Overview of the 2020 Quality Payment Program Final Rule

Overview of the 2020 Quality Payment Program Final Rule


Hello, everyone. Thank you for joining today’s overview of
the 2020 Quality Payment Program Final Rule webinar. During this webinar, CMS will provide an overview
of the final rule for the 2020 performance period of the Quality Payment Program. After the webinar, CMS will take as many questions
as time allows. Now I will turn it over to Kati Moore, Health
Insurance Specialist. Please go ahead. Great. Thanks, Stephanie. And good afternoon to everyone. Thank you so much for joining us today as
we’re going to go through our 2000 — 2020 Quality Payment Program Final Rule overview
that we released our final rule on November 1st. We’re really excited to have so many people
on the call today. We have a lot of great information, so we’re
going to keep moving through our slides and definitely use the chat function if you have
questions throughout the presentation we have. A lot of our subject matter experts in the
room and on online to help answer questions as we’re going through. And we’ll definitely have a Q&A session at
the end. So you’ll definitely get opportunities to
speak with us some more at the end. So thank you all for being here. And with that, I have the pleasure of introducing
Dr. Reena Duseja, who’s our Chief Medical Officer for Quality Measurement in the Quality
Measurement and Value-Based Incentives Group within CCSQ, the Center for Clinical Standards
and Quality. So thanks, Reena. Thanks, Kati. It’s wonderful to be here today to talk with
all of you. I wanted to just provide some framing points
about where we are with the 2020 final rule in terms of our approach and how we’re thinking
about the direction of MIPS. And then after that, I’ll turn it back to
Kati, I think, to go through some more of the details of the actual specifics in the
rule. So first, I just want to give some thoughts
around the Quality Payment Program. We know that the Quality Payment Program is
an opportunity to really take a comprehensive approach in how we think about payments instead
of basing our payment on how you bill, right? We’re really looking at the dimension of quality
through a set of evidence-based measures that were primarily actually developed by, you
know, clinicians and measure stewards to really drive toward improving the care that they’re
delivering to their patients. As a reminder, the categories within MIPS
include Quality, Cost, Improving Activities, and Promoting Interoperability. And what the program is trying to do is encourage
improvements in clinical practice and these efforts are increased by, advances in technology
that allow for you to exchange needed information. And in addition, we have special provisions
to participate in certain new models of care that provide an alternative to fee-for-service. So we are working toward implementing policies
that you see in the rule this year, that reward high quality treatment of patients. So really continuing the shift toward value-based
care and advanced alternative payment models. And the goal, again, is to foster competition,
choice, quality, affordability, as well as innovation in this space. So for the 2020 performance year, we are maintaining
many of the requirements from the 2019 performance year. But we also are providing some very needed
updates to both the MIPS and Advanced APM tracks. And that’s really to really direct us to continue
to reduce burden but also responding to the feedback that we have heard from the clinicians
and stakeholders and also to allow us to align with what’s required by statute. This rule does introduce and finalize this
new participation framework for MIPS in what we’re calling the MIPS Value Pathways, or
MVP, which will begin in 2021. This participation framework will unite, actually,
the four categories that I mentioned earlier and connect the measures and activities across
the categories. This, we believe, will help streamline reporting
requirements, reduce reporting burden, and again, enhance the overall cohesiveness to
the program. In addition, the MIPS Value Pathways will
remove barriers to he lp encourage participation in Advanced Alternative Payment Models. So this — the goal of moving toward MVPs
is also — is an ability also to help providers ease from the transition between the two tracks
of the Quality Payment Program. These changes will create really what we believe
a more practical and cohesive program for each clinician regardless of their specialty
or practice size, to participate within the program and really drive toward value. Now we do recognize in what we heard from
the proposed rule and through the comments with stakeholder concerns about the MVPs ’ timeline. So we are committed to a smooth transition
that does not immediate eliminate — immediately eliminate the current MIPS framework. But we want to engage with stakeholders to
go to co-develop the MVPs. And this will align with our goal of moving
away from the siloed performance category activities and measures toward a set of options
that are meaningful to patient care for clinicians and actable to their scope of practice. We also know that this is really a significant
shift in the way that clinicians have potentially participated in MIPS. Therefore, I’m going to express our commitment
to work closely with the clinicians, patients, societies, and third parties, and others to
establish these Pathways. We want to continue to develop the future
state of MIPS together with all of you to ensure that we’re reducing burden, driving
value through a meaningful participation and most importantly improving outcomes for patients
, so we intend to develop these in collaboration through dialogue and additional feedback. So you can look at the updated MVPs webpage
on the QPP website. That should be going live this week. This will include an overview video of the
MVPs and also we’ll highlight future engagement opportunities. So in conclusion, just want to reiterate we’re
committed to continue to build a MIPS program that achieves our objectives in achieving
high value care in conjunction with and partnership with you. So we look forward to that partnership as
we continue to help transforming MIPS over the next several years to ensure that we’re
reducing burden, we’re driving value through meaningful participation and most importantly
improving outcomes for our patients that we’re taking care of. And with that, Kati, I’ll hand it back to
you. Great. Well, thanks, Reena. So next slide, please. Oh, we have skipped. One more ahead. So we’re just going to go through our agenda
for today. So we’ll just go through a couple really high-level
refresher slides that give you an overview. The Merit-based Incentive Payment System or
MIPS. Then we’ll go into some more details specifically
about our MIPS Value Pathways that Dr. Duseja just touched on. And then we will go through final rule of
the 2020 performance period. We’ll go through what policy changes we’re
going to see for MIPS specifically. We’ll have a couple slides on public reporting
and Physician Compare. Then we’ll go over to our colleagues at CMMI
to talk through all — our Alternative Payment Model changes for 2020. And then we will ride it off with help and
support and resources that are available and we’ll start our Q&A session. Next slide, please. One more. All right. So, just briefly here, we wanted to just do
a quick overview of MIPS for 2020. So, MIPS, the Merit-based Incentive Payment
System. We — so we have — Dr. Duseja said, we have
four performance categories in MIPS. We have Quality, Cost, Improvement Activities,
and Promoting Interoperability. And you’ll get to hear more later in the presentation,
a lot more details on each of those specific performance categories and changes that you’ll
see in the 2020 performance year. And right here underneath, it just shows what
— how much each of those performance categories are weighted for 2020. So 45% for Quality, 15% for Cost, 15% for
Improvement Activities, and 25% for Promoting Interoperability, which adds up to our hundred
percent total final score for MIPS. And we have a later slide that goes into more
detail about how that final score percentage compares to your performance threshold and
how that eventually determines your payment adjustment for 2022. Next slide, please. And these are just some refresher terms that
we’ll use throughout the presentation just for folks that may be new to our Quality Payment
Program. And this is one of your first webinars that
you’re hearing us all speak about the program, when we talk about TIN, your identification
number, NPI, National Provider Identifier. And then we use — a lot of times we use our
TIN, NPI combination. And then the chart just shows you when we
talk about different years of the program. We typically talk about the performance year
just so people can know what year we’re talking about as we’re currently in 2019 performance
period, which corresponds to year three of the program, and the 2021 payment adjustment
year. And then a lot of what you hear from today
is all about our 2020 performance period policies or year four that correspond to our 2022 payment
year. Next slide, please. All right. And this is just a high-level timeline of
how the program works. So we start with the 2020 performance year,
which we’re going to go through the policies for that today. And that begins on January 1st, 2020. And then so you’ll collect all your data throughout
the performance year. And then the following year in 2021 is when
you submit data to CMS and then that summer following the date of submission period, you’ll
receive a lot of different feedback — performance feedback from CMS including your payment adjustment
information and then payment adjustments start January 1st, 2022. Next slide. All right. So I’m going to hand it over to Molly MacHarris
who’s going to get us started talking about our MIPS Value
Pathways. Okay. Great. Thank you, Kati. And thank you again everyone for being here
today. So I first wanted to talk about our MIPS Value
Pathways which was Dr. Duseja talked about earlier that is a new participation framework
which will be — begin being available in 2021. So again not in this most upcoming year but
it would be available in year five beginning in calendar year 2021. We’ve received a fair number of questions
on the start date of that, so I just want to be really clear there. So again, the MIPS Value Pathways, the earliest
those would be available for clinicians to participate in would be in calendar year 2021. But let me back up for a minute and touch
on a little bit of detail of the problem we’re trying to solve for with the MIPS Value Pathways. So what we’ve been hearing from clinicians
on is that while the MIPS program is an improvement from the legacy programs of PQRS, the Physician
Value Modifier, and the Medicare EHR Incentive Program, the structure that we have within
the MIPS program still is producing a lot of confusion for clinicians. There’s too much choice and complexity when
it comes to selecting measures and activities,
the measures and activities across the four performance categories may not always be meaningful
to a clinician specialty. And for patients, it’s really hard for them
to look at the information and be able to make informed decisions when selecting their
clinician. So while we have been making improvements
within the MIPS program and slowly increasing the requirements as required by law, for the
past few years, we do think it’s appropriate to take a new approach to the program, which
moving on to the next slide, as we’ve already mentioned a couple times here today is our
new MIPS Value Pathways or MVPs which again this part icipation framework would begin
in calendar year 2021. So what the MVPs will do is we envision the
MVPs will help remove barriers to APM participation and movement into APMs. As Dr. Duseja mentioned earlier, we also envision
what the MVPs — there will be less siloes across the four performance categories and
instead under this new participation framework, we will really be able to focus on value by
promoting quality and cost measures and improving activities while maintaining a foundational
layer of promoting interoperability as well as population health administrative claims
measures. So let’s go ahead and move on to the next
slide. First, some additional detail of some of the
things we heard through the comments process. With this new framework, we also intend to
provide enhanced data and feedback to clinicians. We also envision we would be able to analyze
existing Medicare information to be able to provide more information to improve health
outcomes. And as you’ll see on the next upcoming slide
from our diagrams, we do also envision as we move to MVPs, we can reduce the number
of required measures and activities across the four performance categories. I also do want to note that we heard really
loud and clear from commenters concerns on the implementation timeline and for us not
to move too far into MVPs too fast. So that’s something we are very much keeping
in mind. And we also heard really loud and clear that
stakeholders you want to work with us as we develop these MVPs, and that’s something we
also want to work with you on as well. We do believe that as we work to build off
the MVPs, we feel it’s really critical to have stakeholder input. Before I move on to a couple of our diagrams,
I did just want to flag that we have built out on our website qpp.cms.gov an MVPs section. So for those of you who have not yet had a
chance to go there, I highly encourage you go ahead and do that. Again, it’s at qpp.cms.gov and we have a MIPS
Value Pathways portion of that website. We also have added a brief video that provides
an overview of what the MIPS Value Pathways could look like as we work to implement them
in 2021. So let’s go ahead and move on to slide 12
to go over a diagram we’ve created. So for those of you who were able to listen
in to the proposed rule engagement sessions, this diagram will look very familiar. But as you can notice in the middle column,
we have indicated that the MIPS Value Pathways will begin in calendar year 2021. So just to briefly walk us through this diagram,
I won’t spend too much time here since we have a lot of content to cover, what we have
on the left-hand side is the current structure of MIPS. So again, we’ve been hearing pretty consistently
from stakeholders is there’s too much choice, too many measures and activities. And as you can see from looking at those four
performance categories, the number of measures and activities that a clinician could be required
to participate in could be upwards to 20 measures and activities. As we look to move to MVPs, moving to the middle column, you can start
seeing closer alignment between Quality, Improvement Activities and Cost. And we also do envision that when we move
to the MVPs where the requirements of clinicians have to comply with across the performance
categories as they become more aligned the number of measures and activities can be reduced. And then moving to the most right-hand side
of the slide as you go to the future state, we see an even closer alignment between Quality,
Cost and Improvement Activities while still maintaining that foundation al layer of Promoting
Interoperability, population health metrics but also expanding out to expanded performance
feedback and patient reported outcomes. Let’s go ahead and move on to the next slide. So just a brief example that we had put together
of what an MVP could look like for surgeons. Again, this is just an example, so I will
just focus on the call out box here. As you can see on the call out box, what an
MVP could look like for general surgeons, we have a few quality measures in here, a
few Improvement Activities and a few cost measures that we feel would be applicable
to surgeons. And then on the following example on the next
slide, we’ve also crafted an example of what an MVP could look like, for example, an endocrinologist
who is focused on their patients with diabetic care. Again, these are examples of what MVPs could
look like. We very much intend to work with stakeholders
as we work to build these MVPs out which again the earliest that MVPs would be available
for participation would be in calendar year 2021. So that’s everything I have on MVPs. Happy to take questions on this if any of
you have them during the Q&A period, but let’s go ahead and move along to the next slide
so I can start talking through the specific final policies for the 2020 year. So next slide again. So for eligibility, overall, no changes were
made to eligibility for this year. So for 2020, again, our fourth year of the
program, we have the same eligible clinician types that existed in 2019, so physicians,
PAs, NPs, clinical nurse specialists, CRNAs. We also of course expanded our eligible clinician
types last year to include physical therapists, occupational therapists, speech language pathologists,
et cetera. So no changes from 2019 to 2020. And then moving on to the next slide, we have
no changes to our low-volume threshold. So the low-volume threshold values are still
set at the same numbers as they were for 2019. So again, they are set at $90,000 in annual
billing providing services to 200 patients or rendering 200 services. To be eligible, you would need to exceed all
three of those values. If you fall below all three, you are excluded. And then if we move to the next slide, I can
briefly explain our opt-in policy which, again, no changes were made to our opt-in policy. So again, for the 2020 year, if you meet one
or more of those low-volume threshold criteria but not all three, you would have the opportunity
to opt-in to the program if you would like to do so. So for example, if you bill a hundred thousand
annually, you render 500 services but you only see 100 patients. That means that you would be opt-in eligible
because you didn’t exceed all three of those values. You exceeded two of those so you would have
the choice to opt-in. If you decide to opt-in, you would be considered
a MIPS eligible clinician and that would include all of the opportunities that come with that
which includes the ability to achieve a positive payment adjustment but it also includes the
risks of potentially having that negative payment adjustment if you don’t have
your final score above the performance threshold. Let’s move on to slide 19 to go — so the
last piece I wanted to touch on for eligibility is where can you go to check your eligibility
status. So we do of course still have our participation
look-up tool. You can enter your NPI and we’re able to provide
information on your eligibility status. If you have not yet used this tool, I highly
encourage you to do so. We provide this update or this ability for
you to look up whether or not you’re eligible and whether or not you have any special statuses
per year. So again, I highly encourage all folks to
go ahead and take a look at that. Okay. That’s everything for eligibility. Let’s go ahead and move on to the next slide
and I’ll start talking through some of the performance category changes. Let’s move on to the next slide again. Okay. Great. So just to briefly touch on the four performance
categories, and we will go into all of these in more detail but just as a teaser of what
you will be hearing in coming slides. So for Quality the major changes we made there
where we did finalize our proposal to increase data completeness to 70%. We did remove a number of our proposed measures,
we had marked for removal. But as part of further implementation of our
meaningful measures initiative we also finalized our policy to have a different benchmarking
approaches for certain measures that potentially can incentivize inappropriate treatment. And we also finalized seven new specialties
set. For Cost we finalized our proposal to add
in 10 new episode-based cost measures and we revised the two global measures, the Medicare
Spen ding for Beneficiary, and Total Per Capita Cost Measures attribution methodology. For Improvement Activities we did finalize
our proposal to increase the group threshold to 50%. The one piece I want to note there is that
we finalized that where clinicians would need to achieve that 50% threshold for any continuous
90-day performance period during the calendar year. We also made some updates to Improvement Activities
inventory and we concluded the studies that was available under Improvement Activities. And for Promoting Interoperability, we kept
the Query of PDMP measures optional, we remove the Verify Opioid Treatment Agreement measure
and reduced the threshold for a group to be considered hospital-based to 75%. Again, we will be going over more of these
details or these updates and more details in coming slides. Let’s move on to the next slide for performance
category rate. So again no changes from where these rates
are set for 2019. We did not finalize our proposal to modify
the Quality and Cost rates. So for 2020 Quality again will count for 45
points for your final score, Cost will count for 15 points for your final score, and Improvement
Activities and Promoting Interoperability will both count for 15 and 25 points. Okay. Let’s move to the next slide and start talking
through the Quality performance category. Okay. Great. Thank you. So starting with the basic, so Quality still
counts for 45 points for your final score. As I mentioned during our highlight, we did
reduce the total number of measures available from last year 2019. I think they were around 250 measures, now
we have 218 measures. Again we have continued to implement the Meaningful
Measures Initiative which is really focusing on ensuring we have measures within our program
that are meaningful to clinicians and provide value to patient. We still have our performance criteria for
quality that if you want to achieve a maximum points under Quality you would need to select
six measures. One of those measures would need to be an
outcome measure. If an outcome measure isn’t available you
would need to select another high priority measure. The other examples of high priority measures are listed on the slide
here. If less than six measures apply, you would
need to report on each measure that applies to you. And if you find it too difficult to select
your six measures from our set of 218 measures that are available within our shopping cart
we also have created specialty sets which does a little bit more work for you where
you can just go and search by your specialties for the specialty set of measures. Moving on to the next slide just again some
refresher basics, we do continue to have bonus points available in the fourth year. We have bonus points available if you report
on additional outcome or patient-experience measures after the first required outcome
measure. We also have bonus points for recording on
additional high priority measures. We also have bonus point s if you use your
— if you submit data to us in an end to end fashion. And we also continue to have our small practice
bonus that is available for any clinicians that are part of a small practice. Again you’re small practice if you have 15
or fewer clinicians and you would just need a report on one quality measure to be eligible
for that small practice bonus. For data completeness as I mentioned previously
we did increase our data completeness threshold to 70% for all of our collection type. If on any given measure data your data completeness
threshold falls below 70%, the maximum number of points you can achieve on that measure
is one* out of ten points unless you are part of a small practice and then you could achieve
three out of ten points. So again highly encourage all of you to report
the measures on really all of your patients so you can ensure you achieve that 70% data
completeness threshold. Moving on to the next slide. A few updates for our measure set. Again as I mentioned a couple of times here
we have continued to implement the Meaningful Measures Framework which is focusing on — improving
our standard of care and process measures and ensuring the measures within our measurement
set are really those that are most meaningful and applicable to clinicians. We also have finalized some specialty sets. On the next slide we also, as I mentioned
a couple of times here, have finalized our increased data completeness requirements to
70%. Moving on to the next slide we also finalized
some additional measure removable criteria specifically we would remove measures that
do not meet case minimum volume and recording volumes and that could not be benchmarked
for two consecutive years. We also would consider removing quality measures
if we determine that that measure is not available for reporting for all clinicians including
third parties. And then moving on to the next slide, the
last piece I wanted to touch on for quality is as I’ve mentioned again at the highlight,
we did finalize our proposal to apply flat percentage benchmark for measures where we
determine that achieving 100% performance on the measure could result in inappropriate
treatment for certain patients. So the two measures we’ve identified that
this would be applying for in the 2020 year is measure number one, Hemoglobin A1c Poor
Control and measure number 236 , Controlling High Blood Pressure. So again for both of those measures at the
top of that file that would switch from being broken out based out of our reduced files
and instead at a flat percentage benchmark. And that is everything I have for Quality,
so moving on to the next slide I’m going to go ahead and turn the presentation over to
my colleague Joel Andress to talk about costs. Joel. *Correction: you would receive zero points
for failing to meet data completeness requirements Thank you, Molly. Good afternoon everyone, my name is Joel Andress,
I’m the Cost measure lead here at CMS. Move to the next slide please. As Molly has already indicated for 2020, the
Cost performance category will comprise of 15% of your MIPS final score which is the
same as 2019. The primary changes for the report here in
the cost performance category center around the Cost measures set, which has now includes
a total of 20 cost measures. As before the measures are calculated using
clinician claims data, this will incur no additional reporting burden on providers. Each type of measure carries a case number
that must be met or exceeded by you or your group in order to be scored for that cost
measure. Next slide, please. As part of the final 2020 rule, we have finalized
the addition of 10 new episode-based cost measures. We’ve also incorporated substantial revisions
to the Total Per Capita Cost Measure and the MSPB Clinician Cost measure. Next slide, please. On this slide we provide a summary of the
measure changes that have occurred from 2019 through 2020. In addition to the 10 new acute medical and
surgical episode-based cost measures, we provided the MSPB and the TPCC cost measures. The case minimums for these measures remain
unchanged from 2019, so those remain case minimum of 20 for the Total Per Capita Cost
Measure, 35 for the MSPB measure. 20 for acute medical inpatient episode-based
cost measures. 10 for surgical procedure of episode-based
cost measures. Next slide, please. As part of the revisions to the TPCC and the
MSPB we have updated their measure attribution logic for 2020. TPCC attribution now requires a billing of
E&M services combined with either a primary care service or a second E&M service from
the same clinician group. These measures also exclude specific clinician
categories who deliver primarily non-primary care services to ensure that they’re not inappropriately
attributed to this measure. The MSPB attribution now establishes attribution
differently for surgical and medical patients. Attribution is specifically defined for individuals
and groups within the applicable measures, specifications that are available on our site. For procedural episode-based cost measures,
we attribute episodes to each MIPS eligible clinician who renders into their service. And for acute , in-patient medical condition
episodes, we attribute patients to each MIPS eligible clinician who bills an E&M claim
line during the trigger hospitalization under a 10, if that 10 renders at least 30% of the
in- patient E&M claim lines during that hospitalization. These attribution methods for the episode-based
cost measures are unchanged from 2019. Next slide, please. And now I will hand it over to Angela McLennan
to discuss the Improvement Activities performance category. Thanks, Joel. Can we have the next slide, please? I’m Angela McLennan. I’m the Improvement Activities lead, and I
will go over the changes that we’ve made to the performance category for 2020. You will see here the basics that have remained
the same. Improvement Activities still account for 15%
of your MIPS final score. We now have a total of a hundred and five
Improvement Activities as part of our inventory for calendar year 2020. The weight for the Improvement Activities
remain the same. A medium activity is worth 10 points while
a high activity is worth 20 points. You will still select an activity and attest
that you completed it by selecting “yes.” And you must earn 40 points to receive the full Improvement
Activities category score. If you are under the category of what we call
special statuses such as small practices, non-patient-facing clinicians and/or clinicians
located in rural or health professional shortage areas, you would be able to receive double
weighting for your Improvement Activities and you would have to report on no more than
two activities to receive the highest score. Next slide, please. So some changes that we made for 2020, we
added two new Improvement Activities while modifying seven existing Improvement Activities,
and we removed 15 existing Improvement Activities from the Improvement Activities inventory. Next slide, please. And here we have a little overview of some
of the other changes that we’ve made for 2020. We did issue a clarification on the definition
of rural areas and we increased the participation threshold for groups and concluded the CMS
study. Next slide, please. We also made some clarifications under the
Patient-Centered Medical Home Criteria. We basically just made it more clear what
that designation would look like, what a certified – accreditation would look like for a Certified
Patient-Centered Medical Home. We’ve taken out the examples that we included
before because we didn’t want to seem as though that we’re limiting any other accrediting
organizations and we’re hoping that this will streamline things and make it a little easier
for folks to understand. Next slide, please. We also finalized the policy for removal of
Improvement Activities. Previous years, we did not have a formal policy
for this. And activity will be considered for removal
based on certain criteria listed here such as if it’s duplicative of another activity,
if the activity does not align with current clinical guidelines or practice, if there
had been no adaptations of activity for three consecutive years, or if the activity is obsolete. Those are just a few. Next slide, please. We’ve also increased the participation threshold
for groups to receive credit under the Improvement Activities category. Now, a group of virtual group can impact on
Improvement Activity when at least 50% of the clinicians in the group or in a virtual
group perform the same activity during any continuous 90-day period within the same performance
year. Next slide, please. And that concludes my little overview of the
Improvement Activities, and I’ll now turn it over to Elizabeth Holland to go over Promoting
Interoperability. Thank you, Angela. Next slide, please. So, talking about Promoting Interoperability,
it is 25% of your MIPS final score. You must use 2015 Edition Certified EHR Technology. We are continuing the performance-based scoring
at the individual measure level and we continue to have four objectives. Next slide, please. So, for 2020 we provided to have a very light
footprint for the Promoting Interoperability performance category in that last year we
did a total overhaul of this performance category, so this year that’s why there are very few
changes. We are continuing the Query of Prescription
Drug Monitoring Programs or PDMP measure as an optional measure and available for bonus points. And we did remove the Verify Opioid Treatment
Agreement measure. Next slide, please. We did make a change to our definition of
how we define a group to be hospital-based. Our threshold used to be 100% of the clinicians
in the group needed to be hospital-based, and our new threshold effective in 2020 is
that more than 75% of the NPIs in the group must meet the definition of Hospital- Based
MIPS eligible clinician. Next slide, please. So there are very few changes to our objectives
and measures. As I mentioned, the Query of PDMP will remain
a yes/no. And we made that change for 2019 and we will
continue it to 2020. We will be redistributing the points associated
with the Support Electronic Referral Loops by Sending Health Information measure to the
Provide Patient Access To Their Health Information measure if an exclusion is claimed. There are exclusions for many of the measures
that if they’re applicable and claimed, the points associated with the measure will be
redistributed to another measure. We also acknowledge that there are certain
circumstances that may exist for eligible clinicians or groups where they may be prevented
from reporting on the Promoting Interoperability performance category. And in those cases, they can apply for a Hardship
Exception. We are currently accepting Hardship Exceptions
for 2019 through December 31st of 2019. So now I’m going to turn it over to Dr. Daniel
Green and he’s going to talk about Third Party Intermediaries. Thanks, Elizabeth. Next slide, please. And one more, please. Great. So, CMS is focusing on improving our partnerships
with our third party intermediaries to try to help reduce clinician reporting burden,
and we also want to try to improve the services and expand the services that are available
to clinicians. So the idea is, if a clinician so chooses,
they could go to one vendor for, like, a one-stop shop to meet all the requirements of the MIPS
program. So starting in 2020 with the 2020 performance
period, we are requiring a Qualified Clinical Data Registries or QCDRs to work together
to harmonize similar QCDR measures in an effort to reduce the overall number of measures,
but — and also to allow for better comparison among clinicians reporting on similar measure
contexts. Starting in 2021, third party intermediaries,
again, such as QCDRs and Registries, will be required to enhance their services by supporting
all MIPS performance categories that require data submission. They’ll also be required to provide enhanced
performance feedback which will allow clinicians to view their performance on a given measure,
and also compare it with others reporting the same measure. Additionally, we will be requiring QCDR measures
to be fully developed and tested prior to self-nominations, so this will be a new requirement
in 2021. Next slide, please. So, hopefully you’re able to follow along
with the slides. In the 2019 performance period, QCDRs and
Registries were not required to support multiple performance categories. In fact, we only require that they report
– – be able to report Quality and if they so
chose to report Improvement Activities and Promoting Interoperability, obviously better
still. But they’re only required to support one. But starting in 2021, they will be required
to provide services for the whole performance year and the applicable submission periods. So, if they have to stop providing services
during the year, they will need to support a transition to an alternate submission method
or third party intermediary. What we don’t want to happen is we don’t want
clinicians to be left kind of high and dry expecting to use, let’s say, Registry or QCDRA,
only to find out, let’s say, in June, perhaps after they’ve already reported, you
know, five or six mont hs’ worth of data, that that entity will not be able to report
their data. So if that comes to pass for whatever reason,
we would want and require that the QCDR or Registry that’s going out of business or not
supporting the data anymore to be able to provide a smooth transition to another vendor
on behalf of that ending conjunction with that clinician. Again, Registries and QCDRs will need to support
the reporting of measures and activities in the Quality, Improvement Activity, and Promoting
Interoperability performance categories. A third party intermediary, AKA a QCDR or
Registry, may be excepted from the requirement if their MIPS eligible clinicians, groups,
or virtual groups fall under the reweighting policies. So if for example there were no Quality measures
and then subsequently were going to have their categories reweighted, they would not necessarily
have to support that category. Next slide, please. So, our feedback policy for 2019, as you probably
know, Registries and QCDRs are required to provide timely feedback, at least four times
per year, on all of the MIPS Performance Categories that you’re supporting for a particular clinician
or crew. Starting in 2021, the feedback will still
be required four times per year, but, again, we’ll need to have information on how your
participants are performing compared to their colleagues who are reporting the same quality
action. QCDRs and Registries will also be required
to attest during the self-nomination process that they can provide this feedback four times
per year. And again, for whatever reason, your — the
QCDR or Registry cannot provide the required four feedbacks per year, we would ask the
vendor to notify CMS straight away. Again, as you know, part of the program, while
we measure and give feedback to clinicians on the Quality and Cost, and Improvement Activities,
as well as Promoting Interoperability, clinicians only have an opportunity to improve if they
know about that data during the performance year, and if they’re not doing as well on
a particular metric, it gives them the opportunity to try to do better on it for the remainder
of the year. Waiting a year and a half to get that information
obviously goes against the goals of the program. All right. So let’s — next slide, please. Let’s talk about the QCDR measure requirements. So in 2019, we did require that measures be
beyond the measurement — measure concept phase of development for self-nomination. Starting in 2020, we created some new guidelines
to help QCDRs better understand which measures are likely to be rejected during their annual
self-nomination process. So, instances where there are multiple or
similar QCDR measures that are self-nomination, we may provisionally approve both those measures
for one year with the condition that the QCDRs address certain areas of duplication with
their — with the other QCDRs reporting the same measure basically to harmonize the measure
so that for the subsequent year, the measure will hopefully have input from all of the
people wanting to report it, or have — who have submitted a similar measure concept,
and they will harmonize the measures. We will not allow duplicative QCDR measures,
we will not approve all of them beyond the one year provisional approval, and that’s
only to allow folks time to harmonize with similar measures. We also are not looking for measures that
split a single clinical practice or action into several measures that focus — and especially
if they focus on rare events, but even — that split one action into multiple measures. So if there were a measure, for example, on
hand pain, we would not expect that the measure be split out to the index finger, the middle
finger, the fourth finger, and the pinky. It would be hand pain. Similarly, we will not approve measures that
occur — that have — that surround rare or never events. We had a measure submitted once about fires
in the operating room, we would all agree that that’s a bad thing. However, in the QCDR’s experience, there were
only three fires in 21 years. That’s not good enough to discern one institution’s
Quality performance as compared to another, it’s more of a happenstance. So those are measures, for example, that we
would not approve. We’re also looking for measures to be — have
a little bit more — that drive quality more than just simple checkbox measures with no
actionable quality measure. If there is a measure in the program for two
years or more, and it has failed to reach benchmarking thresholds due to folks not reporting
the measure, that measure also may be eliminated or not approved in the subsequent year. Obviously, if the science changes behind the
measure, we would expect the measure to keep up with it, or if the measure is considered
low-bar, or not robust enough. Again, those are the other examples where
we might reject a measure. And then finally, measures that have — that
are — have attribution issues or whether quality action is not under the purview, or
direct control, if you will, of the specific clinician or group, those measures also may
be rejected. So incidents measures, for example, are tough
measures to get through the program. Next slide, please. So again, starting in 2021, the QCDRs have
to identify a linkage between their QCDR measures at the time of self-nomination to a cost measure,
Improvement Activity, or CMS-developed MVP as possible. The measures have to be fully developed, as
I mentioned earlier, and completed testing, and ready for implementation at the time of
self-nomination. So we’d want a QCDR to submit a measure for
self-nomination, we approve it, and then they’re now ready to collect data on it January of
the subsequent year. So we are looking for QCDRs to collect data
on QCDR measures prior to submission in an effort to make sure, again, it is collectible
and useable. Excuse me. If CMS determines that a QCDR measure is not
available to MIPS eligible clinicians, groups, and virtual groups reporting through other
QCDRs, we may not approve the measure. So in other words, the measure would be to
be made available to other QCDRs for their use, and you may need to enter into a license
agreement, and we are certainly not policing that, except for the fact that you do have
the license agreement, but the details of that would be subject to the agreement between
the two parties. Again, just as a reminder, if the measure
doesn’t meet the case minimum and recording volumes for benchm arking for two consecutive
years, it may be eliminated. In certain instances, we may allow for a plan
to be submitted in terms of how the QCDR plans to try to improve reporting of that measure
and we will consider that for possible continuation, depending on the contents of the plan. Next slide, please. So rejections for QCDR measures in 2020, we
did finalize guidelines, again, to try to help QCDRs understand when a measure will
likely be rejected and, of course, this would include where there are duplicative measures
in the program, or when there’s been a measure that was in the MIPS program that’s been removed
or even PQRS for that matter. That would be an instance where we would likely
reject the measure. Existing QCDR measures that are topped out,
again, will likely be rejected or removed. If you collect data in the future, as you
have more people report on that measure, and it turns out that it’s not topped out in the
future, again, with additional clinicians, we will consider it when you provide that
data again in the future. So QCDR measures that are process-based or
have no actionable quality action are going to be likely be rejected and any measures
that have potential for unintended consequence to patient care, again, would be something
we would consider with And, again, if you split a measure into multiple or several measures when one
measure would suffice would also be a problem. I think that is it for my part. Thank you, Molly. I’m not sure if the next part is yours or
not. Yes. That goes back to me, okay. And next slide, please. Okay. Just a few other items on MIPS and then we’re
going to touch on Physician Compare, and then we’re going to discuss APMs, and then we’ll
open it up to the Q&A. So as folks can see on the slide here, the
performance threshold, we did finalize our proposed performance threshold for you for
45 points. Again, as a reminder, the performance threshold
is the number that you want your final score to be at or above. If your final score is at or above the performance
threshold, that means that you would not be getting a negative payment adjustment and
that means you would be getting a positive or a neutral adjustment. I also wanted to note, as reflected on the
slide here, beginning in 2020, and for all future years of MIPS, the total amount of
pay ment we can distribute is up to nine percent, subject to a scaling factor. So let’s move on to the next slide, and I
can explain that in a little bit more detail. So as folks can see on this slide here, moving
up the table on the right – hand side, so the 2020 side of things. If your final scores are anywhere above 45
points, you will be getting a positive adjustment. If your final score is at or above 85 points,
not only would you be getting the payment adjustment that is subject to budget neutrality,
you also would be eligible for that exceptional performer bonus. Remember that exceptional performer bonus
is only available for the first six years, and we have five hundred million we can allocate
annually. So, that will go away after performance period
2022, if my math is correct. So then still going down that table, if we
look towards the bottom rows, so you can see that if your final score is anywhere below
44.99 points, we, unfortunately, would have to give you a negative payment adjustment. And you can see that if your final score is
anywhere between 11.25 points or lower, your payment adjustment would be a negative nine
percent. Again, by law, we have to provide clinicians
whose finals scores are on the lowest quartile the maximum negative adjustment. I also wanted to note that we did also finalize
the 2021 performance threshold and exceptional performer bonus as 60 points and 85 points,
so that is something folks can track to as they participate in this upcoming year. So let’s move on to the next slide and then
the next slide again just to briefly touch on a few other MIPS items. So we did also finalize a new reweighting
policy that is actually applicable for the 2018 performance period or the 2020 payment
year. So as folks know, we have a number of reweighting
policies specific to the Promoting Interoperability performance category. We also allow for reweighting if there are
extreme and uncontrollable circumstances due to natural disasters, such as, you know, wildfires,
and flooding, and tornados. We also finalized in this year’s rule the
ability for us to reweight clinician’s performance categories if we determine that data that
have been submitted is inaccurate, unusable, or otherwise compromised due to circumstances
outside of the control of the clinician or their agent. We did finalize this policy, again, effective
for the 2020 payment year, so if folks are interested in leveraging the policy for any
instances that would’ve impacted their submissions for the 2018 performance period, please let
us know of that by the end of this calendar year. And then moving onto the next and last slide
for MIPS, we also clarified our targeted review timeline that it’s 60 days following the release
of our performance feedback. And moving on to the next slide to talk about
Physician Compare, I’m going to turn the presentation back over to Angela McLennan. Angela? Hi, Angela again to go over Physician Compare
for you. If we could have the next slide, please. We have some minor updates in 2020 for Physician
Compare, one deals with the final release of aggregate performance data. This includes minimum and maximum MIPS performance
category and final scores, and will be available on Physician Compare beginning with the 2018
performance period data, available in late 2019 as technically feasible. Next slide, please. Also for 2020, we have the policy for Final
Facility-based Clinician Indicator. You publicly report — publicly report an
indicator if a MIPS eligible clinician is scored using facility based measurement as
t echnically feasible and appropriate. Link from Physician Compare to Hospital Compare
where facility-based measure information that applies would be available beginning with
2019 performance information to be available in late 2020. Next slide, please. And with that, I would like to turn it over
to Brittany to discuss the Alternative Payment Models. Thank you. So I’ll start with just a little bit of background
on APMs, Alternative Payment Models are payment approaches that are developed in partnership
with our clinician communities and provide added incentives for clinicians to provide
high-quality and cost-efficient care. These APMs can apply to specific clinical
conditions, care episodes, or population, and they may offer significant opportunities
for eligible clinicians who are not immediately able or prepared to take on the additional
risk and — financial risk and requirements of Advanced APM participation. Next slide. So, I’m just waiting for the slide to be — next
— there we go. What are the benefits of participating in
Advanced APMs? For payment years 2019 to 2024, clinicians
who meet these requirements are going to be excluded for MIPS payment adjustments and
will receive a five percent lump sum payment incentive on all their Part B professional
services furnished during the calendar year immediately prior to the payment year. So this five percent lump sum bonus is actually
in addition to any other rewards or incentives that may be offered through the APM participation
itself, and it just creates an action incentive to encourage a sufficient degree of participation
in our Advanced APMs. Next slide. To be an Advanced APM, the payment model must
meet three criteria, which are requiring participants to use cert — EHR technology, providing payment
for covered professional services based on quality measures that are comparable to those
used in the MIPS quality performance category, and either, be — they must be either a Medical
Home mMdel that’s been expanded under CMS Innovation Center Authority, or they have
to require participants to bear a more than nominal amount of financial risk. Next slide, please. Here are a few terms you may hear thrown around
in regards to the APM participation. Generally, when we’re talking about APMs,
we refer to the APM Entity which is the group of clinicians who have come together to join
one of these entities. Not all APMs use APM entities, in which case
we will usually refer to the affiliated practitioner. Next slide. There’s also the concept of MIPS APMs which
are not mutually exclusive with Advanced APMs. Many Advanced APMs are MIPS APMs, many MIPS
APMS are Advanced APMS, and through participation in a MIPS APM, if you do not achieve or not
eligible for QP status, there are certain scoring benefits within MIPS for participation
in that APM. Next slide. So here’s an overview of some final little
changes related to APM in 2020. Next slide. So for the APM Scoring Standard, which has
to do with those entities that are scored in MIPS APMs, CMS will be allowing APM entities
participating in APM the option of reporting for the MIPS Quality performance category
through MIPS on behalf of their eligible clinicians. And the goal of this is to offer flexibility
in which measures you’re being scored on, and to improve meaningful measurements and
ensure that participants are being scored on measures that have something to do with
their actual practice. C MS has also created a MIPS APM quality reporting
credit for APM participants scored under the APM Scoring Standard where the quality data
that are used for the APM are not able to be repurposed for MIPS. Meaning that they may be required to report
Quality to the two programs separately, but an acknowledgement of that burden, we are
giving a credit of equal to 50% of the total MIPS Quality performance category weights. Next slide, please. So in the Advanced APM part of the house,
we offer current [indistinct] Medical Home Models. In 2019, Medical Home Models were limited
to Medicare APMs that meet this handful of criteria primarily providing primary care
and having empanelment of each patient to a primary care clinician and then four of
the list of other criteria. Next slide, please. In 2020, we have expanded the definition of
Medical Home Models to include Aligned Other Payer Medical — Aligned Other Payer Medical
Home Models, and this includes Pther Payer arrangements other than Medicaid arrangements. So they’re being operated by another payer
other than CMS, but they have aligned themselves with a CMS Multi-Payer Model. That is a Medical Home Model through a written
expression of alignment or cooperation with CMS and all of this means that if you happen
to be participating in an Aligned Other Payer APM that meets the Medical Home Model definition,
the billing that happens through that Other Payer arrangement will help go towards your
QP calculation. Next slide, please. So there’s also been a clarification on the
definition of expected expenditures in a way which we’re going to be calculating it just
to help ensure that we are achieving our goals of ensuring that all Advanced APM payment
arrangements have a marginal risk rate of at least 30% with applicable exceptions for
large losses according to CMS regulation. Next slide, please. And here again, we just have a quick summary
of the changes that you’ll be seeing in the 2020 final rule regarding APMs — specifically
under the APM Scoring Standards. So, that does it for — that should do it
for APM in the 2020 final rule and I will pass it back to Kati. Great. Thanks, Brittany. All right. We just have I think one more quick slide
and then we’ll open up for Q&A. All right. One more please. All right. Just this slide real quick, just highlight
some available resources for small and solo practices, we still have a no-cost technical
assistance that is available for you all to really encourage
you to reach out this information on the slide and on qpp.cms.gov website. And then these are really great resource to
help walk you through participation in the program, help you understand eligibility,
and how to participate successfully as possible in the program. We also — again, we’ve talked about it throughout
the presentation, but qpp.cms.gov, we have a lot of our really good resources available
in the QPP Resource Library. And then throughout the website, we have a
number of different tools that’ll help you understand eligibility or how to submit data
to the program. In all areas of the program, we have a lot
of information. And then we also have our Webinar Library
that’s available. So, all of our presentations — I know some
folks have asked if these slides were going to be available, and the answer is absolutely
yes. We will have them available along with the
slides, the transcript of today’s presentation as well as the recording. So, we usually typically get that posted in
the next week or two after this presentation, so be on the lookout for that. And then we have our Quality Payment Program,
our service center that has really great agents that are ready, waiting for your calls and
emails to help you answer your questions. And then we also have the Center for Medicare
and Medicaid Innovation Learning System. And there’s links on this slide to all of
that information. I think that is — we’ve talked long enough
and that is all the information we have to share today. So with that, I’m going to turn it back over
to our Ketchum team on the phone to walk you all through how to answer or how to ask your
questions today. Great. Thanks, Kati. So, as Kati said, we’re now going to begin
the Q&A portion of the webinar. You can ask questions via the chat or on the
phone. So if you’d like to ask your question over
the phone, please dial 1-866-452- 7887. And then if you’re prompted, please provide
our conference ID, which is 244-2508. And then you can press 1 — *1 to be added
to the queue. And then, just as a reminder, we may not be
able to answer all of the questions submitted to the Q&A box today, so, if your question
is not answered, please contact the Quality Payment Program Service Center at QPP — at
— sorry, [email protected] So, to start out, we have a few questions
on the MVPs. Number one is, are the MVPs designed to be
an additional option for MIPS or will it replace the current model? Hey, Lauren, this is Molly, I can answer that. So what we envision for MVPs and, again, based
off of the feedback we’ve received from stakeholders to date, we envision that there will need
to be a transition period where we maintain our normal MIPS program and our traditional
ways of participating as we work to build out MVPs internally along with stakeholders. So, again, MVP, the earliest that participation
action will be available would be in year five, which is 2021. And we envision that for that year and potentially
other years as well, we’re still working through much of this with stakeholders, that there
would be the MIPS option as well as the MVP option. I hope that helped clarify. Thanks, Molly. Next question on the MVPs are, with the MVPs,
are you required to do all of the Promoting Interoperability measures? Sure. This is Molly again. So, as we’ve — as I mentioned during the
presentation today, we envision MVPs, at least for the initial years, that they would have
a foundational element of Promoting Interoperability, which would be agnostic to, again, an MVPs. So, meaning that the Promoting Interoperability
requirement would remain consistent regardless of the MVPs that a clinician would be participating in. We — our vision also for that foundational
layer includes the population health administrative claims measures. With that being said, these are items that
we are continuing to work through when we’re engaging, and we want to continue to engage
with stakeholders as we work to develop it out. So, we’re looking forward to those future
conversations as we work to build out the MVP for future role – making. Thank you. Great. Thank you. Can you also clarify how to opt-in, please? Opt-in. Sure. So for opt-in to the program under the low-volume
threshold — so, from 2019 year, I believe we actually are — and so let me explain overall
how to do this and then I’ll let Kati give a little bit more specifics of some additional
educational materials we’ll be getting out soon. So, overall, the way that clinicians will
opt-in is really by the act of submitting data to us. So, for those of you who have gone to the
lookup tool to look at your eligibility status, you will see next to your identifiers whether
or not you could be opt-in eligible. Also, I just wanted to quickly, as in a side
flag for folks, because I saw a number of questions in the chat on when updated eligibility
information will be available both for the remainder of 2019 as well as 2020. For the updated eligibility information for
2019, that should be up in that tool no later than the end of this month. and then the 2020 eligibility should start
being available no later than the end of this calendar year, so no later than the end of
next month. But getting back to the question itself, how
do you opt-in, so essentially if you have that special status next to your name as being
opt-in eligible, you simply would need to submit data to us. When you go to actually submit data to us,
there would be some indicators on whether or not if you ar e opt- in eligible, you want
to opt-in and you want to be become a MIPS eligible clinician, or if you want to volunteer
to submit data. If you’re working with your third party, you’ll
just want to make sure that they are aware of decision so they can also communicate that
to us. But I’ll pause there to see if Kati wants
to add in anything more. Yes. So, we have available right now on our QPP
Resource Library, we have — for 2019, we have our opt-in and voluntary reporting election
toolkit. So, in that, we have some information on if
you’re an APM entity and you want to opt-in, the process and policies around that. And then we have a guide as well as a factsheet,
and the guide is really an operational tool that has screenshots and walks you through
specifically how you log into QPP and walk through the process of opting in. So, everything you need is in the QPP Resource
Library if you’re interested in that option. Okay. Great. Thank you for clarifying. Next question asks, for data completeness
in 2020, I thought that large practices get zero points if they don’t meet the seventy
percent data completeness. Can you just clarify what happens to those
who don’t meet data completeness requirements? Yes. This is Molly again. Thank you for asking that question. And I apologize, I believe I misspoke to this
and there was an error on the slide, and I believe I answered the question correctly
— wrong on this in the chat. So to clarify, I took a closer look at the
role while we were talking through here. So, yes, if you are not a small practice,
and if you fail data completeness, you receive zero points on that given measure. Again, if you are a small practice, and you
would have to have that small practice special status designation of being part of a small
practice that has 15 or fewer clinicians, if you fail Data Completeness, you can get
three points. But for everyone else for that given measures,
you fail data completeness, you would get zero points. We will look to determine whether or not Data
Completeness was achieved on a measure by measure basis, so it is very possible for
you to fail Data Completeness on any given measure, but then exceed it on other measures. So, apologies for the inconsistency there. We’ll get that clarified in our transcript,
but again, it’s zero points if you fail data completeness and you’re not a small practice. Thank you. Great. Thank you. All right. Our next question is for the Improvement Activity
scene to clarify the regulation about the 50% threshold. Basically asking, do at least 50% of providers
need to perform the IA activity in the same 90-day period? Can they perform the same IA in different
90 -day periods and can you please clarify the regulation? They can get it during any 90-day period within
the performance year as long as it’s the same Improvement Activity. Great. Thank you. All right. Stephanie, are there any questions on the
phone line? We do. We have a question from Bryan Gale. Hello. For Data Completeness in 2020, is there an
actual numeric minimum number of cases that have to be submitted? So, for our Data Completeness policy, it’s
at 70%, but we do also look to ensure that 20 cases occurred, so we also look for 20
cases for the measure as well. And the other question is, what options are
there for clinicians who want to get involved in developing MVPs? Sure. So, great question. As I mentioned here today, we just finalized
the framework effective for 2021. So, we intend to work with stakeholders in
the coming weeks and months to have additional opportunities for engagement with us to develop
MVPs. So, what I would encourage you and anyone
else on the phone who would like to work with us on developing an MVP, whether that’s, you
know, full level working with us on developing MVPs versus you may have clinicians or parts
of your organization who may want to engage in user testing with us on MVPs. I’d recommend to you today to ensure you’re
signed up for our qpp.cms.gov’s listserv because that is where we will be sending all of the
update and request for engagement with us. So please make sure you are signed up for
that. Thank you. Thank you. Our next question is from Jennifer Gasperini. Hi, Jennifer Gasperini with the National Association
of ACOs. Can you please confirm that slide 70 and 74
policies do not apply to clinicians and ACOs? We’re getting a lot of questions about that. Yes. I was just responding to that question in
the chat. The APM Quality Reporting Credit is not available
for participants in SSP ACOs because SSP Quality Reporting and MIPS Quality Reporting are one
and the same thing. However, the other rules on those slides has
to do with the way in which individuals or groups can report to MIPS for quality performance
category and there will be an AMP entity rolled up in all of that. Those rules would still be applicable in the
case where an SSP ACO failed to complete reporting. And in that case, we would then look for reporting
at other levels to create an ACO level quality score rather than assigning a zero as we had
done in the past. Thanks. It would be really helpful if you clarified
that on the educational materials. I know we’re getting lots of questions about
those policies. Thanks for addressing. Thank you. Yeah. All right. Great. So going back to questions from chat box. Next question asks, is there a bonus points
cap? Sorry, Lauren. Could you repeat the question? You cut off. Sorry. Yeah. Just asking, is there a cap on the bonus points
available? Sure. So another Quality performance category, there
are caps on the bonus points available. Typically, it is 10% of the available denominator. So for the majority of clinicians, that would
be their quality performance category denominator is around sixty points, so typically, that
would be around six points. But it can differ on a case-by-case basis
depending upon the specific clinician circumstances. Thank you. Great. Thank you. Next question asks, will Web Interface continue
to be available for groups of over 25? Sorry. Can you repeat the question, please? Of course. It asks, will Web Interface continue to be
available for groups of over 25? Yes, it will be. The Web Interface collection type is still
available for the 2020 performance period. All right. Thanks. Next question asks, if we are a Qualified
Registry that supports Quality measures of the QR that supports all of the categories
of an EHR, does the finalized requirement for 2021 mean that we will be required to
also support PI and IA as a QR or does our EHR support for PI and IA suffice? Sorry. I was talking to the mute button. And it really was responsive to my answer,
too. But you would need to be able to support — the
Registry would need to be able to support all three activities. Okay. Thank you. All right. Next, just in general, what help is availabl
e for practices that are just now starting to report for the 2020 performance year? Okay. Great. Thanks for that question, Lauren. So I would encourage — first step, if you’re
brand new to the program and trying to figure out what this program is all about and what
you need to do to participate, I would encourage you to first go to our qpp.cms.gov website. And if you go to the Resource Library, there’s
a number of general resource materials right at the top of the page. And these are specific to, right now, 2019
participation. But if you are looking for 2020 materials,
we are starting to — as we’ve just finalized our rule, we’re
starting to populate a lot of different 2020 resources. We’ll have some quick start guides available
that are really good first kind of intro documents to get you started in the program. And if you’re a small practice, I would — or
a small — or solo practice, I would encourage you to reach out to our technical assistance
that’s available. They can really help you get started. And that information is also on our website,
how to contact them, or you can always contact our QPP Service Center and they’ll connect
you to the right networks depending on where you are in the country. And then if you go to our QPP Webinar Library,
we also have some more recordings of past webinars and things, help you get started
in the program. Thanks. Great. Thank you. All right. Stephanie, do we have any more questions on
the phone line? We do have a question from Sheila Banyai. Hello. Thank you. You’ve already answered my question. All right. That’s okay. Stephanie, are there any more? We do have one additional question. Questioner, please state your name. This is David Kanter. Go ahead with your question. Yeah. In an MVP environment where presumably there
are reduced quality metric requirements, I’m trying to get a feel for the difference between
a QCDR versus a Qualified Registry. Would the representation of QCDR metrics be
as valid in an MVP environment as they are now or would those be viewed differently than
MIPS measures in an MVP context? Sure. This is Molly. So we do believe that there is a role for
a QCDR measures as we move to the MVP framework as you saw within this year’s final rule and
as Dr. Green talked about here today, we finalized the number of policies to really ensure that
the QCDR measures that we have available for clinicians who are participating under MIPS
are at the same level and at the same testing standards as the measures that we finalize
through the MIPS measurement set that go through notice-and-comment rulemaking. So, again, we do envision that there is a
role for QCDR measures and QCDRs as well as registries themselves as we move to the MVP
framework, so that’s something that we look to continue to work with stakeholders on building
that out on exactly the specifics of that. You may recall we requested comments on this
topic in particular in the RFI last year. So I would encourage you today that if — again,
if you have not signed up for our QPP listserv to go ahead and do so because as I answered
to the other comment or person who was asking the question, that would be our main mechanism
for future engagement for building up the MVPs. I hope that helps. Thank you. It does. Can I add another question, please? I think we have time for just one. Go ahead. Realizing that there’s a testing period now
required a QCDR metrics along with harmonization, reconciliation with other QCDR, did you see
any problems with QCDRs collaborating on measure development and testing those together, realizing
that eventually, you know, one QCDR has to be the measure steward? But do you see any problems with measure development
collaboration among various QCDRs? We would actually encourage measure — or
sorry, QCDR collaborations. We think that’ll lead to even a more robust
measure potentially. Great. Thank you. Thank you. All right. Thanks, everybody, for that. It looks like that’s all the time that we
have for today. So we’ll go ahead and close the Q&A. And Kati, I’ll pass it back to you to conclude. Great. Thanks, Lauren. And thanks, everybody, for joining today and
for joining in the discussion. We really appreciate you participating. And just a reminder, all of our slides, transcripts,
and recording will be up on our Webinar Library in the next couple of weeks. So thank you all and we’ll talk to you soon. Thank you. This concludes today’s conference. You may now disconnect. Speakers hold the line.

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