Loyola University Chicago School of Law, JD 2018
The Merit-based Incentive Payment System (“MIPS”) is one of the two different payment methods that MACRA will use for eligible clinicians. Clinicians will be evaluated based on a single Composite Performance Score from four reporting categories: Quality, Resource Use, Advancing Care Information and Clinical Practice Improvement Activities. This article will discuss the Clinical Practice Improvement reporting category and will also touch on tips on how to maximize your overall score.
The Clinical Practice Improvement Activities category focuses on rewarding clinicians for implementing practices that support the general aims of healthcare delivery reform. These activities include expanding access to care, care coordination, beneficiary engagement, patient safety, and many more.
During the first performance year of MACRA in 2017, the Clinical Practice Improvement (CPI) reporting category’s impact on the final composite performance score will only be 15%. The MACRA final rule, which came out on October 14, 2016, did not affect this percentage despite its effect on two of the four reporting categories. Further, this CPI category’s impact on the final score in subsequent years will not change; it will continue to account for 15% of a clinician’s composite score have a 15% effect on the score.
Calculating the Clinical Practice Improvement Score
The CPI reporting category bases its score on activities. These activities will be selected by the clinicians depending on which ones best fit the clinician’s practice. The clinicians may select from a large list of activities and each of the activities carry with it a different weight. These CPI activities fall into two categories: high-weighted activities and medium-weighted activities. The high-weighted activities will each contribute 20 points to the overall score, while the medium-weighted activities will contribute 10 points to the score. In MACRA’s first transition year, CMS will allow reported activities that are met using EHR technology under the Clinical Practice Improvement category to also count for a bonus point in the Advancing Care Information category. This is one example of how the final rule tried to make this first year of reporting easier and more desirable for clinicians.
The combined score of activity points will then be measured against a target score. The proposed rule suggested full credit in this category be achieved at 60 points. However, the final rule lowered the threshold to 40 points for the first coverage year 2017. This means that clinicians may achieve full credit from 4 medium-weighted activities or 2 high-weighted activities instead of 6 medium-weighted activities or 3 high-weighted activities. The CPI category score will be calculated by dividing a clinician’s CPI score with the full credit threshold for that year. The resulting percentage will be used to calculate the final composite performance score for the entire MIPS payment method.
The final rule went even further for small practices (15 or less clinicians), rural practices, areas with a shortage of physicians and non-patient facing physicians (such as radiology). These clinicians will have an even lower threshold for receiving full credit. Full credit for these practices may be achieved through 1 high-weighted activity or 2 medium-weighted activities.
Clinical Practice Improvement Subdivisions
The CPI category is also broken down into subdivisions. These subdivisions look at the broad aims of healthcare delivery and the final rule establishes 6 of them: expanded practice access, population management, care coordination, beneficiary engagement, patient safety and assessment, and participation in an APM. The expanded practice access subdivision focuses on increased access for patients including same day emergency appointments, as well as after-hours services. The population management subdivision is an example of a medium-weighted category under CPI. This subdivision looks at the overall monitoring of a clinician’s patients and also identifying the need for urgent intervention. Care coordination is also a medium-weighted reporting activity which analyzes a clinician’s response time in terms of, among other things, the communication of test results, remote monitoring, telehealth, and health information exchanges with a patient’s other providers. Beneficiary engagement and patient safety and assessment are both examples of high-weighted activities. The beneficiary engagement subdivision centers on the patient experience and what providers can do to improve that experience. It looks at how providers establish care plans for their patients through the use of shared decision making, as well as provider and employee self-monitoring and training. Finally, the patient safety and assessment activity concentrates on the processes that providers can employ to increase patient safety through the use of clinical and surgical checklists and updated provider and employee certification.
Most of these subdivisions are activities that will add to the final CPI score, however, one activity will not achieve a full credit score. The APM participation subdivision may only receive half of the highest CPI category score the clinician achieves. The final rule allows for a favorable scoring for APM participants who are deemed to not be qualified participants, but choose to report in this CPI reporting category. Nevertheless, APM participants have the opportunity to report additional activities to receive that full credit score.
With the release of the MACRA final rule, the overall reporting scheme for the first reporting year 2017 was made significantly easier for clinicians. Especially with 2017 around the corner, clinicians should now go back through the new final rule and figure out what exactly will change with their reporting for this first year. The Clinical Practice Improvement reporting category will not be a large percentage of any reporting year, however, it will be one of the easier reporting categories to achieve. Compliance officers should begin looking at the subdivision activities, keeping in mind the Advanced Care Information Performance reporting category, because these two categories will go hand in hand for this first year.