MIPS/QPP Reporting Assistance Available from KHIN
Are you eligible for the Quality Payment Program (QPP) in 2018 and required to report data to CMS next January, February or March as part of QPP? MIPS-eligible providers in Kansas can receive assistance from KHIN to select quality measures and identify if patient data is adequate for reporting purposes throughout the year. 

Despite the fact that quality measures account for 50 percent of a provider’s MIPS score, too often, providers report data without understanding how it will translate into MIPS points, and what adjustment will be made to future Medicare reimbursements as a result.

  • Breast Cancer
  • Cervical Cancer
  • Colorectal Cancer
  • Controlling High BP
  • Influenza vaccination
  • Pneumonia vaccination
  • Tobacco screening/cessation

KHIN can provide feedback for a total of 36 quality measures on a semi-regular basis.

Members may utilize KHIN’s Doctors Quality Reporting Network, a CMS-approved Qualified Clinical Data Registry (QCDR). The QCDR marries the collection of patient data and the submission of data into one entity of physicians, and currently submits National Committee for Quality Assurance (NCQA) and ONC certified electronic clinical quality measures (eCQMs), Promoting Interoperability (PI) and Improvement Activities (IA) to CMS.
All MIPS-eligible KHIN members can report (attest) their clinical IA and PI measures at no cost. However, there is a fee associated with reporting quality measures to CMS, and August 15 is the deadline to sign up for this service in 2018 . Contact Josh Mosier or Brenda Kebert for more information.
Return on Investment for Health Information Exchange Participation
Laura McCrary, Ed.D,
Executive Director, Kansas Health Information Network and Senior Vice President, KAMMCO

What is the return on investment (ROI) for participating in a health information exchange (HIE)? As the Executive Director of one of the most successful HIEs in the nation, I am often asked this question. I admit I am challenged to answer, as there are several ways to define ROI, and it can mean different things to different people. 

Simply stated, ROI measures the benefit (or return) an investment will generate in relation to the cost of the investment. So, if it costs X to participate in the HIE, what is the financial return to a practice or facility?   

While the ROI calculation for some is framed in strictly financial performance terms, for others it can mean increased productivity and efficiency, minimal disruption to workflow, and improvements in care. As part of an Accountable Care Organization (ACO), or another alternative delivery model, the HIE ROI question will be impacted by resulting improvements in risk adjustment scores and quality metrics. For a payer, the question is whether the HIE will be able to provide data to improve HEDIS scores and STAR ratings. For a patient, the question is simply will the HIE improve my care or my child’s care, and can I access my health records?  

Inherently, the HIE ROI is puzzling because the answer is different for each organization.  I have heard time and again, “why should a healthcare organization (hospital, physician, payer, therapist, FQHC, mental health provider, post-acute care provider, etc.) pay to provide something of value, such as clinical data, to an HIE?” 

This is the “chicken or the egg” question of which comes first. In order for an HIE to have a significant ROI for its members, a certain level of scale or participation by healthcare providers has to occur. One doctor or hospital participating singularly in an HIE does not create much HIE ROI value, however, when all of the healthcare providers in a community, region, or state participate in a HIE, the ROI is noticeably impacted. 

With robust clinical data available, the basic HIE ROI for physicians starts with reducing the time the physician or staff spend gathering the patient’s medical information from disparate sources. A conservative estimate is at least 15 minutes a day of searching and securing medical records can be saved by using the HIE. This 15 minutes allows the physician to see one additional patient daily. One additional patient per day in a fee-for-service model conservatively results in $10,000 annually ($50 x 5 days x 40 weeks). In a three-physician practice this adds $30,000 annual revenue. 

HIE fees for a small practice would be approximately $3,000 annually, with a $10,000 onetime-fee for necessary interfaces. For example, in the first year the practice could realize a $17,000 gain, or an ROI of $1.30 for every $1.00 invested. In the second year and thereafter, the practice could realize a $27,000 gain, or $9.00 for every $1.00 invested.  

The ROI is different for hospitals. For a PPS hospital with diagnosis related groupings (MS-DRGs), the additional information provided by the HIE may significantly increase the hospital’s case mix index (CMI).  

A recent hospital study demonstrated patients receiving care at a small hospital visited 10 other healthcare facilities in the calendar year reviewed. Analysis of the hospital’s problem list (after de-duplication) indicated only 25% of the total problems found in the HIE were present in the hospital EHR and billing­­­. This finding significantly impacts the hospital’s bottom line. Overall the inclusion of the HIE data resulted in a 227% increase in potential ICD-10 codes over what was available in the hospital’s EHR, with an average CMI increase of .44 and an annual increase in MS-DRG payments of $90,000. 

The participation fee for a small hospital HIE is approximately $15,000 annually, with a onetime interface cost of $30,000. This results in a 1:1 first year ROI, with significant returns 5:1 in subsequent years of $5.00 for every $1.00 invested. 

If this same hospital also participated in some form of alternative payment model (APM) the ROI example could be even greater. In most APMs, patient risk scores and the associated payments are based on the complexity of a patient’s health conditions. Each patient is assigned a risk score. This score is based on the problem list for the patient that is included in the billing submitted to the payer. If the problem list is incomplete and reflects only 25% of the total problems patients have been diagnosed with, then the hospital may receive a significantly lower level of reimbursement.  

Utilizing the same small hospital example with Medicare Advantage patients only, the risk adjustment factor (RAF) score increased by 75% when the HIE problem list data was added into the claim. The overall population RAF score increased by 88%. Based upon an estimated monthly $600-$800 risk bonus premium, this results in an overall revenue opportunity of $350,000-$500,000 annually per 1000 Medicare Advantage patients.  

An ACO or Advanced APM may realize a similar ROI on a larger scale.  

Finally, the ROI for patients cannot be evaluated through the same financial performance lens the provider community applies. If the available HIE data saves a patient’s life, either by informing care or preventing a medical error, it may be impossible (or inappropriate) to calculate a traditional ROI, however, the benefit returned has immense value. This is the core patient safety imperative delivered by HIEs across the nation.   

The Kansas Health Information Network (KHIN) recognizes this opportunity, and offers a free personal health record to all Kansas patients through myKSHealtheRecords. The personal health record is connected to the HIE which allows patients to have simple and secure access to all of their health information in one location. In addition, there is ROI for patients in the value of time and money saved when eliminating duplicative testing and the re-creation of patient history for providers. 

KHIN is a physician-led health information network offering a suite of health information technology tools to help Kansas healthcare and healthcare professionals CONNECT. ANALYZE. TRANSFORM. Visit www.khinonline.org or call 877.520.5448 to learn more.
Visit the QPP Website to View MIPS Performance Feedback and Final Score
If you submitted 2017 Merit-based Incentive Payment System (MIPS) data through the Quality Payment Program website , you can now view your performance feedback and MIPS final score

Access your performance feedback and final score by: 

  • Going to the Quality Payment Program website
  • Login using your Enterprise Identity Management (EIDM) credentials; these are the same EIDM credentials that allowed you to submit your MIPS data

If you don’t have an EIDM account, refer to this guide and start the process now. In the coming weeks, CMS will provide additional guidance to help walk through how to review your feedback and to assist in answering your questions. 

Please note: The final performance year for the Value-Based Modifier and Physician Quality Reporting System (PQRS) programs was 2016; therefore, CMS will no longer provide PQRS Feedback Reports or Quality and Resource Use Reports (QRURs). The final reports under these programs were provided in September 2017 and remain available for download through the end of this year.  
Likewise, if you participated in a MIPS Alternative Payment Model (APM) in 2017, specifically in a Medicare Shared Savings Program (Shared Savings Program) or Next Generation Accountable Care Organization (ACO), your performance feedback is now available to your ACO (APM Entity) via the Quality Payment Program website . Participant TINs in Shared Savings Program will be able to login to the Quality Payment Program website directly to access final performance feedback. Participants in Next Generation ACOs will need to request feedback from a representative (such as a security official) within their APM Entity.

Please note: Because all clinicians in the Next Generation ACO Model were Qualifying APM participants, performance feedback for the 2017 performance year will not be provided.

Under the MIPS APM Scoring Standard, the performance feedback, accessible to the APM Entity, will be based on the APM Entity score and is applicable to all MIPS eligible clinicians within the APM Entity group. This feedback and score does not have any impact on the Shared Savings Program or Next Generation ACOs’ quality assessment. 

Questions?  If you have questions about your performance feedback or MIPS final score, please contact the Quality Payment Program by: 

MIPS Eligible Clinicians or Groups Can Request CMS
Review of 2019 MIPS Payment Calculation
If you participated in the Merit-based Incentive Payment System (MIPS) in 2017, your MIPS final score and performance feedback is now available for review on the Quality Payment Program website . The payment adjustment you will receive in 2019 is based on this final score. A positive, negative, or neutral payment adjustment will be applied to the Medicare paid amount for covered professional services furnished under the Medicare Physician Fee Schedule in 2019.

MIPS eligible clinicians or groups (along with their designated support staff or authorized third-party intermediary), including those who are subject to the APM scoring standard may request CMS review their performance feedback and final score through a process called targeted review. 

When to Request a Targeted Review
If you believe an error has been made in your 2019 MIPS payment adjustment calculation, you have until September 30, 2018, to request a targeted review. The following are examples of circumstances in which you may wish to request a targeted review:  
  • Errors or data quality issues on the measures and activities you submitted;
  • Eligibility issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment);
  • Being erroneously excluded from the APM participation list and not being scored under APM scoring standard; or
  • Not being automatically reweighted even tough you qualify for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy.

Note: This is not a comprehensive list of circumstances. CMS encourages submission of a request if you believe a targeted review of your MIPS payment adjustment (or additional MIPS payment adjustment) is warranted.

How to Request a Targeted Review
You can access your MIPS final score and performance feedback and request a targeted review by:
  • Going to the Quality Payment Program website, and login using your Enterprise Identity Management (EIDM) credentials; these are the same EIDM credentials that allowed you to submit your MIPS data. Please refer to the EIDM User Guide for additional details. 

When evaluating a targeted review request, CMS will generally require additional documentation to support the request. If your targeted review request is approved, CMS will update your final score and associated payment adjustment (if applicable), as soon as technically feasible. CMS will determine the amount of the upward payment adjustments after the conclusion of the targeted review submission period. Please note that targeted review decisions are final and not eligible for further review .

Questions? If you have questions about your performance feedback or MIPS final score, please contact the Quality Payment Program by: phone: 1-866-288-8292/TTY: 1-877-715-6222 or email: QPP@cms.hhs.gov .

Just a reminder CMS reporting for the Quality Payment Programs can be simplified using the tools and resources of the Kansas Health Information Network (KHIN). For more information on KHIN, contact Josh Mosier at jmosier@khinonline.org or visit www.khinonline.org.
Keeping Pace With the Interoperability Landscape TEFCA, What It Is and How It Will Work
The Trusted Exchange Framework and Common Agreement (TEFCA) will define standards for interoperability as required by the 21 st Century Cures Act signed into law in December 2016. The 21 st Century Cures Act contains a number of interoperability requirements, including the creation of a Trusted Exchange Framework being built through TEFCA with oversight by the Office of the National Coordinator (ONC).

Following a comment period, the final version of TEFCA will be published in the Federal Register later this year. The draft TEFCA guidance contains policies, procedures, and technical standards that the government views as an on-ramp to interoperability. This coordination is expected to bridge the gap between providers’ and patients’ information systems and enable interoperability across disparate Health Information Networks.  

TEFCA is meant to establish a single way for Health Information Exchanges (HIEs), enabling providers, hospitals and other healthcare stakeholders to join any health information network (HIN) and automatically connect and participate in nationwide health information exchange.

TEFCA also creates “Qualified” HINs as a vehicle to facilitate a standardized methodology for HIE interconnectivity, along with a new administrative organization, the Recognized Coordinating Entity (RCE). The concept is to create a network of networks and connect authorized participants or end users, including payers, vendor networks, government agencies, individuals, and the nation’s 100-or-so HIEs such as KHIN, the physician-led HIE created in partnership with Kansas Medical Society. 
An Update on New Medicare Cards
As a reminder, the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 , requires the Centers for Medicare & Medicaid Services (CMS) to remove Social Security Numbers (SSNs) from all Medicare cards by April 2019. A new Medicare Beneficiary Identifier (MBI) will replace the SSN-based Health Insurance Claim Number (HICN) on the new Medicare cards for Medicare transactions like billing, eligibility status, and claim status. Delivery of cards in Kansas began in July 2018. 

Beginning in October 2018 and through the transition period (which ends December 31, 2019) when providers submit a claim using a patient’s valid and active HICN, CMS will return both the HICN and the MBI on every remittance advice. Here are examples of different remittance advices:
Medicare Remit Easy Print (Medicare Part B providers and suppliers)

Individuals should start using their new Medicare cards right away. Doctors and healthcare providers should ask for new Medicare cards when providing care, and encourage patients to destroy their old Medicare card. 

However, patients in a Medicare Advantage Plan, like an HMO or PPO, should continue to use their Medicare Advantage Plan ID card whenever care is needed. 

Visit Medicare.gov/NewCard to learn more about your new Medicare card.
Promoting Interoperability
CMS recently restated its commitment to improving interoperability and patients' access to health information. To reflect this focus, CMS renamed the EHR Incentive Programs to the Promoting Interoperability (PI) Programs. CMS also plans to streamline the programs to reduce the time and cost required of providers to participate.

This is exciting news for physicians and their patients, and great news for KHIN participants who have access to all of the tools required to align CMS's aim to become patient centric. To learn more about how this rule-making affects Medicare eligible clinicians participating in the Promoting Interoperability (formerly Advancing Care Information) performance category of the Merit-based Incentive Payment System (MIPS), visit the Quality Payment Program website, https://qpp.cms.gov/ and stay tuned for more information.

To become a KHIN participant, visit www.khinonline.org or contact Josh Mosier at 785.231.1341.
New Resources Available From CMS:
CMS has posted new resources on CMS.gov to help eligible clinicians and groups understand their Merit-based Incentive Payment System (MIPS) final score, performance feedback, and payment adjustment, as well as the targeted review process.

The new resources include:

For More Information: Visit the Quality Payment Program Resource Library on CMS.gov to review new and existing Quality Payment Program resources. Contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222). 

Just a reminder CMS reporting for the Quality Payment Programs can be simplified using the tools and resources of the Kansas Health Information Network (KHIN). For more information on KHIN, contact Josh Mosier at jmosier@khinonline.org or visit www.khinonline.org .
Come See Us!
September 6 - 7, 2018
Kansas Hospital Association
2018 Annual Convention and Trade Show
Sheraton Overland Park/Overland Park Convention Center
Overland Park, KS
September 21 - 22, 2018
Kansas Medical Society
22nd Annual Meeting
Topeka, KS

Josh Mosier
Manager of Client Services