also be posted on CMS’s Physician Compare Website.  While few consumers are likely to make use of that feature, we’ve already gotten reports that Hospitals and BPCI Conveners are using this site as a screening tool for network development.

Rod Baird

Rod Baird

About Rod Baird

Rod Baird is the Founder and President of Geriatric Practice Management (GPM). Since 1977, he’s led provider and management organizations that deliver care to Medicare/Medicaid beneficiaries. Past programs he’s overseen include home health, personal care, hospice, rehabilitation hospitals, adult and psych daycare, alcohol/drug rehabilitation, industrial medicine and primary care practices. The Centers for Medicare and Medicaid Services (CMS) selected Baird as one of only 73 individuals to serve with its InnovationProgram. His educational background includes a Master’s Degree in Physical Chemistry from the American University, Washington, D.C.

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